Fire and emergency services safety officer chapter 12. HSO Reporting and Recommendations

• HSOs must submit formal reports and recommendations on health and safety issues to the fire chief and/or organizational administration.
• These reports come from departmental records, research data, the occupational safety and health committee, accident investigations, near-misses, and post-incident analyses.
• Reports reflect the organization’s performance and consistency between policy and practice.
• Reports are an opportunity to inform organizational leadership about safety and health issues.

Required Reports

• HSOs must create regular reports on SOP/G compliance.
• HSOs must create regular reports on training program compliance, as well as fire department accidents, occupational injuries, deaths, and exposures.
• Information must be compiled and analyzed to produce recommendations.
• Reports should be submitted to the fire chief on a set schedule, such as semiannually.
• Reports should provide a comparison between the department’s records and national fire and industry safety and health data.
• Reports should help determine developing trends
• Reports are based on department audits, incident reports, surveys, accident reports, injury reports, inspection reports, and other department information.

Qualities of Formal Reports

• Legibility: text must be printed or typed rather than in script
• Research: text must be based upon factual information
• Clarity: concise wording that is grammatically correct and error-free
• Accuracy: times, addresses, names, quantities, and events must be correct
• Completeness: all available information must be included
• Objectivity: text must express facts and not opinions and cannot be subjective
• Reports help decision-makers create or modify existing policy based upon accurate information.

Types of Narrative Reports

• Justification: focuses on why a certain course of action was or should have been taken, useful for budget requests, purchase recommendations, or after-action reports
• Recommendation: states the problem, policy, practice, and proposed best solution
• Progress: provides an overview of the current status of a project, is chronological, and allows the audience to visualize project development, useful for long-term projects
• Progress and Justification: combines the two forms into one by providing justification for the project, describing the steps to complete the project, and including justification for any changes in the project development.
• Description: describes a process, project, or item that gives the audience a detailed image of the subject, useful for describing a new apparatus design or the steps necessary to implement a rapid intervention crew policy

Steps for Writing Reports

• Research the topic thoroughly, including background data from previous reports, personal experience, interviews, analysis, and other documents.
• Include source citations in the form of footnotes and endnotes to provide credibility and direct the audience to the original material.
• Know your audience: knowing who you are writing a report to will drive what to include in the report and the writing style used
• Determine the format of the report: formal written reports require structure
• At a minimum, include a title page, introduction, background, body, recommendations, and a conclusion or summary.
• An executive summary may also be included to provide a brief review of the key points.
• Write in the first person using active voice.
• Do not include opinions or subjective information.
• Keep it concise with factual, accurate, and objective information.
• Develop a draft: this process involves getting the basic information on paper and do not worry about perfection
• Develop and include pictures and exhibits, as illustrations, graphics, diagrams, and photographs in a report are useful additions to present information briefly and concisely.
• Review and edit: this is an ongoing process of reading the report for grammar and spelling, verifying facts, documenting references, and revising the report
• Review and edit continuously and have other individuals proofread it to ensure that they understand the content and concur with the writing style and structure.
• Develop the final report and let it sit for a day or two, then review it again to ensure it addresses the reason for the report.
• Ensure the final report is satisfactory, as any written report submitted is a direct reflection on the author.

Report Considerations

• Take the time to investigate and research the facts, read or collect testimony from witnesses and on-scene personnel, find appropriate reference material, proofread for grammar and spelling, and edit, edit, edit.
• Getting an extra set of eyes helps ensure it is logical and complete.
• All report documents, both final and in-process, may be requested under public records laws.
• High-quality reports will lend credibility both to the author and the information.

