LETTERS TO THE EDITOR (June 2008)

NFPA 1404 and air management

This refers to “Is Your Department Complying with the National Fire Protection Association (NFPA) 1404 Air Management Policy?” (Steve Bernocco, Mike Gagliano, Casey Phillips, and Phil Jose, February 2008). I was amazed to learn that you must leave the immediately dangerous to life and heath area BEFORE your low-air alarm sounds and that once it does sound, you should treat it as serious as a Mayday. I am an instructor and a lieutenant. My chief and I were concerned, so I checked into it.

I could not find that this is “law” in the NFPA standards. I did find the information in the appendix, where it says you should do these things. I called the NFPA and asked the technical people if these actions are now mandated. I was told it is not true. The information referenced in the article is found in the NFPA 1404, Standard for Fire Service Respiratory Training, appendix, which is where you can get information on different suggestions, not policy. Therefore, as long as your department has a written procedure on air management (or what to do when low on air), you are in compliance with the code.

Jaimie Miller
Lieutenant
Rollinsford (NH) Fire Department

The article on air management in the February issue purports to convey “mandatory” language from the 2006 edition of NFPA 1404 concerning individual air management. Most of the article conveys what the authors believe is a sound approach to firefighter air management as well as advocates a need for a cultural evolution in terms of the fire service’s approach to SCBA use. However, because of the authors’ seemingly misinterpretation of the text of NFPA 1404, the context in which they present their beliefs concerning air management “mandates” is skewed.

In summarizing NFPA 1404, the authors say, “The new language states that the individual air management program shall include the following directives:

1. “Exit the immediately dangerous to life and health (IDLH) atmosphere before consumption of the reserve air supply begins.

2. The low-air alarm is notification that the individual is consuming the reserve air supply.

3. Activation of the reserve air alarm is an immediate action item for the individual and the team.”

The article then states that NFPA 1404 “mandates that firefighters be out of the fire (IDLH area) before their low-air warning alarm activates.” There are then further assertions that NFPA 1404 mandates that all firefighters be out of the building before their low-air warning alarm activates.

Although the title of the article suggests that NFPA 1404 contains a mandate for an organizational, operational air management policy, there is nothing in the stated scope, purpose, or relevant provisions of NFPA 1404 to support this conclusion. In fact, the scope and purpose of NFPA 1404 specifically target respiratory protection training to meet the requirements of NFPA 1500, Standard on Fire Department Occupational Safety and Health Program. NFPA 1500 does mandate that fire departments adopt and maintain a respiratory protection program; however, it does not contain any provisions mandating that firefighters exit IDLH areas prior to the low-air alarm warning. Since NFPA 1404’s scope is limited to training, it does not convey operational air management policy mandates.

NFPA 1404 does indeed specify that authorities having jurisdiction establish and enforce written SOPs for training in the use of SCBAs, including an individual air management program. The asterisk associated with the air management program provision [5.1.4(2)*] indicates that there is attendant text in Annex A of the document.

The following text prefaces the provisions in Annex A: Annex A is not a part of the requirements of this NFPA document but is included for informational purposes only. This annex contains explanatory material, numbered to correspond with the applicable text paragraphs.

Generally considered to be useful to standards users in understanding, interpreting, and applying the mandatory language of the document, Annex A material is not intended to convey “mandatory” requirements. The authors assert, “The new language [in NFPA 1404] states that the individual air management program shall include the following directives ….” If they had accurately quoted the document, the authors would not have substituted the “should” with a “shall.”

It is important that Fire Engineering readers are accurately informed regarding the contents of the NFPA’s fire service-related standards. At times, many question the efficacy of the changes to those standards. Very often though, those questions are fueled by the exchange of incomplete or distorted information regarding these standards. In this circumstance, please inform your readers that NFPA 1404 recommends (does not “mandate”) that, from a training perspective, an air management program should include the directive: “Exit from an IDLH atmosphere should be before consumption of reserve air supply begins.”

Below are related excerpts of NFPA 1404. These views represent my personal opinion and do not in any way claim to represent the views of the Fire Department of New York, the NFPA, the Technical Committee responsible for NFPA 1404, or the NFPA Standards Council.

1.1* Scope.

