Fire and emergency services safety officer chapter 5. SOPs and HSO Responsibilities

• Most fire and emergency service organizations have written organizational policies and procedures, named standard operating procedures (SOPs), standard operating guidelines (SOGs), or policy and procedures manual (PPM), depending on the AHJ’s adopted definition.
• Departmental manuals can be divided into administrative policies, outlining the organization's mission, responsibilities, and authority, and operational procedures, detailing how members function, and processes.
• Policy and procedure documents specify expected performance of members.
• SOP/G refers to the policy and procedure manual.

HSO Responsibilities for SOP/Gs

• HSOs serve on teams to develop, evaluate, and revise SOP/Gs, ensuring they address workforce and workplace safety and health.
• HSO's responsibilities:
• Developing a policy for risk management
• Identifying and recommending policy and procedure improvements
• Training personnel, and evaluating training procedures for safety
• Developing corrective actions
• Ensuring established training evolution procedures, and preburn inspection procedures for all live-fire training evolutions
• Ensuring safety investigation procedures, and procedures for treating and transporting injured or ill members
• Ensuring incident rehabilitation procedures, and the inclusion of a safety and health component in postincident analysis

Occupational Safety and Health Program Procedures

• Written policies and procedures ensure effective and efficient operations.
• Procedures establish benchmarks for performance despite workplace or response environment changes.
• Procedures document the organization's expectations based on strategic and operational plans.
• Procedures may be created due to safety issues, changes in standards or regulations, or to formalize safe work behaviors.
• General steps for determining the need for a new policy or procedure:
• Identify the problem or requirement
• Collect data to evaluate the need, including best practices, standards, and regulations
• Select an evaluation model: goals-based, process-based, or outcome-based
• Establish a timetable for evaluation
• Conduct the evaluation
• Select the best response, which may include no policy at all
• Select alternative responses
• Establish a revision process or schedule
• Recommend the policy or procedure
• Consider the need for legal adoption
• FEMA’s "Developing Effective Standard Operating Procedures for Fire and EMS Departments" is a helpful resource for HSOs in SOP/G development.

Effectiveness Assessment and Criteria

• SOP/G manuals must address administrative and operational needs and be regularly reviewed for appropriateness and effectiveness.
• Reviews should occur on a schedule, and unscheduled reviews will occur following incidents or investigations.
• Focus on both successful and unsuccessful operations during SOP/G reviews within the scope of the incident.
• Each incident is unique; SOP/Gs must provide guidance for all hazards, with flexibility for various situations.
• HSOs should focus on the safety and health aspects when assessing SOP/G effectiveness.
• Criteria for assessing effectiveness include:
• Successful incident conclusion
• Sufficient guidance for team coordination
• Applicability and relevance to current practices
• Flexibility for adaptation
• Occurrence of injuries, fatalities, illnesses, or exposures
• Positive impact of incident risk analysis
• Appropriateness of deviations from SOP/Gs
• Compliance with laws, codes, regulations, or standards
• The goal is to improve responder performance while ensuring safety and health.
• HSOs should oversee the policy and procedure review process.

Fire Department Operations

• Standardized operational SOP/Gs ensure consistent performance during incidents.
• SOP/Gs should provide direction without limiting member's abilities.
• Assess overall performance against SOP/G guidance to determine effectiveness.
• HSO's role:
• Assessing safety and health aspects
• Significant involvement if injuries, fatalities, illnesses, or exposures occur
• Determining mutual aid or automatic aid operational differences that may affect responder safety and health

Training Practices

• HSOs proactively ensure procedures are in place before training.
• Training evolutions should replicate realistic response environments safely and are beneficial for assessing the adequacy of SOP/Gs in a controlled environment.
• The process can be viewed as a cyclical sequence of reviews.