Report on SOP/G Compliance

• SOP/Gs should be reviewed and assessed for continued adequacy and applicability.
• The HSO and the occupational safety and health committee should develop a schedule for these reviews.
• The review schedule should include assessment of topics regarding occupational health and safety.
• Other fire department divisions will review the same SOP/Gs based upon criteria important to their divisions.
• The report should also include the consequences of noncompliance

SOP/G Compliance Report: Topics

• Risk management, such as rehabilitation protocols and communication procedures.
• Training and education, such as frequency of training and recertification requirements.
• Accident prevention, such as accident reporting procedures.
• Records management, such as retention and security procedures.
• Accident and equipment, such as equipment use procedures and equipment inspection record programs.
• Facility and equipment inspections, such as daily, monthly, annual, and OSHA or state labor inspection procedures.
• Health maintenance, such as physical assessment procedures, fitness-for-duty records and reporting.
• Infection control, such as exposure procedures, bloodborne pathogens procedures

SOP/G Adequacy and Effectiveness

• The HSO will include information on the adequacy of current SOP/Gs in the SOP/G compliance report.
• SOP/Gs must address all accepted practices and associated procedures that are expected to be followed.
• Flexibility of guidelines in the SOP/Gs should be included where appropriate.
• Any gaps between SOP/Gs and practices/procedures must be included in the report.
• When considering adequacy, the HSO should assess whether a normalization of deviation has occurred, as these deviations can indicate needed changes to personnel behavior or a need for updating a policy.
• The SOP/G compliance report must contain information on the effectiveness of current SOP/Gs.
• SOP/Gs are effective if they address risk management concerns and provide needed guidance to personnel in accomplishing operational effectiveness.
• HSOs analyze all injuries, deaths, illnesses, exposures, accidents, and near-misses and then report on whether the SOP/Gs provide the needed guidance for some standardization of operations while maintaining flexibility when needed.
• The HSO conducts a gap analysis on what SOP/Gs address and where deficiencies exist and revisions are needed.

Report on Training Program Compliance

• The HSO will report on training program compliance with regards to safety and health, and include any deficiencies or improvement recommendations.
• This report should outline how well the organization achieved mandatory safety and health training, and the inclusion of safety and health topics in all other training.

Mandatory Training Examples

• Annual OSHA refresher training, including respiratory protection training.
• Infection control and prevention
• Bloodborne pathogen training
• Annual HIPAA compliance
• OSHA Hazard Communication
• New apparatus, equipment, and/or protective clothing in-service
• New or revised operating procedures

Report on Accidents, Occupational Injuries, Illnesses, Deaths, and Exposures

• The HSO is responsible for producing a regularly occurring report that outlines any department accidents, occupational injuries, illnesses, deaths, and exposures.
• This report provides a comparison between the department’s records and national fire and industry safety and health data.
• This report helps to determine trends that may be developing.
• The report should be based on department audits, incident reports, surveys, accident reports, injury reports, inspection reports, and other pertinent department information.
• The report should contain comparison data on similar occurrences in the local, regional, state, and national setting, or comparison data between similar departments.
• Analyzing accidents from different locations may provide valuable lessons learned that can be incorporated locally.
• Once an issue or trend is identified, recommendations for risk control measures must be identified and communicated in the report
• Reporting requires review of accident investigations and reporting on the root cause findings that resulted.
• The HSO must report facts and not allow bias or personal opinions to influence the report.
• The HSO is responsible for providing recommendations to prevent similar future events from occurring, not recommending disciplinary action.
• Ethical considerations can also be used to help create change.

Current Local and National Fire Service Trends

• HSOs should examine local and national reports for any developing trends.
• All accidents, near-misses, injuries, deaths, illnesses, and exposures reports provide valuable clues and lessons to improve departmental practices, training, and culture.
• The HSO should gather these reports, discern critical information, and include a summary in the written report.
• Comparison with identified trends should follow the trend data.
• Some trends will be localized to a department or jurisdiction, while other trends may have national significance that alters standards, best practices, or training manuals.
• The HSO has the most impact at the local department level by recommending changes before they become trends.

Prevention or Mitigation Recommendations

• The HSO, with assistance from the occupational safety and health committee, should identify prevention or mitigation recommendations.
• This process should include a root cause analysis of departmental incidents and accident reports.
• Prevention and mitigation recommendations should be directed at improving processes, practices, or the culture, not assigning blame to individuals.

