We have all read and heard a great deal recently about the issues surrounding the use of live fire at locations other than established, regulated and properly designed training facilities. It is extremely difficult to think about this topic without pondering the fact that lives have been lost. It is also critical that we not forget the lives that have been derailed and destroyed as a result of these episodes.
The most recent incidents involving deaths and injuries during live-fire training come from New York and Florida. Tragically, a life was lost in a small community near Utica, NY, and an other changed forever by severe burn injuries. Not too many months later, several firefighters were injured during a live-fire training session when the building blew up near Amsterdam, NY. In July, two Florida firefighters lost their lives in a live-fire training accident.
How can this be? How could we have reached our current state of affairs in the year 2002? Weren't there two tragic deaths in Boulder, CO, in 1982? Didn't we lose three more firefighters in Milford, MI, back in 1985? I know that there were three serious injuries in Parsippany, NJ, in 1992. I know this because this was the defining moment that led to our mandatory live-fire training requirements in New Jersey. That adds up to 20 years of actual identified experience.
There have also been reports involving serious burn injuries at acquired structure training sessions from a number of different states over the past few years. It was also my sad duty to participate in the funeral for the assistant fire chief who died in Delaware in 2001. The death of that young man had a real impact on me. That is why I have written so much on the topic recently.
The assistant chief who was in charge of the 2001 live-fire training session in New York State where a young volunteer firefighter died has been convicted of manslaughter. We can no longer debate the efficacy of the decision to prosecute him. What is past is now truly prologue. Now that the heavy hand of the law has landed on one of our own, I fear that this judicial action may have a chilling impact upon the live-fire training opportunities for future generations of firefighters.
Using acquired structures is the only way that firefighters in many places can experience the heat, smoke and challenge of combating an actual fire. It is my fear that people in many places will simply stop conducting these sorts of important training exercises. Rather than spending the necessary time to learn the proper way to conduct live-fire evolutions in acquired structures, they will stop live-fire training all together. I am quite concerned that people will think that the only way to avoid liability is to halt live-fire training sessions in acquired structures. Fear is a powerful force, particularly fear of the legal community.
I strongly believe that this must not happen. We who teach and train must work to make sure that everyone has an equal access to proper fire training. Far too many states do not have regulations governing training. I think the time has come for those states to develop training standards that apply equally to all within their fire service.
Questions To Consider
The days of burying our heads in the sand must come to an end. We must determine what is going on here? I now want to ask a few serious questions. We have to step up to the plate and answer them if we are to continue to progress as a fire service in the U.S.:
- Why are there people out there within our fire service who think that they are exempt from the laws of physics and chemistry?
- Why are there people who think that they do not have to obey anyone's rules and regulations because they are only volunteers?
- Why are there people who think that Nomex turnout gear is a cure for everything, including the common cold?
- How can there still be people who are not aware that there is a safe way to train, if you but take the time to learn it?
- What must we do to get the fire service to training correctly?
If we are to continue to train firefighters to perform the dirty and dangerous job of fire suppression, we must provide them with the proper training. We must expose them to the effects of fire, but we must do this in a way that minimizes the potential for death and serious injury.
I have been writing and reporting on live-fire training issues for more than 10 years. My mission has been to create an awareness of how to conduct such training in a safe manner. This is now particularly true for the acquired structure environment.
A great deal has been said about what we should know, who should know it and who is responsible. Even more has been spoken and written about the number of people who claim ignorance when it comes to the issues regarding National Fire Protection Association (NFPA) codes, standards, and recommended practices.
I have received a number of negative e-mail responses when I have chosen to speak up regarding the need for safe training practices. Here is a short list of some comments I have received:
- I have never heard of the NFPA. Who are they? Why do I need to pay attention to them?
- I am a volunteer. Those standards are for career people, not for me.
- They are hard to read.
- They are just for lawyers anyway.
- They are too expensive.
- They make reference to all sorts of obscure things.
- Who says that I have to obey them anyway?
These make no sense to me. However, since they seem to be the prevailing thoughts in many places, let me address the issue of how to overcome ignorance of the rules for live-fire training in acquired structures.