This standard shall contain minimum requirements for the training component of the Respiratory Protection Program found in NFPA 1500, Standard on Fire Department Occupational Safety and Health Program.

1.2* Purpose.

The purpose of this standard shall be to specify the minimum requirements for respiratory protection training for the emergency response organization, including safety procedures for those involved in fire suppression, rescue, and related activities in a toxic, contaminated, or oxygen-deficient atmosphere or environment.

5.1.4 The AHJ shall establish and enforce written standard operating procedures

for training in the use of respiratory protection equipment that shall include the

following:

1. * When respiratory protection equipment is to be used.
2. * Individual air management program.
3. Emergency evacuation procedures.
4. Procedures for ensuring proper face piece fit.
5. Cleaning of respiratory protection equipment components
6. * A policy for changing respiratory filters and cartridges.
7. A policy defining end of service life for all types of filter or cartridge-type respirators.
8. A policy defining the proper storage and inventory control of all respiratory protection equipment.

A.5.1.4 (2) This program will develop the ability of an individual to manage his or her air consumption as part of a team during a work period. This can require team members to rotate positions of heavy work to light work so air consumption is equalized among team members. The individual air management program should include the following directives:

1. Exit from an IDLH atmosphere should be before consumption of reserve air supply begins.
2. Low-air alarm is notification that the individual is consuming the reserve air supply.
3. Activation of the reserve air alarm is an immediate action item for the individual and the team.

Joseph M. Jardin, P.E.
Captain, Special Operations Command
Fire Department of New York

Steve Bernocco, Mike Gagliano, Casey Phillips, and Phil Jose respond: We appreciate Lieutenant Miller and Captain Jardin’s interest in air management and firefighter safety and for caring enough about their firefighters and students to conduct such thorough research before accepting as fact anything they read. From their correspondence about our article, we would like to address the following concerns:

1. The training components of NFPA 1404 do not relate to an NFPA 1500 requirement for an operational component of air management.
2. The NFPA standard is not “law.”
3. The standard does not require firefighters to exit the IDLH before the low-air alarm, also known as the End of Service Time Indicator (EOSTI).
4. Having a procedure for “what to do when low on air” meets the standard’s requirement of an “individual air management program.”
5. The low-air alarm is treated in a manner similar to that for a Mayday.

We understand the point about the operational requirements of NFPA 1500 vs. the training requirements of NFPA 1404. We believe we can make a compelling case that NFPA 1500 does support the requirements of the 1404 standard. In this case, and in the interest of brevity, we are willing to concede the point for purposes of discussing the issue.

Even if the writers believe that NFPA 1500 may not require an air management approach to the fireground, it certainly does not prevent any fire department from instituting one. In fact, most fire service and safety documents support the premise that when there is conflict between standards, or portions thereof, the more restrictive language should be used. In this case, the more restrictive language is in the 1404 standard, in that it requires an air management program (AMP). The recommended components of the AMP are described in the 1404 standard, but it is certainly the case that fire departments are not required to comply with the recommended components. Fire departments would have to support their AMP in relation to the standard and describe how their program is at least as effective as the AMP recommended in the 1404 standard. Rather than defend something outside the standard, we believe the best course is to adopt the recommendations in the standard.

On this point we want to be clear: We did not misinterpret NFPA 1404 to require an operational component. We simply see no difference in the reasonable and practical application of training procedures vs. operational procedures. We make no differentiation in our article, because we make no differentiation in our thinking. When we look at a training standard, we automatically compare it with our operational philosophy. We have always believed that firefighters operate according to their training. It makes no sense to us to argue that we should train one way and operate in another.

We believe training standards and operational policies should reflect each other and that firefighters should “train as if their life depends on it.” That is why we worked closely with members of the NFPA 1404 committee while the standard was developed, debated, and decided. Committee members passed the standard unanimously, and their comments on the direction of the air management section of the standard are outlined below. We look forward to making our case for the AMP during the next revision cycle for NFPA 1500 so that it more accurately reflects the requirements of other NFPA standards, including 1404.

