NFPA 1500 Compliance Audit

1. NFPA 1500 Compliance Audit William Ruting, STA Emergency Planning Specialist Argonne National Laboratory

2. Overview Rationale NFPA 1500 Audit Process NFPA 1500 Deconstruction Assessment Findings Final Report

3. Rationale 10 CFR Part 851, Worker Safety and Health Programs DOE Part 851 Rules require: Compliance with NFPA 1500 FD’s to determine compliance Submit plan on achieving compliance DOE Orders 420.1 & 440.1

4. 10 CFR 481 Requirements “This [compliance] includes meeting the applicable building code and National Fire Protection Association (NFPA) Codes and Standards or exceeding them, when necessary, to meet safety objectives, unless explicit written relief has been granted by DOE.”

5. Some “Wiggle Room” in 481! “…DOE agrees that any requirement that is not directly related to the safety and health of workers is not applicable in the context of this rule.”

6. Equivalencies “DOE agrees in part and concludes that, beyond the definition of a formal exemption process to this rule, no explicit reference to ‘equivalencies’ is necessary, as this concept is an integral part of all NFPA codes and standards and DOE fire safety directives.”

7. Which NFPA Codes?

10. DOE agrees and has deleted the NFPA standards governing fire department operations from the final rule.DOE agrees and has deleted the NFPA standards governing fire department operations from the final rule.

12. Other 10 CFR 481 Requirements Industrial Hygiene Biological Safety Occupational Medicine Motor Vehicle safety Electrical Safety Workplace Violence Prevention

13. A. Subpart A—General ProvisionsSection 851.1—Scope and Purpose …to minimize the burden on contractors by clarifying that they need not establish redundant worker protection programs to protect workers from occupational safety and health hazards.

14. Appendix A—Worker Safety andHealth Functional Areas 2. Fire Protection “DOE agrees that a more pragmatic and less prescriptive approach to the delineation of requirements for fire protection and emergency services is appropriate. Consequently, the final rule has been revised to include the text from the fire protection portion of DOE Order 440.1A, which has been in effect since1998.”

15. Primary NFPA Standard NFPA 1500: Standard on Fire Department Occupational Safety and Health Program

16. NFPA 1500 First publication 1987 Current version 2007 Designed for public fire departments National Standard No regulatory force Used as legal exhibit

17. Changes in 2007 Version Added protective ensembles for technical rescue and chemical/biological terrorism An updated section on risk management Revised and reorganized chapter on training and education Enhanced chapter on operating fire apparatus First-time sections on operations at traffic incidents, establishing control zones, and fitness for duty evaluations Added section on appointment of a health and safety officer

18. 1500 Overview

19. Public Fire v. DOE Fire DOE primary coverage non-residential Predominance of fixed suppression systems Smaller total protected area Private roads = quicker responses Fire experience lower Personal concern over fire losses

20. DOE Considerations Unique facilities Extremely high value Irreplaceable Unique hazardous materials Radiologcial Non-Radiological Security concerns

21. The “1500” Pound Taco Whole is greater than sum of parts More convoluted than the Mississippi River Is a “moving target” Was developed by a committee “The camel is a horse designed by a committee”

22. 45 in blue list45 in blue list

23. ANL 1500 Compliance Audit Completed in 2006

24. Methodology “Deconstruction” of 1500 2002 Version 406 individual criteria Each criterion individually evaluated Interview with Chief & Staff Review of Department Materials Policies, procedures, SOP’s, Etc. Site-wide materials Personnel policies, safety rules

25. Methodology, Continued Compliance level determined Full Comply With Intent “Equivalencies” Partial Non-Compliant Not Applicable Detailed description of compliance status

26. Methodology, Continued Developed plan to improve or achieve compliance Date by which compliance could be achieved Projected costs for compliance Initial On-Going Exhibits Title of document Other supporting material

30. Assessing Results Numerical data Percent in each category Cost to achieve full compliance Non-Numerical Compliance issues Obstacles to compliance Other issues

31. Final Report: Contents Executive Summary Introduction Results by Section Discussion of Results Cost of Compliance Conclusions & Recommendations

32. Results 73.9% = Full 8.9% = Comply With Intent 4.2% = Partial 3.4% = Non-Compliant 9.6 = Not Applicable

33. Results By Chapter

34. Compliance With Applicable

35. Major Compliance Costs Annual testing of ground ladders Fire resistant uniforms Changes to communications center Traffic cones Fitness trainer certification Fitness program

36. Recommendations Develop a structured fitness program Annual testing of ground ladders FD respiratory protection program Develop additional written policies In-depth review of “partial” items