Safety Subjects to Include

• HSOs focus on safety and health concerns, including:
• Emergency vehicle operations
• Incident Command System use and accountability
• Incident and technical safety officers use
• Incident Action Plan with risk analysis
• Recurring injuries, like sprains and strains
• Member physical fitness importance
• Proper protective clothing/equipment training, inspection, and use
• Rapid intervention crews (RICs) use
• Backup teams use
• Rehabilitation of members
• Compliance with safety and health laws, codes, regulations, and standards
• Training on newly implemented practices and new apparatus or equipment

Compliance with Laws, Codes, Regulations, and Standards

• SOP/Gs must comply with:
• State, provincial, and federal regulations, including OSHA
• State, provincial, and local traffic and vehicle operation laws
• Apparatus, equipment, and protective clothing specifications standards
• FOIA or state/local open records laws and retention schedules
• HIPAA regulations
• NFPA® consensus standards, codes, and guides
• NIMS and ICS compliance
• Environmental protection regulations

SOP/G Creation

• HSOs identify the need for new SOP/Gs to improve firefighter safety and health, using a standard format matching the AHJ’s procedures manual.
• Transcribing information from other sources into the SOP/G should be considered.

SOP/G Format and Template

• Procedures manual typically includes:
• Statement of purpose and scope
• Contents page
• Procedures/policies organized by topic/function
• Appendices with copies of forms
• Each page includes:
• Subject
• Procedure number
• Dates (original and revisions)
• Supersedes (replaced procedure number)
• Approvals (initials)
• Distribution (list of recipients)
• Applicability (persons/groups affected)
• Pages (number in document)
• Revision status
• Forms used
• Track the copies of the policy and procedures manual, making them available to the administration.
• Current and archived copies of procedures should be available to the administration.

New SOP/G Distribution

• Distribution methods:
• Paper documents
• Email lists
• Networked server systems for central access
• The HSO may delegate training on new or revised health and safety procedures to the training division.

Material Added from Other Sources

• When writing SOP/Gs, information is drawn from various sources like laws, codes, standards, other jurisdictions’ SOP/Gs, research reports, manufacturer recommendations, emergency management plans, and postincident analyses.
• Properly cite or acknowledge source for information.
• Ensure compliance with legal mandates and incorporation of safety and health requirements.
• Collaborate with other agencies, EMS, and special operations teams, especially for mutual aid.
• Reference fire science and investigative reports, and manufacturer guidelines.
• Align with federal, state, and local emergency management plans to support operational practices.
• Use postincident reviews to improve SOP/Gs and incorporate lessons learned from actual incidents and events.
• Consult manuals like FEMA’s "Emergency Incident Rehabilitation" and the "National Fire Service Incident Management System Consortium Model Procedures Guide for Structural Firefighting."

SOP/G Revision

• Revise SOP/Gs only when a demonstrated need exists.
• HSOs should distinguish between deviations from good procedures and poorly written or outdated procedures.
• Implementation of new procedures should be monitored to ensure proper adherence.

Verification of Procedures

• SOP/Gs must be followed, reviewed, and updated/removed.
• HSOs verify SOP/G use during postincident analysis and accident investigations.
• Document deviations from SOP/Gs, but do not police the operational setting.
• Rely on company and chief officers to supervise and enforce policies within the chain of command.

Revision Process

• The revision process is included in the policy or procedures manual and is based on answers to the following questions:
• When should it be revised? Is there a specific timeline?
• What conditions or circumstances would cause it to need revision?
• How should it be revised: completely, partially, or not at all?
• Indications that a policy or procedure needs to be revised:
• Increase in policy infractions
• Injuries or property loss due to procedure failure
• Change in resources used
• Change in the problem addressed
• Policies and procedures should be continually monitored for effectiveness and revised as needed.

Live-Fire Training Procedures

• Live-fire training procedures:
• Must follow applicable laws, codes, regulations, and standards, and NIOSH reports for lessons learned
• Need to cover all types of exercises
• HSOs ensure procedures address safety and health for all participants, and work with the Training Division.
• NFPA® 1403 is the guiding document, but state/provincial and local regulations also apply.

Requirements for Live-Fire Training

• Common safety and health requirements for all live-fire training evolutions:
• Fire types
• Interior versus exterior requirements
• Fuel loading/fire location
• Weather conditions
• Safety officers present, and safety officer training includes specific knowledge of the type of fire
• Rapid Intervention Crews (RICs)
• Rehabilitation/emergency medical procedures
• Preburn inspection procedure
• No live victims
• Structure/facility reassessment after each evolution
• Procedures should also address:
• Protective clothing/equipment inspections
• Water supply and communications plans
• Emergency plans
• Resource allocation

Requirements Unique to Fixed Facilities

• HSOs Inspect fixed facilities, addressing any structural damage.
• Inspections:
• Preburn inspection
• Annual structural inspection
• 5-year structural inspection by a licensed engineer
• All openings and safety devices must be operational.
• AHJ or building owner does an annual evaluation of structural integrity, including core sampling of the concrete.