There is no question in our minds that suggesting to firefighters that they behave one way in training while clearly expecting something different in operations is a recipe for disaster. When we regard the 1404 standard as a whole, it is impossible for us to advocate teaching firefighters to use their SCBA other than how we expect them to use the SCBA in operations. For example, we teach them to respond to an SCBA emergency in training in the same way as they are expected to perform should they experience an SCBA emergency on the fireground. This approach to training is captured in the appendix of NFPA 1404 by the following:

NFPA 1404 A.5.1.7: One role of any training program is to generate acceptance of operational evolutions for coordination and skill. The use of proper procedures and the dispelling of false notions concerning the use and application of respiratory protection equipment are equally important. The state of the art in today’s firefighting environment demands a commitment by each AHJ to ensure maximum acceptance in the use of respiratory protection equipment.

In our article, we hoped to “generate acceptance of operational evolutions for coordination and skill” as they apply to air management. We also hoped to assist the fire service in “dispelling of false notions concerning the use and application of respiratory protection training.” We believe that SCBA training should represent the “state of the art in today’s firefighting environment” and that that “state of the art” is the air management program. We recognize that this language is taken from the appendix of 1404 and not the primary text, and we will address the “should” vs. “shall” of the discussion later. For the purpose of this section, we will close by stating that we do not and will not advocate anything less than training firefighters to use their SCBAs as we expect them to use them in operations. Further, we recommend that any operational philosophy that results in a direct conflict between the training standard and the operational standard within an organization be dealt with immediately.

Whether the standards qualify as the law within a state is dependent on whether the local government agencies have adopted the standard for jurisdictions under their control. This is a state-to-state issue. While the standards may or may not represent “law,” they are considered the industry “best practices” and are written and presented as such. Courts have held that the NFPA standards do represent the fire service’s best practices and have consistently supported them. In this case, we are talking about a standard that applies to the self-contained breathing apparatus, arguably one of the most important pieces of safety equipment in the fire service. We believe that when an incident occurs that results in a firefighter’s being out of air within an IDLH environment, it would be reasonable to expect the widow/widower’s attorney to request your training documents, policies, and procedures. The questioning likely would go like this:

1. Did you train your firefighters according to the unanimously adopted recommendations of the NPFA 1404 standard?
2. If not, why not? (Feel free to supply an answer here, as we can’t come up with one.)
3. If you did not adopt the recommendations of the NFPA 1404 committee, what did you implement that met or exceeded those recommendations?
4. If your respiratory training differs from the way you operate, what other areas of your operations are contrary to how you train?

We readily admit that our position is a conservative interpretation of NFPA 1404. Our goal is to save firefighters’ lives, and a strict adherence to the recommendations of the standard is the best way to do that. Our position is consistent with the intent of the 1404 committee. Our article should have used the word “should” instead of “shall” for the appendix material, and that is our normal wording. This is a minor consideration when a fire department is looking at the intent and impact of the standard. We rarely come across an AMP that adequately addresses the “shall” and “should” of the current standard. From a legal perspective, it begs the question why a fire department would knowingly and willfully disregard the unanimous recommendations of the 1404 committee. Moreover, from a practical perspective, it simply works. We believe the question then is not “shall” you train to the standard or “should” you train to the standard, but WILL you, ARE you training to the standard? We think you should.

So, let us look at what the standard says. The standard includes mandatory language as follows:

NFPA 1404, 5.1.4*: The authority having jurisdiction shall establish and enforce written standard operating procedures for training in the use of respiratory protection equipment that shall include the following:

(2)* Individual air management program.

The standard clearly requires that fire departments have an individual air management program. What are the recommended components of that program? Those components are in the appendix, as indicated by the asterisk next to the paragraph citation. In this case, we need to read the appendix to gain insight and guidance provided by the committee responsible for the standard.

The appendix states the following:

A.5.1.4 (2): This program (the air management program) will develop the ability of an individual to manage his or her air consumption as part of a team during a work period. This can require team members to rotate positions of heavy work to light work so air consumption is equalized among team members.

The individual air management program should include the following directives:

(1) Exit from an IDLH atmosphere should be before consumption of reserve air supply begins.

(2) Low air alarm is notification the individual is consuming their [sic] reserve air supply.

(3) Activation of the reserve air alarm is an immediate action item for the individual and the team.

