Public Comment No. 6-NFPA [ Section No ] Statement of Problem and Substantiation for Public Comment

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Judith Young
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1 Page 1 of 18 Public Comment No. 6-NFPA [ Section No ] This standard contains minimum requirements for organizing, operating, training, and equipping facility fire brigades when / fire departments when responding to fires in industrial, commercial, institutional, and similar properties. Many industrial, busines, and government complexes have thier own fire departments. They do not call them brigades and they are organized, staffed and managed as any State, County or local government department may be. By adding the words fire department we are making it clear that you can and should use this standard when looking at these type of operations and not NFPA 1710 or Submittal Date: Thu Oct 10 09:55:02 EDT 2013 The term Fire Department is not needed as it is already addressed in the definition of facility fire brigade. Mutual aid is not covered by the standard except as indicated in The term staffing is already covered in the organizational statement of fire brigades.

2 Page 2 of 18 Public Comment No. 7-NFPA [ Section No ] This standard contains minimum requirements for organizing, operating, training staffing, training, and equipping facility fire brigades when / fire departments when responding to fires in industrial, commercial, institutional, and similar properties. This would add to the standard a way to determine peoper staffing levels for an industrial fire department or brigade. Submittal Date: Thu Oct 10 10:03:12 EDT 2013 The term Fire Department is not needed as it is already addressed in the definition of facility fire brigade. Mutual aid is not covered by the standard except as indicated in The term staffing is already covered in the organizational statement of fire brigades.

3 Page 3 of 18 Public Comment No. 8-NFPA [ Section No ] This standard contains minimum requirements for organizing, operating, training staffing, training, and equipping facility fire brigades when / fire departments when responding to fires in industrial, commercial, institutional, and mutual aid and similar properties. Covers addiditions as need to meet above changes and also adds responces to other industries and incidents cvered by MOUs or other aggreements. Submittal Date: Thu Oct 10 10:06:40 EDT 2013 The term Fire Department is not needed as it is already addressed in the definition of facility fire brigade. Mutual aid is not covered by the standard except as indicated in The term staffing is already covered in the organizational statement of fire brigades.

4 Page 4 of 18 Public Comment No. 9-NFPA [ Section No. 1.2 ] 1.2 * Purpose. The purpose of this standard is to provide minimum requirements for organization, operation, staffing, training, and occupational safety and health for facility fire brigades / fire departments. Make changes throughout the document if agrees to change / addition. Submittal Date: Thu Oct 10 10:09:34 EDT 2013 The term Fire Department is not needed as it is already addressed in the definition of facility fire brigade. Mutual aid is not covered by the standard except as indicated in The term staffing is already covered in the organizational statement of fire brigades.

5 Page 5 of 18 Public Comment No. 10-NFPA [ Section No ] * This standard shall apply to any organized, group of employees having the primiary fire-fighting response duties, such as emergency brigades, emergency response teams, fire teams, department or and plant emergency organizations. These 'groups' may also preform rescue, haz-mat and medical responses. These changes will assist to better define more of the type of industial departments that are in the industry. I believe this standard needs to cover not only the groups who may do other duties until an alarm goes off but also the full time emergency response personnal that cover large office, business and industrial complexes that we have and do not fall under NFPA Submittal Date: Thu Oct 10 10:11:26 EDT 2013 NFPA 600 does not cover other activities such as confined space, haz mat and rescue however this does not prohibit fire brigades from performing these duties if the appropriate standards are followed.

6 Page 6 of 18 Public Comment No. 11-NFPA [ Section No ] * This standard shall not apply to facility fire brigades that respond to fire emergencies outside the boundaries of the site where the off-site fire involves unfamiliar hazards or enclosed structures with layout and contents that are unknown to the facility fire brigade. If the agrees to some of my above changes then the Brigade / fire department may be allowed to provide mutual ade where MOU are in force. Again this will cover more the the type of departments that are out there and function more like a County or City fire department. Submittal Date: Thu Oct 10 10:21:11 EDT 2013 Mutual aid agreements are not prohibited however those agreements must be for known hazards. See annex note for

7 Page 7 of 18 Public Comment No. 12-NFPA [ Section No ] This standard shall not apply to medical response, confined space rescue response, and hazardous material response activities. If agress to above changes this would need to be removed or reworded. I think that there is a gap between the type of brigade that NFPA 600 talks to and what is out in the world. There are many "fire department" type organizations that fall between NFPA 600 and NFPA 1710 that should be covered. They do more than just fire response. (A new proposal to the Standards Council was reject as they felt NFPA 600 covered these type of organizations.) Submittal Date: Thu Oct 10 10:25:02 EDT 2013 This section clearly describes the scope of the document which does not include medical response, confined space rescue and hazardous materials response activities. The chair is appointing a task group to review the issues raised in the public comment at the next revision cycle.

