Fire Protection Risk Management “A DoD Program Manager’s Perspective” Carmen DiGiandomenico

1. Fire Protection Risk Management “A DoD Program Manager’s Perspective” Carmen DiGiandomenico Pollution Prevention Planning, Inc. 2185 Harpoon Drive Stafford, Virginia 22552 (540) 659-5077 Pollution Prevention Planning, Inc.

2. OUTLINE • Purpose • Organizations & Functions • Decision-making Process • Summary Pollution Prevention Planning, Inc.

3. PURPOSE • Help you understand how DoD Program Managers (PMs) conduct fire protection risk management by providing: • An organizational & functional overview • Approaches to fire protection risk management • Insight into differences among services Pollution Prevention Planning, Inc.

4. ORGANIZATIONS & FUNCTIONS Pollution Prevention Planning, Inc.

5. External Regulators & General Accounting Office Laboratories Systems & Materiel Commands Program Manager (PM) Offices Operational Organizations Depot/Repair Organizations Organizational Overview Internal Regulators, Inspectors General & Advisors Pollution Prevention Planning, Inc.

6. Internal Regulators - USD(A&T) • DoD Regulation 5000.2-R - All PMs must: • Integrate environmental, safety, & health (ESH) issues into the systems engineering process • Develop a system safety & health program that: • manages risks from - death - injury - acute/chronic illness - disability - reduced job performance • covers personnel involved with the system who - produce - test - operate - maintain - provide support • ESH decisions based on lowest life cycle cost to protect human life and the environment Pollution Prevention Planning, Inc.

7. Internal Inspectors General • DoD & each service • Audit & review compliance to regulations • Conduct investigations into • Fraud, Waste & Abuse • Examples of reports: • HazWaste Minimization • 80% of DoD’s HazWastes come from weapon systems • Comanche (RAH-66) • $18B-$30B in HAZMAT-related life cycle costs Pollution Prevention Planning, Inc.

8. “Internal” Advisory Boards • DoD & service independent Science Boards • Examples of reports: • Defense Science Board Report on Aviation Safety • Decline in DoD accident rate has leveled off • Programs address basic causes only to a limited extent • Life Cycle Cost of accidents is rarely addressed • Naval Studies Board (NRC/Academy of Science) • Halon replacement efforts are being studied effectively, the body of knowledge is being developed & no gaps in the effort • Unlikely a drop-in replacement will be discovered • Effective alternatives have been identified & are being incorporated in new ships & aircraft • Promising agents, in addition to chemical replacement agents, are being considered (e.g., water-mist & inert gas generators) Pollution Prevention Planning, Inc.

9. External Regulators • Environmental Protection Agency • Clean Air Act (CAA) • Section 612(c) prohibits replacing Class I & II substances w/substitutes that may present adverse effects to human health & the environment • Significant New Alternatives Policy (SNAP) • Requires toxicity data (e.g., cardiotoxicity study in dogs) • EPA defers to OSHA for regulating workplace safety • EPA expects users to conduct thorough technical investigations • Acceptability not to be construed as endorsement of any given fire or explosion scenario - users should consult fire protection specialists • National Environmental Policy Act (NEPA) • Federal agencies (e.g., EPA, DoD, FAA) must consider the impact of policies & actions on the human environment as a part of their decision-making process • Occupational Safety & Health Administration • Occupational Safety & Health Standards (29 CFR 1910) • 29 CFR 1910.162 governs use of all gaseous agents in fixed extinguishing systems Pollution Prevention Planning, Inc.

10. General Accounting Office (GAO) • Congressional investigative office • Audits & reviews federal agencies • Example of reports: • Best Practices • Commercial firms gain more knowledge of a product’s technology, performance, & producibility much earlier in the product development than DoD • DoD increases risks by allowing more technology development to continue into product development Pollution Prevention Planning, Inc.

11. Laboratories • Basic & applied research • Typically non-system specific • Examples: • US Air Force Research Laboratory (AFRL) • Performance evaluation tests • Toxicity tests • US Army Center for Health Promotion & Preventative Medicine (CHPPM) • Toxicity Profiles • Health Hazards Analyses • US Naval Research Laboratory (NRL) • Performance evaluation tests Pollution Prevention Planning, Inc.

12. System & Materiel Commands • Provide PMs with engineering infrastructure • Examples • Air Force Materiel Command • Product Centers • Eliminated Fire Protection Office in early 1990s • Process Action Committees (PACs) concluded Air Force lacked sufficient infrastructure support • Naval Air Systems Command • Naval Air Warfare Centers • Army Materiel Command • Major Subordinate Commands Pollution Prevention Planning, Inc.

13. Program Managers (PMs) • Responsible for all aspects of program • Cost • Schedule • Performance • Operational requirements (e.g., survivability) • Technical requirements (e.g., ESH integration) • Develop & control maintenance procedures • Decide on system fire protection • Passive (e.g., isolate hot surfaces, quick shut-off) • Active (e.g., agent, distribution, detectors) Pollution Prevention Planning, Inc.