Requirements Unique to Acquired Structures

• HSOs Considerations for acquired structures:
• Permits/permission obtained
• Site evaluation for hazard removal (asbestos, vegetation, debris)
• Protection of neighboring properties
• Unobstructed routes
• Inspection of structural integrity, wall/floor openings, stairwells
• Securing of utilities

Preburn Inspections of Acquired Structures

• HSOs ensure that acquired structures meet NFPA® 1403 standards, including:
• Structural integrity
• Hazardous material removal
• Repair of structural members, stairs, walls, ceilings, and floors
• Secure loose bricks in masonry walls or chimneys
• Adequate roof ventilation
• Shutting off utilities
• Removing trash, debris, combustible fiberboard coverings, vermin, and insects
• Exposure protection for adjacent structures
• Vegetation removal
• The use of the acquired structure for live-fire training should not take place if firefighter safety and health procedures have not or cannot be completed.
• Provide sufficient egress routes, and develop a predetermined evacuation plan.
• Ensure that all participants understand the incident management system to be used.

Medical Emergency Procedures

• Emergency services organizations have SOP/Gs in place that deal with accidents or incidents.
• Established SOP/Gs provide guidelines for decision-making, easing stress when making decisions.
• Key areas for SOP/G development:
• Recognizing the signs and symptoms of injuries and illnesses
• Providing rehabilitation at emergency scenes and training evolutions
• Evaluating the seriousness of the injury/illness
• Treating the injured/ill member(s)
• Notifying the immediate supervisor of the injured/ill member(s)
• Obtaining the right medical transportation resource for the member(s)
• Having the member(s) transported to the appropriate medical facility, if necessary
• ICS Form 206, Medical Plan, can be used.
• Additional responsibilities for immediate supervisors/commanding officers include:
• Notifying the fire chief via chain of command
• Notifying other fire department members (limited to life-threatening injuries/illnesses)
• Notifying the family (if the injured/ill members are unable to)
• Ensuring paperwork is completed and forwarded
• Having Critical Incident Stress Management (CISM) services available

Vital Sign Measurements

• Medical surveillance is important to ensure firefighter health during a response and should be a part of the rehabilitation function at an incident.
• Vital sign values that should be measured during rehabilitation:
• NFPA® 1584, Standard on the Rehabilitation Process for Members During Emergency Operations and Training Exercises
• FEMA FA-314 Emergency Incident Rehabilitation
• NFSIMS, Model Procedures Guide for Structural Firefighting

Procedures

• Procedures should outline who is responsible for what.
• HSOs need to follow up during accident investigations and postincident analysis to check medical emergency procedures.

Identification of Appropriate Medical Facilities

• Depends on:
• The severity and type of injury/illness
• The geographical location of the person and the facility
• The mode of transportation
• HSOs help identify the most appropriate medical facility.
• Appropriate medical facilities specific to life-threatening situations include:
• Burn centers
• Trauma centers (Level I-IV)
• Neurologic specialty centers
• Cerebrovascular specialty centers
• Cardiovascular specialty centers
• Hyperbaric oxygen therapy centers
• Guidelines:
• Local EMS protocols
• Closeness and availability of specialized services

Treatment and Transport Procedures

• Treatment and transport are distinct steps:
• Treatment depends on the injury/illness and available medical care
• BLS is appropriate for minor injuries/illnesses
• ALS is appropriate for non-life-threatening or life-threatening injuries or illnesses
• Jurisdictional resources determine decisions on treatment
• Transportation
• Ground BLS ambulance can be used for minor injuries/illnesses
• Ground ALS Ambulance for life-threatening injuries/illnesses.
• Air medical transport for life-threatening injuries/illnesses and when advanced life support care is needed and transport time is a critical factor.