NFPA 1403 In Review
I would like to begin with a review of NFPA 1403, Standard on Live Fire Training Evolutions, what it is and why it was written. The latest edition of this important standard was issued in January 2002. My first task is to identify just what the standard is intended to do. I would suggest that this information is contained within the scope statement, located at the beginning of the document: "This standard shall contain the minimum requirements for training fire suppression personnel engaged in fire-fighting operations under live fire conditions … Procedures for live fire training evolutions that involve marine structures or vessels and ground cover or wildland fires shall not be covered in this standard."
I think that we can see from this description that NFPA 1403 was created to guide us in the delivery of live-fire training in the standard structural environment. Further guidance comes from the purpose statement for this document: "The purpose of this standard shall be to provide a process for conducting live fire training evolutions to ensure that they are conducted in safe facilities and that the exposure to health and safety hazards for the fire fighters receiving the training is minimized."
The committee that drafted this document had standard structural firefighting operations in mind when they drafted this document. We train to prepare us for those things we are expected to do.
Like all NFPA standards, NFPA 1403 has no force of law until someone or some entity adopts it. However, when they do, there are some guidelines to assist in its implementation. It is important to note that whether this standard is adopted or not, it can be used by the legal community to establish what is known as a standard of care. Basically this theory states that if such a standard as this exists, it should be used to guide the thinking of operational personnel whether or not it has been adopted and has the force of law behind it.
This latest revision of this standard discusses two distinctly different live-fire-training environments. It covers interior live-fire training in a training center burn building, of either the gas-fired environment or the non-gas fired facility. It also covered live-fire training in an acquired building. Each of these facilities has hazards inherent in their specific circumstances. You need to be aware of this fact.
Definitions lie at the heart of every NFPA standard. It is critical for you to become familiar with these definitions. In this case, NFPA 1403 defines an acquired building as "a structure acquired by the authority having jurisdiction from a property owner for the purpose of conducting live-fire training evolutions." The authority having jurisdiction is defined as, "The organization, office, or individual responsible for approving equipment, materials, an installation, or a procedure." It can be a city, county, state or other jurisdiction, or organization.
It has been my experience that exposing your personnel to live-fire evolutions is an excellent means of training firefighters. While we have found that this type of training provides a real environment, it also carries with it the actual hazards of interior fire fighting at an actual emergency. Interior live-fire training evolutions shall be planned with great care and supervised closely by instructional personnel. Safety has to be everyone's first consideration.
It has been my experience that any information contained in NFPA 1403 is there to help us do our job safely. The standard allows your organization flexibility to utilize independent judgment based on local situations and the level of training to be accomplished. The experience of the instructors can be utilized within an established framework.
One of the critical definitions included in this document involves the difference between acquired structures and training center burn building. The acquired building is "a structure acquired by the authority having jurisdiction from a property owner for the purpose of conducting live fire training evolutions." On the other hand, a training center burn building is "a structure specifically designed for conducting live fire training evolutions on a repetitive basis."
I would suggest that the major difference between the two structures comes from the relative permanent nature of the training center, as compared to the transitory, changing nature of the acquired structure. The training center building is the same every day.
Regardless of whether the training structure is fixed and permanent, or is of an acquired nature, each operation has the same entry level requirements for their student populations. They specifically state that, "… prior to being permitted to participate in live fire training evolutions, the student shall have received training to meet the job performance requirements for Fire Fighter I in NFPA 1001, Standard for Fire Fighter Professional Qualifications, related to the following subjects:
- Fire behavior
- Portable extinguishers
- Personal protective equipment
- Fire hose, appliances, and streams
- Water supply
- Forcible entry.
This requirement is extremely important. People who are about to partake in the stressful environment of live-fire training need to have a firm grounding in the basic operational skills needed to be an active participant in structural firefighting training operations.
One of the problems that I recall from the 1992 training accident in Parsippany, NJ, came from the uneven basic training experience that existed among the people who were injured. There was no even standard among the people in the training evolution.
We in New Jersey have addressed this particular problem as part of our mandatory state live-fire training regulations. We have specified the same requirements as NFPA 1403 as our prerequisites for the live-fire portions of our firefighter-training program. While training itself is a voluntary undertaking, the live-fire aspect of it is covered by mandatory legislation.