Recommendations for Change

• Recommendations for change should include specific assignments with names, time frames for compliance, and schedules for follow-up reports.
• Recommendations are based on research, the need to correct an unsafe practice or procedure, and new evidence-based technologies and methods.
• Compiling this information with additional hazard identification and control measures helps the HSO and the occupational safety and health committee generate recommendations to reduce accidents, injuries, and loss.
• Recommendations should address any deficiencies in compliance with laws, codes, regulations, and standards.
• Training recommendations should include curriculum updates, ergonomic issues identified from injury reports, rehab, and preburn inspections.

Accident Review Boards (ARB)

• Accident Review Board (ARB) is a committee of department personnel and stakeholders whose responsibility is to review vehicular accident investigations

Considerations for HSO Recommendations

• Accident or incident injury investigation: may include recommendations to prevent or reduce the chance of a repeated incident based on investigations, and may include input from a supplemental ARB
• Treatment and transport of an injured department member: may include recommendations to revise SOP/Gs regarding the treatment, transportation, and medical facility options for any injured department member
• Driver/Operator: may include recommendations for SOP/Gs, certifying courses, and recertifying criteria
• Safety audits: recommendations should address any deficiency in workplace practice, procedure, or legal mandate compliance
• Post-incident analysis: recommendations based on deficiencies or preventative measures necessary to improve safety based upon firefighter performance during incidents
• Consideration should also be given to company officer, Command staff, and junior officer training and refresher training.
• Training should be in place to prepare members for moving up to the next level of responsibility, as attrition occurs in a department.
• Training and certification of specialty positions should be assessed for compliance with local SOP/Gs and NFPA® standards

Accident Review Boards (ARBs)

• In some jurisdictions, an ARB is convened regularly to review all vehicular accidents involving departmental vehicles or personnel.
• The board members will vary among jurisdiction and could include the battalion chief, company officers not involved in the accident, a jurisdictional safety officer or risk manager, or members of the training division.
• The purpose of the board is to provide accountability and quality assurance of the investigation process.
• The team can forward determinations of preventable/nonpreventable events with or without contributing factors.
• During board hearings, those involved in the accident and investigation will have an opportunity to present their account of events to the board and answer any questions that the board may have.
• This testimony is typically internal to the organization, but considerations for confidentiality should be included in SOP/Gs for the board proceedings.
• Disciplinary action is not the intention of ARB review; however, when the individuals involved in the accident have a history of SOP/G infractions, some boards are allowed to be specific in their disciplinary recommendations.

ARB Responsibilities Upon Completion of Review

• Determine whether accidents were preventable
• Verify that investigations were thorough and impartial
• Determine causative factors relating to the accident that may have been missed
• Make recommendations to prevent future accidents

ARB Report

• Reports from the ARB become a part of departmental records, and the fire chief has the enforcement responsibility to either follow the boards’ recommendations or take other action.
• The board may review reports from earlier meetings and accidents to help inform future decisions.

Recommendations from the Occupational Safety and Health Committee

• The occupational safety and health committee serves an advisory role when making recommendations to the fire chief.
• The HSO’s responsibility is to guide the committee in its decision-making process and report its recommendations to the fire chief or appropriate authority.
• Disciplinary action is one issue that is not an objective of the committee.
• The activities and issues that are addressed must be within the committee’s scope.
• The committee’s intent is to conduct research, develop recommendations, and study and review matters pertaining to occupational health and safety within the department.

Improvements to Safety and Health Programs

• Improvements to safety and health programs are an ongoing process.
• The HSO serves as the main point of contact for all safety and health programs and any improvement recommendations.
• These recommendations should be based on research and not the latest fad.
• The HSO must be able to justify improvements and explain why they are needed.
• Showing how an existing program is deficient or obsolete will help the membership understand the importance of any change.
• Getting personnel to accept the change is essential for the success of any program.
• Changes in equipment, procedures, and methods should come after data analysis of accidents, near-misses, injuries, deaths, illnesses, and exposures is completed.
• The recommendations may come from safety audits, accident reports, and/ or root cause analysis reports.
• The HSO should examine all of the above to determine if equipment, procedures, and/or methods of operations are trending toward an unsafe condition.
• The goal in making changes is to improve the safe working environment for all personnel.