An Issue of Certification
Vol 21 No 2
OSHA is not famous for leniency when it comes to job safety violations. The following recent headlines speak for themselves:
- OSHA Cites Pipe Plant for 38 Health, Safety Violations
- OSHA Proposes $332,000 in Fines at Local Foundry
- OSHA Fines Plant After Fatality
Yet, despite this rigid reputation, neither OSHA, EPA nor even the NFPA can be accused of being zealots when it comes to certification of training standards for industrial emergency responders. That has been left to the industrial fire and emergency response managers. In Texas, there is a movement through the Emergency Services Training Institute at Texas A&M University to certify industrial firefighters as meeting the standards set by NFPA 1081 interior and exterior, along with other NFPA standards.
NFPA 1081 identifies the minimum job performance requirements necessary to carry out the duties of an individual who is a member of an organized industrial fire brigade providing service at a specific facility or site. NFPA 1081 interior certifies that a firefighter is trained in interior structural fire fighting. More important, NFPA 1081 exterior certifies that a firefighter is trained to handle fires in exterior process units.
NFPA 1081 is what is commonly referred to as a "consensus" standard. It came about because industrial people representing many different disciplines and many different regions came together using an NFPA committee-type format to develop a standard spelling out what emergency responders needed to know. This action was not at the behest of the Occupational Safety and Health Administration but because industry thought it necessary. To my knowledge, OSHA has never made an effort to adopt the provisions of NFPA 1081 as a job safety criteria.
Not that industry was being entirely altruistic when NFPA 1081 came into being. That warning on the side of cigarette packs about health risks is there to protect the manufacturers, not the smokers. Likewise, companies with fire brigades recognized that to protect themselves from litigation they needed to establish training standards that could be certified by a third party. Then, if the worst happened, the company would have evidence of its diligence in having adequately trained personnel on hand for any contingency. From this came the happy byproduct of better training for the firefighters being asked to risk injury or death defending the plant from catastrophe.
Sure, it is more than a bit hypocritical for a government agency such as OSHA to hold companies to a higher standard than applies to municipalities and other government agencies. And, in fact, companies receive far less than total indemnification even if compliance with NFPA 1081 is mandatory. That compliance is one factor in the company's favor taken into consideration against possible penalties. Still, half a loaf is better than none. Earning that half loaf is contingent on ordering the right kind of training for your fire personnel.
Training and, in particular, training exercises, should be based on the actual needs of your facility. That need is determined by the type of risk to which your particular industry and facility are most vulnerable. What type of fire are you going to have to fight and control? What equipment are you going to use? What style of incident management are you going to employ? You should be trained using a program that has defined objectives and criteria. Tank fire to hazardous material spills, rescue work -- if that kind of emergency is possible you have to be trained to handle it. And, at the end of the day, there has to be a method in place to measure the success of that training. Because that is what OSHA will be interested in once the fire is extinguished and the water hoses shut down.
It's a shame that the argument has to be framed in terms like "we might get nailed" rather than "it's the right thing to do." But like the song says "This ain't no Never-Neverland." True, and those big plants don't make cake batter. An industrial firefighter dead in the line of duty is a terrible thing that only rarely happens, thank God. But having the family of that firefighter claim in court that he lost his life because he was inadequately trained can quickly become an expensive affair for the company, to say nothing of a public relations nightmare continuing long after the smoke from the emergency has cleared.
Corporate executives weigh safety against what the company can afford every day. In the overwhelming majority of the time they decide correctly. Given the enormity of American industry, the record for safety is amazing. By its own admission the Chinese government reported that more 362,000 workers were injured and more than 63,000 had died on the job during the first half of 2004 alone.
Giving corporate executives some extra incentive to look favorably on more and better fire training is an effective route to what we all want in the end -- the best trained and equipped fire brigade possible. I'm a long way from saying I love OSHA, but its hard to deny they are doing what has to be done in this regard.o