Training a firefighter in “what to do when low on air” addresses only the third directive. Training like this is consistent with what fire departments have always done: Virtually every firefighter has been trained to begin exiting the IDLH area when low on air. We do not believe a policy like this meets the mandates or the intent of the standard. We do not believe this is a safe way to operate. In fact, one of the reasons for the change in the standard was the death of firefighter Bret Tarver of the Phoenix (AZ) Fire Department. In its report on his death (2001-1), the National Institute for Occupational Safety and Health recommends the following: “Ensure that firefighters manage their air supplies as warranted by the size of the structure involved.”

Another document to support our contention is the Report on Comments F2005, NFPA 1404. This document represents the committee’s decision on comments received during the revision of the NFPA 1404 standard. Following is the committee’s response to a request to remove directive #1 of the AMP that requires firefighters to exit BEFORE (emphasis ours) consumption of the reserve air supply begins.

The committee realizes that exiting the immediately dangerous to life and health (IDLH) atmosphere prior to activation of the End of Service Time Indicator (EOSTI) will be a profound culture change to the fire service as we know it today. If the user relies upon emergency air as get-out air, there will continue to be thousands of close calls, injuries, and deaths because of the dangerously reduced safety margin of time when the unexpected does and will occur. Training must be done (sic) to the worst case scenario, not the best, especially when the surrounding environment is so unforgiving. Although new technology could help and has helped as an air management tool, it must be remembered that every piece of technology that is carried into the IDLH has failed at one time or another, including EOSTI and Heads Up Display (HUD).

The committee states that it believes Directive 1 of the standard “will be a profound culture change to the fire service as we know it today.” This indicates to us that members of the NFPA committee were fully aware that this “new idea” that firefighters leave before the EOSTI was the same as the idea presented in our article. We believe that the new standard does require a complete air management program and that such a program should include all three directives. We believe that firefighters should be trained to know how much air they have prior to entry, manage their air as they proceed, and exit the IDLH environment before the low-air alarm activates. To do less would, in our opinion, represent the same thinking that contributed to the death of Bret Tarver and significant injuries to multiple members of our own fire department.

Finally, to the concern about treating the activation of a low-air alarm the same as a Mayday, this statement is a result of our teaching thousands of firefighters around the country on the topic of air management. When we teach, we ask the question, “What things on the fireground constitute an ‘immediate action item’ for the fire departments represented in the class?” Here is a list of those things we hear most from students: collapse, Mayday, rapid fire progress, lost firefighter, and trapped firefighter.

Within our department, the low-air alarm requires the firefighter or team to transmit an immediate radio report identifying who the member/team is, where, status, and point of egress. Firefighters in the fire building and the command staff outside treat any low-air alarm that is not followed by an immediate radio transmission as a firefighter emergency or “immediate action item.” This way, we do not mistake an activated low-air alarm as just another false alarm on our fireground but rather as an indication that something is not right and needs to be handled immediately.

It is interesting to note that our article dealt with two subjects: air management and resistance to change. The only points of discussion result from our contention that air management is “required” rather than “recommended.” We are having a discussion about “should” vs. “shall” while ignoring the role that “resistance” is playing in the discussion. At least, we are making progress in our quest to increase firefighter safety through the implementation of air management. Three years ago, the topic of letters was a discussion about whether firefighters “could” be trained to manage their air. We have progressed to the point of discussion of whether they “should” or “shall” be trained. Perhaps if we continue to counteract resistance to the idea of air management, we will eventually get to the discussion about “how” to train firefighters to manage their air.

We are thankful for this opportunity to address an issue about which we are passionate and one that is often misunderstood in its application. Air management training provided to the letter and intent of the standard requires firefighters to exit the IDLH before the EOSTI. This is a profound cultural change to the fire service as we know it today. We believe that this change is a vital component to firefighter health and safety. Teaching firefighters to use their emergency air reserve as part of their normal operating air is ineffective in protecting them from breathing smoke. This is old thinking. The smoke in the modern fire environment can kill on the first breath. When the penalty for failure is death, why not take a proactive approach and provide training that ensures an adequate margin for error within the hostile fire environment? We believe you should.

Correction

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Editor’s Note: In “Cold Towels Valuable Rehab Tools” in the April 2008 issue, substitute the following graphic for the graphic on page 196.

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