8 Page 8 of 18 Public Comment No. 13-NFPA [ Section No ] Facility Fire Brigade / Department. An organized group of employees at a facility who are knowledgeable, trained, and skilled in at least basic in fire-fighting operations, and whose full-time occupation might or might not be the provision of fire suppression and related activities for their employer Facility Fire Brigade Leader. An individual responsible for overseeing the performance or activity of other members. Let the AHJ decide how high the level of training should be. or reference NFPA 1001 Submittal Date: Thu Oct 10 10:32:03 EDT 2013 The level of training is defined by the organizational statement. Fire departments are included in the definition of fire brigade. See statement for PC 6-8.

9 Page 9 of 18 Public Comment No. 14-NFPA [ Section No ] Facility Fire Brigade Apparatus. A facility fire brigade emergency response vehicle designed and intended primarily for fire suppression, rescue, or other specialized function that includes pumpers, foam apparatus, aerial ladders, rescue vehicles, and other such apparatus. You say in Chap 2 that the brigade cannot do rescue or hazmat then why do you have the vehicles be anything other than a pumper or ladder? Submittal Date: Thu Oct 10 10:34:33 EDT 2013 NFPA 600 does not prohibit fire brigades from performing other duties.

10 Page 10 of 18 Public Comment No. 15-NFPA [ New Section after ] Fire Brigade / Department Suppression Capability Fire Suppression Capability Fire suppression operations shall be organized to ensure that the fire brigade s fire suppression capability encompasses deployment of personnel, equipment, and resources for an initial arriving resonse, the initial full alarm assignment, and additional resonse assignments The fire brigade shall be permitted to use established automatic aid and mutual aid agreements to comply with the requirements of Section * Staffing. The number of on-duty fire suppression personnel shall be sufficient to perform the necessary fire-fighting operations given the expected fire-fighting conditions These numbers shall be determined through task analyses that take the following factors into consideration: (1) Life hazard to the populace protected (2) Provisions of safe and effective fire-fighting performance conditions for the fire fighters (3) Potential property loss (4) Nature, configuration, hazards, and internal protection of the properties involved (5) Types of fireground tactics and evolutions employed as standard procedure, type of apparatus used, and results expected to be obtained at the fire scene On-duty personnel assigned to fire suppression shall be organized into company units and shall have appropriate apparatus and equipment assigned to such company The fire brigade shall identify minimum company staffing levels as necessary to meet the deployment criteria required in (above section) to ensure that a sufficient number of members are assigned, on duty, and available to safely and effectively respond with each company Each company shall be led by an officer who shall be considered a part of the company. 5.3 Supervisory leader shall be dispatched or notified to respond to all full alarm assignments. 5.4 The supervisory leader shall ensure that the

11 Page 11 of 18 incident management system is established as required in Section XX 5.5* Supervisory leader shall have staff aides deployed to them for purposes of incident management and accountability at emergency incidents. 5.6 Operating Units. Fire company staffing requirements shall be based on minimum levels necessary for safe, effective, and efficient emergency operations Fire companies whose primary functions are to pump and deliver water and perform basic fire fighting at fires, including search and rescue, shall be known as engine companies These companies shall be staffed or assigned with a minimum of four on-duty personnel In jurisdictions with tactical hazards, high-hazard occupancies, high incident frequencies, geographical restrictions, or other pertinent factors as identified by the AHJ, these companies shall be staffed with a minimum of five or six onduty or assigned members. 5.7 Deployment The fire brigade resources shall be deployed to provide the arrival of the team/department within 300-seconds to 90 percent of the incidents. 5.8 Personnel assigned to the initial arriving responders shall have the capability to implement an initial rapid intervention crew (IRIC) This standard should also strive to set a min standard for staffing and response time for the brigade. This new section should address this. Submittal Date: Thu Oct 10 10:51:26 EDT 2013 These requirements can be covered in the organizational statement and are the responsibility of management.

12 Page 12 of 18 Public Comment No. 2-NFPA [ Section No. 6.1 ] 6.1 General. Facility fire brigades organized to perform advanced exterior or interior structural fire fighting only shall meet the requirements of Sections 6.2 through 6.6 in addition to all applicable requirements of Chapters 1 and 4 of this standard. This chapter now applys to facility fire brigades that perform advanced exterior or interior structure fire fighting as well as those that perform both advanced exterior and interior structure fire fighting. So "only" needs to be deleted for proper meaning of the applicability. Submitter Full Name: Michael DeVore Organization: State Farm Insurance Company Submittal Date: Wed Sep 18 10:56:56 EDT 2013 Accepted SR-1-NFPA Statement: Chapter 6 now applies to facility fire brigades that perform advanced exterior or interior structure fire fighting as well as those that perform both advanced exterior and interior structure fire fighting. So "only" needs to be deleted for proper meaning of the applicability. Language was added to clarify that facilities may choose to have an advanced exterior fire brigade only, an interior structural fire brigade only or both.