The standard also recognizes that fire personnel periodically move from place to place. They specify that, "Students participating in a live-fire training evolution who received the required minimum training specified in 4.1.1 from other than the authority having jurisdiction shall present written evidence of having successfully completed the prescribed training prior to being permitted to participate in any live fire training evolution." This allows people to document past experience, rather than having to start all over at the beginning. This is an important provision in today's more mobile society.
It is critical to remember that you will need to operate via a specified incident management system (IMS). There will be an instructor-in-charge who will be in operational command of the training evolution. There will be a designated safety officer. NFPA 1403 states specifically that there must be enough trained instructors to insure:
- One instructor is assigned to each functional crew, which shall not exceed five students.
- One instructor to each backup line.
- Sufficient additional personnel to backup lines to provide mobility.
- One additional instructor for each additional functional assignment.
You should delineate the training area through the use of ropes, signs, and fire line markings. The code specifically requires you to restrict spectators "to an area outside the operations perimeter established by the safety officer." Just as one the fireground, freelancing should be prohibited.
One of the things that you must never do is use a live human subject as a victim in the burn building. Suitable props should be acquired and used.
Prior to beginning live-fire evolutions, a search of the structure must be made. This is done to assure that unauthorized persons are not entering the structure to get a closer look at the operation. Or in the case of Newark, to insure that our resident homeless were herded out before the fire was lit.
A critical part of any live-fire training session, regardless of location, involves the pre-burn briefing session. Each aspect of the various evolutions will be covered and roles and expectations discussed. You do not want any unpleasant surprises during your training evolutions. Be sure to have a written plan to follow.
It is also extremely important to do a pre-burn walkthrough in the burn structure. It has been my experience that this gives a greater sense of confidence to the participants and instructors. They can become familiar with the layout of the building while they can still see the various parts of the training area. It will be the same building when filled with heat and smoke, but it sure won't seem that way.
All personnel, both students and faculty, must use the appropriate NFPA-compliant turnout gear, self-contained breathing apparatus (SCBA) and personal alert safety systems (PASS devices). Newer SCBA have the PASS device built into the apparatus. Just before the operation begins, an inspection of all personnel must be made. This is done for the following reasons:
- To insure that all gear is compliant.
- To insure that all gear is being worn correctly.
- To insure that sufficient air is available in each SCBA. NFPA 1403 goes on to specify the circumstances that require the use of SCBA. These devices must be worn:
- In an atmosphere that is oxygen deficient or contaminated by products of combustion or both.
- In an atmosphere that is suspected of being oxygen deficient or contaminated, or both.
- In any environment that can become oxygen deficient or contaminated, or both.
- Below ground level.
Once the instructor-in-charge and the safety officer have concluded that all is in readiness, the decision to light the fire can be made. It is critical that an instructor visually confirms that the area where the fire is located is clear of personnel. This can eliminate the chance for death or serious injury. It is important to remember that the instructor-in-charge has the overall responsibility for the manner in which the operation is conducted.
The code is quite specific when it comes to the nature of the fuels to be used. It states in NFPA 1403 that "the fuels that are utilized in live fire training evolutions shall have known burning characteristics that are as controllable as possible. Unidentified materials, such as debris found in or around the structure that could burn in unanticipated ways, react violently, or create environmental or health hazards, shall not be permitted to be used." You should only use enough fuel to create a fire of the desired size.
There are the fuels you are not permitted to use. They include:
- Pressure-treated wood.
- Straw or hay treated with pesticides or harmful chemicals.
- Flammable or combustible liquids are strictly prohibited.
There is an exception to this last statement. Limited quantities of combustible liquids with a flash point above 100 degrees Fahrenheit shall be permitted in structures that have been designed to allow the use of fuels such as this.
Remember that the authority of the safety officer is absolute. Regardless of their rank, they have the authority to shut down any operation deemed by them to be unsafe. The wise instructor-in-charge will accept their word and shut down the operation.
I want to reinforce the fact that the greatest percentage of live-fire training problems we have reviewed can be found in the arena involving the use of structures acquired for training purposes. We would suggest that the use of these buildings be undertaken in accordance with strict safety procedures.
These procedures should be developed by your staff and be directly extracted from the pages of NFPA 1403. A great deal of information is available in the appendices of the standard for your use. Once these procedures are developed, they shall govern the use of all off-site structures that have been acquired for training purposes. While a fire training center structure has usually been designed for the role it will play in training, off-site structures have not.
