BY STEVEN A. SAVIA, CMC
With all of the controversy surrounding National Fire Protection Association (NFPA) 1710, Standard for the Organization and Deployment of Fire Suppression, Emergency Medical Operations, and Special Operations to the Public by Career Departments, most municipalities have forgotten, and many stand-alone volunteer departments have not heard about, its comparable volunteer standard, NFPA 1720, Standard for the Organization and Deployment of Fire Suppression, Emergency Medical Operations, and Special Operations to the Public by Volunteer Departments. This standard has received little of the publicity that has accompanied the standard addressing paid fire departments. But, you should view its provisions and implications with similar discernment.
NFPA 1720 will become a guiding force in the future of the volunteer fire and rescue service. What does that future look like under this proposed standard? Following are some of the provisions of NFPA 1720 and the implications of those provisions.
WHAT IS NOT COVERED?
Let’s start with the easy part: what’s not included under the standard. Section 1.1.4 points out that the “standard does not address fire prevention, community education, fire investigations, support services, personnel management, and budgeting.” This is a standard that is about the organization and operations of a substantially volunteer fire department (we’ll deal with that definition later) that provides fire suppression, emergency medical services, and special operations activities such as haz-mat response.
WHAT’S THE BIG DEAL?
First, some background. NFPA standards are not law (unless adopted by a jurisdiction), nor do they hold the authority of government regulatory standards. The NFPA is a nongovernmental organization.
So what’s the big deal if this standard and other standards are not laws or regulations that can be enforced? NFPA standards tend to be viewed as accepted industry standards. That means that if there is litigation, these standards will be held as the baseline against which to measure. So an expert witness testifying in a lawsuit against a volunteer department for negligence resulting in the loss of life or property would probably cite NFPA 1720 as the standard for organization and operations for a volunteer department. Although other experts can argue that it is a written standard not necessarily reflecting standard practices, a lot more work has to be done to make that argument.
The other important component has to do with the language used in the standard. One important word is “requirement.” Several commentators recommended to the Technical Committee that formulated this standard that the word “requirement” be replaced with “recommendation.” The Committee’s response makes clear its and the NFPA’s position on the matter: “The Technical Committee is developing a standard, and by changing to recommendations it is non-mandatory text that is not used in a standard.” The key phrase is “non-mandatory.” The NFPA sees this as a mandatory standard that is to be implemented, and based on the comments of those recommending the change, the NFPA doesn’t care if that means problems for a volunteer department. In particular, wherever the word “shall” is used, the NFPA says it is “a mandatory requirement.” (Section 3.2.3) There is no doubt in the NFPA’s mind that this standard is not a guideline for volunteer departments or a recommendation for how to improve them.
THE CAVEAT
Before getting into the details, there is an interesting section that could neutralize the standard. Section 1.2.3 states “[t]he authority having jurisdiction determines if this standard is applicable to their fire department.” So who is this “authority having jurisdiction”? The official NFPA definition is cited in Section 3.2.2: “The organization, office, or individual responsible for approving equipment, materials, an installation, or a procedure.”
As further illustration, the Appendix, which contains explanatory material, says that this term is “used in … a broad manner.” It could refer to a fire chief or to the person or persons to whom that fire chief reports. This could be a mayor if the volunteer department is part of a municipality or a board of directors if it is a nonprofit corporation. The language seems to refer to someone with legal standing to make an organizational decision. My own recommendation would be that if a fire chief undertakes to make the decision that the department is not subject to this standard, he should probably have concurrence from whoever hires or appoints him.
WHY 1720?
According to the stated purpose within 1720 (Section 1.2), the reason for 1720 is to “specify the minimum criteria addressing the effectiveness and efficiency of the volunteer public fire suppression operations, emergency medical service, and special operations delivery in protecting the citizens of the jurisdiction.” Apparently, there are those who believe the volunteer fire/rescue system could use improvement. As kids say today, “Duh.” But this standard asserts that it is “THE” way for that improvement to be made.
These minimum criteria are aimed at effectiveness and efficiency. Effectiveness, as I tell my students, refers to the manner in which things are done: meeting an objective fully and correctly the first time. This implies that it may require more resources and take more time than expected, but the objective is fully satisfied and does not require revisiting. Efficiency is really an economic term referring to accomplishing an objective at the lowest cost. Cost is a function of resources, direct financial cost, and time. Effectiveness and cost are not always compatible.
We need to look at the definition of “substantially volunteer.” NFPA 1720 is the volunteer version of NFPA 1710, which addresses substantially paid departments. Unfortunately, neither standard defines the word substantially. When in doubt, look it up. The Merriam-Webster Dictionary cites substantially as the adverbial form of substantial. Substantial is defined as “existing as or in substance: material … important, essential … considerable … strong, firm.” For something to be material in an accounting sense, it has to have influencethe ability to alter a financial condition. I would contend that each of the words in the definition implies that for a department to be substantially volunteer, the volunteers must control the organization and operations of the department and must be a majority of the personnel in the department. I would even go so far as to say that volunteers must be the majority of personnel responding to incidents if the department is to qualify under this standard. After all, the standard is intended to address how volunteers operate on the scene.