13 Page 13 of 18 Public Comment No. 3-NFPA [ Section No. 6.3 ] 6.3 Operational Requirements. Operational safety requirements shall be established for facility fire brigade members responding to a fire emergency shall be established and shall at a minimum include the emergency including, but not limited to, the following: (1) Personnel who are not trained in accordance with this standard are not permitted to enter the warm or hot zones established for a fire emergency. (2)* SCBA and thermal protective clothing are worn by facility fire brigade members entering the hot zone. (3) Thermal protective clothing is worn by facility fire brigade members entering the warm zone. (4) Facility fire brigade members operate in teams of two or more in response to fires that have advanced beyond the incipient stage. (5) Facility fire brigade members operating in the hot and warm zones have an established communications system. (6) When facility fire brigade members are operating in the hot zone, at least one facility fire brigade member with the capability to call for assistance remains outside the hot zone and maintains an awareness of the safety of facility fire brigade members located inside the hot zone. (7) When facility fire brigade members are operating in the hot zone, additional brigade members are standing by in the warm zone with approved equipment to provide assistance or rescue. (8) Facility fire brigade members positioned in the warm zone are visible to command positions at all times. (9) Personnel and facility fire brigade members positioned in any fire zone have opportunity to relocate to an alternate position should fire conditions change. (10) Experienced facility fire brigade members oversee activities of less experienced brigade members during fire-fighting operations. Edited for compliance with Manual of Style, section 1.8. Only 1 requirement permitted per sentence.

14 Page 14 of 18 Submitter Full Name: Michael DeVore Organization: State Farm Insurance Company Submittal Date: Wed Sep 18 11:01:02 EDT 2013 Accepted SR-2-NFPA Statement: Edited for compliance with Manual of Style, section 1.8. Only 1 requirement permitted per sentence.

15 Page 15 of 18 Public Comment No. 4-NFPA [ Section No ] Closed-circuit-type self-contained breathing devices shall be approved by NIOSH and MSHA with a minimum service duration of 30 minutes and shall Closed-circuit-type self-contained breathing devices shall operate in the positive pressure mode only. Edited to comply with Manual of Style, section 1.8. Only 1 requirement permitted per sentence. Submitter Full Name: Michael DeVore Organization: State Farm Insurance Company Submittal Date: Wed Sep 18 12:02:29 EDT 2013 Accepted SR-4-NFPA Statement: Edited to comply with Manual of Style, section 1.8. Only 1 requirement permitted per sentence.

16 Page 16 of 18 Public Comment No. 5-NFPA [ Section No ] * Facility fire brigade members using SCBA shall operate in teams of two or more members who are in communication with each other through visual or voice contact to coordinate their activities and are in close proximity to each other to and to provide assistance in case of an emergency Where facility fire brigade members are involved in operations that require the use of SCBA, at least two members shall be assigned to remain outside the area where respiratory protection is required One member shall be responsible for maintaining a constant awareness of the number and identity of personnel using SCBA, their location, function, and time of entry These members with SCBA shall The members assigned in shall be trained, equipped with SCBA, and available for rescue edited to comply with Manual of Style, section 1.8, for only 1 requirement. Sentence edited for clarity as to who "these members" are. Submitter Full Name: Michael DeVore Organization: State Farm Insurance Company Submittal Date: Wed Sep 18 12:10:02 EDT 2013 but see related SR SR-5-NFPA Statement: edited to comply with Manual of Style, section 1.8, for only 1 requirement. Sentence edited for clarity as to who "these members" are was modified to parallel terminology used in NFPA 1500 for methods of acceptable communication.

17 Page 17 of 18 Public Comment No. 1-NFPA [ Section No. A ] A Facility. The extent or limits for the location or facility at which a fire brigade operates might not coincide with property boundaries. The boundaries could be set by the authority having jurisdiction or in the organizational statement. The fire brigade can respond to fire incidents at locations that are familiar work places or have been pre-fire planned. At a facility or complex, there might be many different hazards or occupancy uses of structures. A fire brigade can respond at part of a site or at multiple structures at one location. Here are some examples: (1) Nuclear Power Plant: The fire brigade at a nuclear power plant responds inside the protected area. Beyond these limits, to the site property lines, is a security area that might contain structures. Typically these structures in the security area would be protected by a fire department complying with NFPA 1500, Standard on Fire Department Occupational Safety and Health Program. (2) College or University Campus: A science laboratory might need a fire brigade dedicated to the special hazards of the laboratory. Other occupancy uses on campus including large assembly spaces and dormitories might have fire brigades separate from the one at the science laboratory. (3) National Park Recreational Areas : A national park recreation area such as Yellowstone National Park might have several lodge areas within the limits of the park. Due to distance, each lodging facility could have its own fire brigade. (4) Industrial Park: There might be several structures at an industrial park that could be protected by a fire brigade. The technical committee discussed these changes in the First Draft meeting, but the revisions got lost in the larger reorganization of the document. The first paren about the nuclear facilities could be true or not and is too much information in either case. Recreation areas can be public or private and broadens the scope of the sentence as intended by the committee. Submitter Full Name: Michael DeVore Organization: State Farm Insurance Company Submittal Date: Wed Sep 18 10:28:57 EDT 2013

18 Page 18 of 18 but see related SR SR-6-NFPA Statement: The committee has provided nuclear facilities as an example. The term National Park was too limited and the term recreation area provides a better description of the intent by broadening the scope to include all types of recreation areas.

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