Fire and Aviation Management High Visibility Development Plan

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Introduction:

The Missoula Technology and Development Center was asked to put together a list of actions needed for Fire and Aviation Management to meet new federal high visibility regulations published in November.

Background Information:

On November 24, 2008, a new Federal regulation (23 CFR Part 634) went into effect mandating that workers whose duties place them in the right-of-way of a Federal-aid highway must be wearing high-visibility safety apparel that meets the requirements of ANSI/ISEA 107, Class 2 or 3.

The DOT/FHWA has recommended some changes to the rule, including allowing the use of high-visibility apparel that meets ANSI/ISEA 207. This standard was developed specifically for first responders and law enforcement personnel who must carry equipment, such as firearms, on their belts. ANSI/ISEA 207 allows garments with less background material, thus shorter vests with easier access to equipment will meet the standard.

DOT/FHWA has also proposed incorporating 23 CFR Part 634 into the MUTCD (Manual on Uniform Traffic Control Devices). This would expand the requirement for high-visibility garments to anyone working on any road open to public travel, not just Federal-aid highways.

Exemption for Firefighters:

On November 21, 2008, FHWA issued an Interim Final Rule to address safety concerns raised by the firefighting community regarding the particular high-visibility safety apparel that is required. This came about because no materials meet the fluorescent requirements of ANSI/ISEA 107 or 207 and the flame resistance standards of NFPA 1971 (for structural firefighting) or NFPA 1977 (for wildland firefighting).

The Interim Final Rule:

• Revises the definition of "worker" to exclude firefighters and other emergency responders when they are exposed to flame, fire, high heat, or hazardous materials.
• Exempts firefighters from the requirement to use high-visibility safety apparel (as defined in this rule) when they are exposed to hazardous conditions where the use of such apparel may increase the risk of injury to firefighters.
• Allows firefighters or other emergency responders to wear retroreflective turnout gear that is specified and regulated by other organizations, such as the National Fire Protection Association (NFPA), when working within the right-of-way of a Federal-aid highway and engaged in emergency operations that directly expose them to flame, fire, heat, and/or hazardous materials.
• Continues to require firefighters to wear high-visibility safety apparel meeting the standards cited in the original rule when working within the right-of-way, but not exposed to flame, high heat, or hazardous materials.

The US Forest Service Office of Safety and Occupational Health confirmed with FHWA that the exemption applies to all firefighters when performing firefighting duties, including wildland firefighters wearing garments that meet NFPA 1977. The Forest Service must still provide guidance to its employees describing the circumstances under which high visibility garments must be worn. The agency also wishes to evaluate other methods for mitigating the hazards associated with working along a roadway.

Recommended Actions and Development Work:

1. Policies/Procedures – Estimated Cost $15K:
   Establish procedures, policies, and SOPs so that Fire and Aviation Management (FAM) can provide guidance to the field on how to meet the requirements of the new rule.

• DECISION POINT: Establish specific guidelines and provide guidance to field for determining when high-visibility apparel meeting ANSI 107 (or eventually 207) is required and when wearing flame-resistant garments for wildland firefighting is appropriate. The dynamic nature of fire can make it difficult to determine whether workers are exposed. Employees such as ground support and workers in fire camp will need to know how to determine which type of garment is needed. (WO Leadership)
• Consider mitigating measures that could be used to decrease the exposure of firefighters to traffic, such as road closures (where possible), and alternative garment and accessory options. (Henderson, Sutton, MTDC)
• Consider whether policy changes are needed and make recommendations for appropriate changes in manuals and handbooks. (Henderson, Sutton, MTDC)
• Develop implementation strategy when mitigating measures have been selected (Henderson, Sutton, MTDC):

  i. If the selected option(s) includes manufacture or purchase of new PPE items, develop a plan for manufacture, purchase or retrofit of PPE.
  ii. If selected option(s) includes signing, develop a plan for manufacture or purchase of signs.
  iii. Develop and implement training plans.

2. Evaluate and/or develop equipment:
   Phase 1 – Evaluate/Develop Garments or Accessories - Estimated cost $42K:

• Evaluate options for increasing the conspicuity of wildland firefighters: Evaluate:

  i. The possibility of designing a new garment or accessory (MTDC)
  ii. The possibility of redesigning existing wildland PPE (MTDC).
  iii. Other methods for making firefighters more conspicuous, such as lighting or strobes. (MTDC)
  

For an option to be acceptable it must increase conspicuity, without hindering the safety or increasing hazards to wildland firefighters. (MTDC, Henderson). An acceptable solution must:

• Ensure immediate access to emergency equipment such as fire shelters.
• Ensure firefighters are not placed at risk caused by thermal instability of garment material, such as melting. Another emerging issue that must be evaluated is the risk of burn injuries associated with the discharge of stored thermal energy in some garment materials.
• Ensure garments do not cause additional hazards, such as entanglement in chain saws or other powered equipment.
• Ensure garments do not subject firefighters to additional heat stress.
• Design and field test garment or accessory. (MTDC).
• Determine costs of various options. (Henderson, MTDC)
• DECISION POINT: A decision by WO leadership will be required to select the appropriate option.

Phase 2 - Implement Selected Garment or Accessory Option: Estimated Cost $16K

• Develop drawings and specifications for selected option. (MTDC)
• Develop inspection criteria, instructions for refurbishment, and retirement guidelines. (MTDC)
• Identify how, when, and where to store or carry equipment. (Henderson, Sutton, MTDC)
• Develop tech transfer information and training to share with field. (MTDC)
• Implementation of tech transfer information. (WO Leadership)
• Work with GSA as needed. QA/QC (MTDC)

Phase 3 - Signing – Estimated cost $28K

• Determine SOPs for use of sign by FAM on roadways. (Sutton, Sheehy)
• Develop training curriculum. (Sheehy)
• Develop purchasing plan and field guidance. (Henderson)
• Develop materials to facilitate training and sharing of guidance with field. (MTDC)

Total Cost for all phases $100K

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