Whether it is your intention to conduct burn evolutions in the building or not, strict attention must be paid to preparing the structure for your use. It may be that you will have to spend a sum of money to ready the property to meet local building codes. I can recall a series of live-fire exercises conducted in New England a few years back. A number of these structures were offered for live-fire use in performing Class-A foam firefighting research.
In order to obtain permission from local code compliance authorities, more than $5,000 had to be spent to repair holes and improve structural integrity. When the building was properly repaired, a series of live burns was conducted. It should be remembered that safety and not expediency is the primary goal of any operation in an acquired structure.
There are a number of important steps that must be taken to insure that your use of an acquired structure is performed properly. You should:
- Secure all necessary permits for air quality, water runoff, water usage, burning and traffic control. You will need to research the appropriate state and local regulations to insure that you are in compliance.
- Confirm property ownership.
- You will need to examine proof of clear title to the property in question.
- A clear description of the anticipated condition of the acquired building at the completion of the evolution(s) and the method of returning the property to the owner shall be put in writing and shall be acknowledged by the owner of the structure.
- Secure the appropriate live-fire training permits from state and local authorities.
- The owner of the property shall provide a certificate of insurance.
- A complete inspection of the property in question will be made to insure structural integrity.
- It must be ascertained whether the structure in question will hold the weight of personnel, equipment, and water.
- Damage from fire will be a part of this assessment.
- All hazardous materials and storage will be removed from the property in accordance with appropriate state and local regulations.
- All hazardous conditions shall be corrected prior to the using the structure for your live-fire evolution.
- Closed containers and highly combustible materials shall be removed from the structure.
- Oil tanks and similar closed vessels that cannot be removed shall be vented sufficiently to prevent an explosion or overpressure rupture.
- Any hazardous or combustible atmosphere within the tank or vessel shall be rendered inert.
- All hazardous structural conditions shall be removed or repaired so as to not present a safety problem during use of the structure for live-fire training evolutions.
- Floor openings shall be covered.
- Missing stair treads and rails shall be repaired or replaced.
- Dangerous portions of any chimney shall be removed.
- Holes in walls and ceilings shall be patched.
- Some locales actually paint arrows on the floor so that the participants can find easy egress.
- Paint the wall sides with A, B, C and D to create an understanding of building layout. In order to insure that the structure is safe for personnel, the following items shall be inspected and defects corrected:
- Floors, railings and stairs shall be made safe.
- Special attention shall be given to potential chimney collapse hazards.
- All walls and ceilings shall be intact or patched.
- Debris creating or contributing to unsafe conditions shall be removed.
- Low-density combustible fiberboard and unconventional interior finishes shall be removed.
- All extraordinary weight that might rest above the training area shall be removed.
- Bathtubs should be removed, so that they do not fill up with water and add weight to the floor. Any hole caused by this action will be covered in a solid, permanent method. (Nailing boards over the hole could be one way.)
- No one will be allowed to move on floors above the fire area, as they might increase the weight and cause an unexpected collapse.
- An adequate ventilation opening shall be created in the roof to insure that there will be a minimal opportunity for heat, smoke, and toxic or explosive gases to build up in the structure.
- Utilities to the structure shall be disconnected at the street.
- Always think about the existence of toxic materials, insects and vermin that might be in the structure.
- All asbestos shall be removed from the structure by a qualified asbestos-removal contractor.
- Some states require that you remove the roof covering.
- Be sure that your operation complies with all appropriate state, county, and local regulations.
After reviewing this list, you can begin to see where all of the hidden costs in using an acquired structure might lie. Never forget for one moment where a failure to consider safety might leave you. Let the results of the New York case be your guide as to what can happen. It is difficult to justify death and injury if you just plain ignore the literature on how to operate safely.
Here are a few more thoughts on training in acquired structures:
- If you cannot make the building safe, do not use it.
- If there is a building next door, take pains to protect it.
- If the building next door cannot be protected, see if it can be taken down. If not, you should consider not operating. While the house that was donated to you might not cost much, burning down the neighbor's can be real expensive.
- Trees and brush that can spread the fire should be cut back or removed.
- The utilities to surrounding property must be protected or cut off.
- Be sure to let the people in the area know that you will be training in their neighborhood.