Accident and Injury Reporting Procedures

• The HSO investigates incidents resulting in hazardous conditions, injuries, illnesses, exposures, and fatalities.
• Also investigates property damage and near-miss occurrences.
• Reviews procedures and develops corrective procedures.
• Aspects of investigation SOP/Gs should include:
• Immediate responsibility:
• This includes transportation and medical treatment for injured personnel.
• Agency cooperation:
• Work with law enforcement agencies to en- sure complete and accurate reporting.
• This information will be included as part of the postincident analysis.
• Deviations or drift from policy:
• Evaluate any deviation or drift in policy.
• Incident review:
• Include recommendations to the organization’s chief/ manager or AHJ for corrective action.
• Investigating and reporting:
• Develop and review procedures periodi- cally; ensure compliance with federal, state/territorial/provincial, and local requirements.

Reporting Procedures

• The HSO's main purpose is to record the incident for analysis and to look for trends, control measures, or corrective actions.
• Reporting typically involves notifying a supervisor who then follows chain of command.
• An SOP/G must address reporting to the local law enforcement for accident investigations.

OSHA Reporting Requirements

• OSHA 29 CFR 1904 requires reporting of:
• Death
• Days away from work
• Restricted work or transfer to another job
• Medical treatment beyond first aid
• Loss of consciousness
• A significant injury or illness diagnosed by a physician or other licensed health care professional
• SOP/G should provide a flowchart of decision points and notifications.
• HSOs should be versed in local jurisdictional requirements.

Investigation Procedures

• Key areas in investigation process:
• Responsibility
• Documentation
• Final written report
• Investigations are objective, fact-finding (not fault-finding), intended to prevent future accidents, injuries, and losses.
• Reasons to investigate workplace accidents:
• Root cause
• Previously unrecognized hazards
• Apparatus/equipment obsolescence, defects, design flaws
• Training needs
• Improvements in safety policies and procedures
• Facts with legal impact
• Historical trends
• Interviews and documentation are crucial.

Facility Inspection Procedures

• Inspection procedures will vary depending on the type of fire department facility being inspected.
• HSOs ensure procedures are in place for inspections.
• Inspections are documented and centrally filed.

Infection Control Procedures

• HSOs assess the infection control program.
• HSO is responsible for the infection control program complies with:
• NFPA® 1500
• NFPA® 1581
• NFPA® 1582
• 29 CFR 1910.132
• 29 CFR 1910.134
• 29 CFR 1910.1020
• 29 CFR 1910.1030
• Ryan White HIV/AIDS Treatment Extension Act of 2009, Part G – Notification of Possible Exposure to Infectious Diseases
• Infectious diseases exposure: facilities, apparatus, events, equipment cleaning.
• Establishment of SOP/Gs provide a guide to ensure awareness and steps for protection.
• Highlighted topics from NFPA® 1581:
• Training and education
• Fire department facilities
• Fire department apparatus, equipment, and clothing and not permitted to be taken home

Facilities Cont.

• Fire department facilities inspections:
• Fire administration, office buildings, and classrooms: building safety and fire codes.
• Fire stations: building safety and fire codes, NFPA® standards, and OSHA regulations.
• Fleet maintenance facilities: building safety and fire codes, EPA and OSHA regulations.
• Training facilities: building safety codes, structural engineer inspection, EPA regulations, and NFPA® standards.
• Storage facilities: building safety and fire codes.
• Special inspections occur after natural events or at the request of risk manager or OSHA inspector.
• Procedures must address before, during, and after a potential exposure.
• The before or prevention phase procedures include awareness of the potential for exposure, the allocation of protective clothing and equipment, vaccinations and immunizations, and training. -The during any potential situation where an infectious agent exposure exists, members must have the knowledge to recognize the potential, the protective clothing and equipment to protect themselves, and the training to properly deal with the situation.
• The after or post-exposure phase includes documentation of the exposure, any needed follow-up evaluations and procedures, counseling, and required notifications.

Risk Management Plan:

• Fire/emergency services must develop and use a risk management plan to guide operations.
• The risk management plan serves as documentation that risks have been identified and evaluated, and that a reasonable control plan has been implemented and followed.
• The department chief is responsible for the development of a risk management plan, but may delegate to the HSO.

Overall Plan Structure:

• Community Risk Assessment: Provides information on known community risks.
• Organizational Risk Management: Evaluates organizational risks and provides control measures.
• Operational Risk Management: Focuses on incident response risks and control measures.

