Beards, training, and my liability as a training officer
I find myself in a bit of a quandry regarding beards and training. I am the training officer for 2 POC FDs and as such I have firefighters on both FDs that have beards and 2 chiefs that simply won't enforce the no beards or facial hair that interferes with the seal of the mask standard. It becomes even more interesting when you look at Administrative Code in Wisconsin where it specifically spells out no facial hair with a mask. Specifically SPS330, FIRE DEPARTMENT SAFETY AND HEALTH STANDARDS, Sub-Chapter 8 Protective Clothing and Equipment, SPS 330.12, Paragraph 2, Part d:
So where am I going with this? Besides being the training officer of these 2 POC FDs I am a career firefighter and a 33 year tech college instructor. I know the NFPA Standard and I know the State of Wisconsin Administrative Code regarding facial hair and the wearing of SCBA facepieces and I have begun to wonder what MY PERSONAL liablity is if I train people with beards in drills using SCBA? It has become such a concern to me that I am considering going to both chiefs and stating that I will no longer allow anyone with a beard to participate in any drill that requires the use of SCBA. I am relatively sure that I may not be a training officer for much longer but I feel this issue is serious enough to force that kind of confrontation. I take my position as training officer very seriously and documentation of that training just as seriously. I have already implemented the "You don't physically participate you don't get on the training record rule" and that has met with some unhappy officers that like to watch but not do the actual drill.
(d) A fire fighter may not wear a beard or facial hair that comes
in contact with a facepiece seal if the fire fighter’s duties require
him or her to use a self−contained breathing apparatus. If a fire
fighter wears eyeglasses, the fire fighter shall use frames that do
not pass through the seal area of the facepiece.
So help me out here, am I overreacting or am I spot on here?