One final note about definitions: Chapter 3 of the standard contains the definitions of terms used throughout the standard itself. Become familiar with them, especially those that relate to incident operations.
WHAT 1720 SAYS
What does this standard actually require?
Organization. First, the standard requires that operations be organized. The standard goes on to describe how that organization is to look, but it is important to stop right here. Many volunteer departments still operate pretty much on the flynot scheduling personnel, uncertain about who will respond to what calls and which equipment will go out with which firefighters, based solely on the order in which they arrive, and so on. Many volunteer departments still have members who go to the scene in their personal vehicles and meet (hopefully) the equipment there.
Part of this “organization” referred to in the standard is to require that the “department’s organizational, operational, and deployment procedures” be in writing and issued to the members. The standard says these procedures must be in the form of “written administrative regulations, standard operating procedures, and departmental orders.” (Section 4.1.1) Written communication is a crucial component of any career department: It’s the basis from which discipline can be administered. The volunteer fire service has typically relied on experienced firefighters to do what needs doing.
Section 4.1.2 says the department is to be involved in developing a community risk management plan. Such a plan requires significant coordination with law enforcement; emergency management; EMS; haz mat; and others only occasionally involved in emergency services such as local, state, and federal environmental, transportation, education, utility, and industrial agencies. Although many communities in this country have no such plan or a cursory one at best, this requirement actually places no burden on the fire department beyond what is already in place under the Occupational Safety and Health Administration’s Hazardous Waste Operations and Emergency Response regulation: to participate in the preparation of a plan.
Company organization. NFPA 1720 requires that “personnel responding to fires and other emergencies shall be organized into company units or response teams and shall have appropriate apparatus and equipment.” (Section 4.1.4) This is one of the places where NFPA 1720 mirrors NFPA 1710: “On-duty personnel assigned to fire suppression shall be organized into company units and shall have appropriate apparatus and equipment assigned to such companies.” (Section 5.2.1.2) It is interesting that a nonvolunteer standard should influence volunteer organization and operations. Volunteers respond from home and frequently are not assigned to or scheduled for specific apparatus or even for duty. Being organized into companies in much the same way as paid departments is a major paradigm shift and will require volunteer departments to institute some substantive changes.
The standard requires volunteer fire departments to identify minimum staffing levels. “Wait a minute,” you say, “I thought we were talking about a volunteer standard, not a paid one!” We are.
Section 4.1.5 says minimum staffing is required “to ensure that a sufficient number of members are available to operate safely and effectively.” This is one of those dicey points. Traditionally, volunteer departments have operated with whatever resources were available. If fewer people than desired are available, departments typically modify their tactics to reflect what resources are available. Sometimes that means calling for additional mutual aid. Sometimes that means an external instead of an internal attack. This section of the standard indicates that the department must define all of these issues in advance.
Let’s look at the implications, again, from the perspective of potential litigation because that’s really the only true enforcement mechanism. Let’s say the department identifies its minimum staffing. Let’s also assume there is an injury at a fire scene. Because the department is also required to have a report indicating response information, including personnel (Section 4.1.6), let’s assume that fewer than the specified minimum number of personnel were on the scene. An expert witness in the trial will point out that the department was in violation of its own established minimum staffing and thus was negligent.
Finally, response to an “incident shall be based on risk analysis and prefire planning based on specific location or incident.” (Section 4.1.7; also see 4.1.8) This section implies that the department must establish a risk analysis and preplan for every major structure, residential neighborhood, and even woodlands and wildlands. The process for implementing response under these plans is assumed to be through a “[m]odern computerized dispatch system” with the ability to make “specific dispatch assignments” to the individual building or street level (Appendix A.4.1.7 and A.4.1.8). That’s a tall order for many volunteer departments.
FIRE SUPPRESSION OPERATIONS
There are no real issues in this area of the standard. Incident command and personnel accountability are consistent with OSHA regulations describing both. The only twist is Section 4.2.1.6: “Orders addressed to individual members, particularly verbal orders and orders at incident scenes, shall be transmitted through the company officer.” Volunteer departments tend to operate on a more informal basis, especially at the fire scene. Delegation of authority, issuing orders through company officers to non-officers, and operating within a formal command structure are standard in the paid service but are the exception for volunteers. It’s not unusual that experienced personnel are not officers for a variety of reasons; thus, it’s also not unusual for officers to look to more experienced personnel for direction. In this situation, the volunteer service is very different from the paid service.
INITIAL ATTACK
A controversial component of NFPA 1710 is the response time requirement. In the case of 1720, there is no response time requirement per se. Section 4.2.2.1 states: “Upon assembling the necessary resources, the fire department shall have the capability to safely initiate an initial attack within 2 minutes 90 percent of the time.” Given the qualifiers in this section, I doubt any department will have a problem meeting this requirement. Notice that this doesn’t refer to an interior attack, only a safe initial attack.
