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DC Fire and Emergency Services Department
Internal Report on Hazardous Materials Training
August 2001

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On June 4, 2001, A Captain Edward Pearson informed me that I would be assuming the duties of the Special Operations Lieutenant at the Fire Training Academy. This is a position in which I feel I have the credentials and where I could make a difference toward mitigating risk to the community, risk to the Department, and risk during emergency operations.

Special operations was created in August 1997 to coordinate the following:

  • Hazardous Materials Operations 
  • Rescue Operations (including confined space, high angle rope rescue, water rescue, collapse rescue and vehicle rescue) 
  • Metro Operations 
  • Rail Operations 
  • Fireboat Operations 
  • Counter Terrorism Planning and Operations 
  • Foam Unit

Recently, infection control, wellness and occupational health officer and special events planning officer have been merged into special operations. As the tri-Data report stated, "the organization of the special operations into a single section is a very positive step towards the efficient delivery of these services." However, with the abolishment of the Battalion Chief and Lieutenant, Special Operations positions. the operational effectiveness and safety of the Department with regard to these incidents has been greatly diminished. Special operations arc inherently the rarest of incidents. yet pose the greatest danger to emergency responders and require the highest level of technical skill and competence to perform safely and effectively.

The probability of risk is two-pronged. It relates not only to the chance that something undesirable might happen, but also to the probable outcome as rated on a scale of negative consequences. The evaluation of risk potential involves determining or estimating the likelihood that an event will occur and the consequences that will result if it does. Probability is generally established by studying the frequency at which incidents have occurred in the past. The magnitude of a loss might be predictable from past experiences both national (such as the World Trade Center or Oklahoma City) and local (Air Florida and Metro simultaneously and B'nai Brith anthrax incident). It is important to remember that incidents with the most severe consequences are usually the most rare. Therefore, when prioritizing risk management actions it is important to remember that special operations are low frequency but high severity, with high potential losses to the organization.

After considering the probabilities of occurrence and probable outcomes. the next step is to prioritize the risks and decide on the areas that need to be addressed as priorities. Generally. risks with the most severe potential outcomes are considered ahead of risks with relatively minor outcomes, Unfortunately, with the fiscal crisis and the misperceived risk based on low frequency of occurrence, special operations has been reduced to an "bare-bones" function and increased risk within three major categories:

  • Risk to the community -- community risk 
  • Risk to the fire department organization -- organizational risk 
  • Risk during emergency operations -- operational risk

There are two key areas of potential exposure and associated organizational risk management techniques that should be immediately addressed:

PERSONNEL

  • There is a failure to meet minimum performance requirements with regard to Hazardous Materials Operations (Level II) and Technician (Level Ill). The current level of training is woefully inadequate with regard to the severity of risk posed to this jurisdiction. Minimum performance standards along with the mandated re-certification are not being adhered to. 
  • There is a failure to train all Fire and EMS to Haz-Mat Level II. EMS personnel are as susceptible to exposure as firefighting personnel. 
  • Ideally, all operational personnel should be trained to Level III standard, while reserving Level IV training to the Special Operations Units. 
  • Battalion Chief and all command personnel receiving Level V training. 
  • Members of the three rescue squads have not been re-certified in either confined space (NEPA 1006:7.1), trench (NFPA 1006:9.1) or rope (NFPA 1006:) in over two years. Individual company commanders have taken great initiative in field drills but there are a significant number of personnel who have never received formalized rescue training from within the Department. This would be resolved with the establishment of a performance based Rescue Technician Program compliant with NFPA 1006 and 1670 and made available to all interested members of the Department. This would address the variable efficiency with regard to rotation of personnel detailed to a rescue squad, in that the training would be standardized and comprehensive. 
  • The rescue companies do not get the opportunity to cross-train with each other, sharing their designated specialties. In other jurisdictions, rescue companies are fully interchangeable, and multi- tasked. A confined space incident can have a high-angle component as well as the potential for structural collapse. Each rescue squad is supposed to back each other up during technical emergency operations. 
  • The D.C. Fire and EMS Structural Collapse and Confined Space Simulator have the potential to be a world-class prop, which could be used for revenue generating classes. It should be re-engineered and used on a regular basis. OSHA Standard 1910.146 mandates annual recertification on confined space. There is a mistaken belief within the Department that Federal OSHA Standards do not apply and are not enforceable for the District of Columbia. Any operational failure, which would result in injury or fatality, could be potentially met with civil action for violation of the Standard for which the Department would be accountable. 
  • The rescue squads currently respond to water rescue incidents but the training has been limited and non-recurring. Drills using the fireboat personnel to assist in training should be conducted. National Airport has disbanded its dive rescue team. MPD uses its team primarily for body recovery. The options for rescue with a capsized boat or downed aircraft in the Potomac River are greatly reduced. The establishment of a dive rescue team should be strongly considered within the near future.
  • Communication between rescue squad captains is important and should occur on at least a quarterly basis. There should be formal meetings with the rescue squad captains between the Risk-Management Office (Special Ops) and the Office of the Firefighting Deputy. Deficiency within both the FED and SO would be addressed and hopefully remedied. 
  • First responding units have diminished detection and immediate treatment capabilities for Haz-Mat and NBC terrorist attack. The community, organizational, and operational risk is greatly increased without the addition of MACH IV Kits, binoculars, gas and radiological dosimeters and current DOT and Haz-Mat references. 
  • Rescue Squads should be equipped with laptop computers to include the Haz-Mat software and geographic and pre-planning references.

ADMINISTRATIVE

  • There are specific requirements for rescue operations mandated by NEPA 1670 and OSHA. It is essential to be familiar with these provisions not only from an operational perspective but also of risk from Organizational liability. The approved handling jurisdiction shall establish levels of operational capability needed to conduct operations at tech rescue incidents safety and effectively based on hazard analysis, risk assessment. training level of personnel and availability of internal and external resources. NEPA 2-1.2 requires general awareness training and SOP's for all first line engine and truck companies. The Department needs to define the level of service consistent for the awareness, operations, and technician requirements. 
  • The rescue squads should conduct a hazard analysis and risk assessment of the response area and should determine the feasibility of conducting technical rescue. Potential hazards and their likelihood of causing an incident shall be identified. These "rescue" inspections are mandated in NFPA 2-2 and should be concurrent with the provisions of Order Book Article XVIII. 

The current budget deficit has obviously curtailed many operational needs and training consensus standards. However, there are "stop-gap" measures that could be implemented before FY '02 funding becomes available.

The recently formed National Medical Strike Team is being developed and will soon be ready for operation within the Washington Metropolitan Region D.C. Fire and FMS was invited to participate by the COG. However, the Department has failed to make provisions for its qualified members. This would be an opportunity for members to bring back medical management of multi-casualty training and experience in working with other agencies and jurisdictions. The Region is in contention for the 2011 Olympics and a lack of serious commitment toward technical rescue capabilities and ALS response to hazardous materials incidents will undoubtedly hurt our chances for this major economic opportunity for the District of Columbia.

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