NFPA® 1500 Requirements:

• The fire department shall adopt an official written risk management plan.
• Plan covers administration, facilities, training, vehicle operations, protective clothing/equipment, incidents, and other activities.

Hazard vs. Risk:

• Hazard: Unsafe act/condition that is the source of a risk.
• Risk: Potential of loss, injury, harm, failure, or exposure to a hazard.

Components of the Organizational Risk Management Plan:

• Risk Identification: Risks in the community, organization, and operational settings.
• Risk Evaluation: Assessment of probability and consequences.
• Establishment of Priorities: Ranking based on severity and frequency.
• Risk Control Techniques: Identifying control measures.
• Risk Management Monitoring: Ongoing monitoring for revisions.

Development Strategies:

• Correlate plan to the organization’s mission.
• Review reports (injury, vehicle, near-miss).
• Identify, implement, and monitor control measures.
• Cooperate with other agencies.
• Be proactive.
• Involve organizational membership.
• Use additional resources (NFPA®, FEMA, NFFF, USFA, NIOSH, NFA, CPSE/CFAI).

Risk Identification Sources:

• Department loss prevention data.
• National averages and trends.
• Input from department personnel.
• Trade journals.
• Workers’ compensation insurer.
• NFPA® annual injury report.
• State Fire Marshal.
• Professional associations.
• Other service providers, such as law enforcement to identify the potential risks.

Emergency Risks:

• Risks associated with getting to an incident, stabilizing the situation, and returning to service.
• Responders need some forethought before being placed them in hazardous conditions.
• Ongoing communication between responders and staff officers.
• The HSO must thoroughly understand risks associated with response, clothing and equipment, operational setting, and expanded services.
• Evaluated by:
• Policy and procedures, especially seat belt use
• Crew supervision
• Driver/operator training
• The use of spotters
• Geographical layout of the jurisdiction
• Other drivers and distracted drivers
• Weather
• Speed zones
• Road hazards
• Preemptive signaling device options

Protective Clothing and Equipment:

• Selection
• Inspection
• Care
• Regular cleaning
• Years of service for each type of PPE
• Discarding
• Donating or destroying of PPE

Emergency and Operational All-Hazard Concept :

• Coordinated approach to a wide variety of incidents; all responders use a similar, coordinated approach with a common set of authorities, protections, and resources.
• Hazard Communication Program: OSHA mandated, using signage, placards, labels, and documents.
• Employee Right-to-Know: Employees right to information about hazards in the workplace

Nonemergency Risks:

• Administration, Training, Other Functions, and Postincident Illness or Injury.
• Considered by:
  • HSOs
  • OSHA/EPA compliance
  • Ergonomic needs of members
  • Membership assistance program

Facilities Risks:

• HSOs and the administrative team create and maintain a safe working environment for department personnel whether they are at an incident or in quarters.
• The HSO must deal with identifying risks associated with health and physical hazards.

###Training Risks:

• The HSO is responsible for ensuring that all members receive training in safety procedures related to all departmental operations and tasks.

Environmental Impact

• The HSO must also consider the impact of the environment on the personnel involved in the training.

Vehicle Inspection and Maintenance Risks:

• These policies may also indicate training requirements and documentation of training in the use of these types of protection.

Risk Evaluation:

• Evaluated in these standpoints will involve:
• Frequency
• Severity
• Probability

###NFPA® 1561, Consider: – Territory – Jurisdiction – Entity – Segment of the Public – Compliance with applicable laws, codes, standards, and recommended practices

Establishment of Priorities for Action :

• Assess the risk severity and frequency to establish these priorities.
• Non-serious incidents with a low likelihood of occurrence are lower priorities and can be placed near the bottom of the action-required list.

Setting Goals and Objectives:

• Goals must be attainable, desirable, and quantifiable; they must also fit the organization’s mission statement as well as any legal mandates.

Risk Control Techniques:

• Once risks are prioritized, it is time to apply risk control techniques, by also measuring their effectiveness.

Risk Avoidance:

• Simply put, avoid the activity that creates the risk.
• Risk Reduction (Control Measures): Implement control measures to provide the safest possible working environment.

Hierarchy of Controls:

• Elimination
• Substitution
• Engineering Controls
• Administrative Controls
• Protective Clothing and Equipment