14. Operational Organizations • Establish operational requirements for PMs • Primary input for funding prioritization • Conduct “day-to-day” maintenance • Include “Users” of weapon systems, e.g., • Air Force User Major Commands • Army - User Major Commands • Navy - Fleet Commanders in Chief Pollution Prevention Planning, Inc.

15. Depot/Repair Organizations • Conduct major overhauls, rebuilds, & repairs • Follow PMs’ maintenance procedures • Include: • Air Force Logistic Centers • Naval/Marine Corps Air Rework Facilities • Army Depots Pollution Prevention Planning, Inc.

16. Decision-making Process Pollution Prevention Planning, Inc.

17. How Do PMs Make Decisions? • “Risk Management” decisions based on available data that are: • Accurate • Based on accepted technical & management standards • Complete • Balanced across all critical parameters • Systems engineering (“holistic”) solutions • Objective • Provided/reviewed by “honest brokers” (e.g., input from agencies who have no vested interest in the outcome of the decision) • PMs place trust in agencies who provide data that are accurate, complete, & objective Pollution Prevention Planning, Inc.

18. Accepted Technical Standards • Data based on universally accepted standards, e.g., • Fire suppression • NFPA • Materials Compatibility • ASTM, NIST • Toxicity & Exposure • AMES Screening • DuPont, et. al. Cardiac Sensitization • OSHA Standards Pollution Prevention Planning, Inc.

19. Accepted Management Standards • MIL-STD-882C “System Safety Program” • Accepted by both industry & government • Proven & used by services in managing ESH risks • For system hazards, requires all PMs to: • Identify in terms of their specific system • Assess in severity and probability of occurrence • Categorize in terms of high, medium/serious, and low • Prioritize in terms of importance & mitigation effectiveness • Mitigate in terms of how and when • Obtain acceptance in terms of the correct level of authority Pollution Prevention Planning, Inc.

20. These don’t happen These happen often too often but when and they’re always they do, they’re bad. bad. FIX THESE. FIX THESE. These happen often but when they do, These don’t happen they’re not too bad. often and when they FIX THESE. do, they’re not bad. They don’t pass the “so-what” test! System Risk Management Analysis HIGH SEVERITY OF AN OCCURRENCE LOW HIGH PROBABILITY OF AN OCCURRENCE Pollution Prevention Planning, Inc.

21. A2-Exposure > Cardiac Sensitization & Infrequent Accidental Discharges B1-Exposure < Cardiac Sensitization but > permanent lung damage & Frequent Accidental Discharges B2-Exposure < Cardiac Sensitization and > permanent lung damage & Infrequent Accidental Discharges A1-Exposure > Cardiac Sensitization & Frequent Accidental Discharges B2 B1 A1 A2 Risk Management Analysis Comparison of Two Agents During Accidental Discharges HIGH SEVERITY OF AN OCCURRENCE ( chemical & exposure related) LOW HIGH PROBABILITY OF AN OCCURRENCE (system related) Pollution Prevention Planning, Inc.

22. Critical Parameters • Identified by PMs • Varies from system to system based on requirements • Must include life cycle issues • A common list has been developed by Army • Common list effectively used by PMs in other services Pollution Prevention Planning, Inc.

23. Class A Effectiveness Class B Effectiveness Class C Effectiveness Class D Effectiveness Complete Volume Fill Quick Response Time Persistence Cooling Effect Throwing Characteristics Neat Agent Health Effects Pyrolysis Health Effects Visual Acuity Clean Agent Shelf Life Stability in Bottle Environmental Impact of Production Environmental Impact of Neat Agent Environmental Impact of Pyrolysis Products Electrically non-conductive Neat Agent Compatibility w/Protected System Pyrolysis Products Compatibility w/Protected System Neat Agent Compatibility w/Fire Suppression System Availability of a Viable Production Base Refill Capability Handling, Transportation, Maintenance Impacts Testing Hardware Availability Space & weight Impacts Costs Critical Parameters Common List Pollution Prevention Planning, Inc.

24. Systems Engineering Approach • Seeks “holistic” solution • Avoids “drop-in” euphoria • Involves much more than “chemists” • Considers all practical aspects • Passive as well as active techniques • Agent effectiveness • Distribution aspects • Detection sensitivity/reliability Pollution Prevention Planning, Inc.

25. Objective Information • PMs don’t like being given “half-truths” • PMs rely on internal “honest brokers” • PMs are inundated with “sales pitches” • PMs are wary of “drop-in” solutions Pollution Prevention Planning, Inc.

26. Summary • PMs • Are key to system-related fire protection decisions within DoD • Respond to Military Operators’ requirements • Attempt to make informed “risk management” decisions • Approach issues from a systems engineering perspective • Rely on accurate, complete, & objective data • Use accepted standards • Don’t like “surprises” • Researchers can be most effective when they • Understand the system(s) that their technology/agent may support • Understand PM’s “risk management” decision process • Understand the life cycle issues involved with their technology • Provide accurate, complete, & objective data early in process Pollution Prevention Planning, Inc.