The remainder of the initial attack section addresses rapid intervention, two-in/two-out, and using the buddy system in hazardous environments and includes a broad description of fundamental incident operations. None of the requirements indicate any significant change in typical volunteer incident operations.
Section 4.2.2.3 refers to an issue that frequently comes up when I teach strategies and tactics: rescue operations in imminent life-threatening situations. The requirement states that action is permitted where that action could prevent the loss of life or serious injury. I appreciate the added qualification “could prevent.” I have long taught that only when there is a reasonable probability of success should such actions be undertaken. There is no reason to undertake a life-threatening action when there is low or no probability of success.
INTERCOMMUNITY ORGANIZATION
This section of the standard deals with mutual, automatic-aid, and other protection contracts and agreements. The intent is clearly to create “uniform operations.” (Section 4.3.2) In the volunteer service, neighboring departments often operate differently but have been able to put those differences aside when working together. I concur with this section’s objectives of making sure that agreements are in writing and include expectations and responsibilities.
EMS, QUALITY MANAGEMENT, AND SPECIAL OPERATIONS RESPONSE
I’m not going to spend much time on these sections, since they don’t apply to all departments. If your department provides EMS at whatever level, the EMS and Quality Management sections apply to you. The key components are Section 4.4.1.2 (documenting the department’s role) and Section 4.5.1 (instituting a quality management program).
Special operations are defined in the Appendix. They “include but are not limited to (1) Rope rescue including high angle, (2) Water rescue, (3) Trench/collapse rescue, (4) Confined space rescue, (5) Extrication rescue, (6) Air/sea rescue, (7) Urban search and rescue (USAR), and (8) SWAT (special weapons and tactics team operations).”
The standard primarily addresses a department’s capabilities to respond to these incidents, its organization, and its training. It doesn’t indicate that a department must perform these functions. However, if it does perform these functions, the department must do the following: be properly organized, have specific procedures in place, appropriately plan for such incidents, have members properly trained, and identify and call for additional resources as needed.
SYSTEMS
The final section of the standard addresses safety and health, incident management, training, communication, and preplanning. Most of these areas are covered by other NFPA standards. For example, Section 5.1 Safety and Health System states: “[a] firefighter occupational safety and health program shall be provided in accordance with NFPA 1500 … regardless of the scale of the department or the emergency.” In this case, a department not currently requiring its members to meet the physical requirements of NFPA 1500, Fire Department Occupational Safety and Health Program1997, would be in violation. Of course, that department is already in violation of NFPA 1500.
Incident management is to be in accordance with NFPA 1561, Standard for Emergency Services Incident Management System2000, and communications in compliance with NFPA 1221, Standard for Communications, Emergency Services1998. Preplanning is to be instituted and be consistent with NFPA 1620, Standard for Pre-Incident Planning1998.
Finally, “[t]he fire department shall have a training program and policy that ensure that personnel are trained and competency is maintained to effectively, efficiently, and safely execute all responsibilities consistent with the department’s organization and deployment as addressed in Chapter 4.” This is another change for most volunteer departments. This section requires departments to have a planned, comprehensive training program that provides training in all of the functional aspects of fire suppression, EMS (as appropriate), and special operations. By stating that this is to be a program, it is implied that training isn’t conducted on an ad hoc basis. It will need to be planned in advance and over time no deciding the day of training what will be done that evening. The objectives and functional skills addressed by the training will need to be identified and documented.
In spite of what supporters may be saying, this standard is a very significant change for most volunteer fire departments. Changes include moving away from informal organization and communication to required additional planning, documentation, and scheduling of members. It appears that there is a desire to make the volunteer service emulate the paid service.
Not everyone favors this standard. Out of 51 pages issued by the NFPA relating to the standard, more than 44 pages are comments, recommendations for change, or calls for outright elimination of the standard from the volunteer community. It appears that the Technical Committee rejected 90 percent or more of them. More than 150 contributors recommended eliminating the entire standard, suggesting that the NFPA was overstepping its bounds trying to create a cookie-cutter approach to the volunteer fire service or was depriving local departments of the opportunity to make their own determination regarding organization, procedures, and processes.
If this standard passes the last hurdles to be approved, such as appeals to the NFPA Executive Board and any litigation that might follow, there will be much more discussion about the pros and cons of implementation. There will also be discussion about whether the NFPA will continue to carry its traditional creditability in setting fire safety-related standards.
STEVEN A. SAVIA, CMC, is a founding principal of The Sage Group, a professional management consulting and public policy research firm specializing in serving local government organizations. He started in the fire/rescue service in the Vienna (VA) Volunteer Fire Department (Fairfax County Fire and Rescue Services) more than 30 years ago and is currently a member of the Bay Leaf Volunteer Fire Department in Wake County, North Carolina. Savia has a BA and an MA and has pursued doctoral study in public policy. He is a certified management consultant and past national chairman of the Institute of Management Consultants (USA). He teaches a variety of public administration and fire service subjects.
