By JACK SULLIVAN
One of the more challenging fire service issues today is how to best protect firefighters, emergency medical technicians, and law enforcement personnel at the ever-increasing number of roadway incidents. Related to this challenge is the protection and management of the victims of the initial incident and the motorists who are passing the scene. A secondary challenge is clearing the scene and resuming normal traffic flow.
In 2005, the National Institute for Occupational Safety and Health (NIOSH) reported 390 workers of all occupations were struck and killed by vehicles on roadways, up from 378 in 2004. NIOSH also reports an average of 365 struck-by-vehicle incidents per year from 2000 to 2004. Struck-by incidents account for seven percent of all fatal occupational injuries.1
In 2001, NIOSH reported 26 firefighters struck and killed between 1990 and 1999, which then represented an 89-percent increase in those fatality types from 1995 to 2000. From 1989 to 1998, the National Firefighter Protection Association (NFPA) reported 36 firefighters struck and killed by vehicles.2
The Emergency Responder Safety Institute (www.respondersafety.com) has reported and tracked struck-by incidents involving emergency responders for many years. The frequency of this type of incident appears to be increasing. Many of us can relate stories of close calls at incident scenes at some time in our careers.
Every time units respond to an emergency, the personnel onboard step into harm’s way wherever they disembark from the apparatus. Being struck by a vehicle is possible along any type of roadway—not just on limited-access, high-speed highways. Even personnel who stop for groceries in a shopping center parking lot are at risk. It is absolutely critical that every agency improve efforts to prevent personnel from being struck by vehicles during emergency responses and routine operations.
There are some core elements of a comprehensive Roadway Incident Safety Program that each fire department should have in place. Evaluate the current program elements for your agency with the following list3:
1 Roadway incident safety training for all personnel.
- a. Initial orientation for new recruits before they respond to any emergency.<
- b. Annual in-service training session for all personnel.
- c. All training in line with standard operating procedures (SOPs) and national standards, rules, regulations, and “best practices.”
2 Roadway incident response procedures.
- a. Document, authorize, and publish SOPs. (3)
- b. Comply with NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, Section 8.7 on Traffic Incidents.4
- c. Comply with the Manual of Uniform Traffic Control Devices (MUTCD), Chapter 6I—Control of Traffic through Traffic Incident Management Areas.5
3 Proper personal protective equipment (PPE) for all personnel.
- a. Document Occupational Safety and Health Administration-compliant PPE hazard assessment.6
- b. NFPA-compliant turnout gear.7
- c. American National Standards Institute (ANSI)-compliant high-visibility garments.8
4 Multiagency and multijurisdictional cooperation, collaboration, and communication.
- a. Regular fire department attendance and participation in local and regional traffic incident management committees.9
- b. Ongoing multiagency planning and training on roadway incident response procedures. (9)
- c. Multiagency review and critique of traffic incidents to improve strategies and tactics at future incidents.10
5 Properly position apparatus and traffic control equipment at incidents.
- a. Park large fire apparatus at an angle upstream of the incident work area.
- b. Turn front wheels away from the incident scene and properly chock units when parked.
- c. Properly deploy advance warning devices, including MUTCD-compliant high-visibility signs and cones.
- d. Position ambulances downstream with the loading area doors angled away from moving traffic, whenever possible.11
- e. Park all emergency equipment on one side of the road.
- f. Effectively place police cars for traffic control and scene safety.
- g. Effectively use any available safety service patrol apparatus.
6 Fire apparatus enhanced visibility design features.
- a. Emergency warning lights designed for on-scene protection.
- b. NFPA 1901, Standard for Automotive Fire Apparatus-compliant high-visibility (reflective and florescent) chevrons on the rear of apparatus, road cones, and PPE.12
High-visibility traffic safety vests got a lot of attention on November 24, 2008, because of the publicity surrounding Federal Rule 634, which, for the first time, required all workers operating within the right-of-way of a federal-aid highway to wear a high-visibility garment that meets or exceeds ANSI-107 Class 2 or Class 3 standards. For months preceding the implementation date, firefighter forums and Web sites buzzed about the new rule and its implications.
Many of us in the fire service recognized that it was a new rule with good intent, but it was somewhat impractical as originally written for safe firefighting operations on the nation’s highways. Fortunately, the Federal Highway Administration (FHA) announced a last-minute interim rule that allows firefighters engaged in direct firefighting operations and exposed to heat, flame, fire, or hazardous materials to wear appropriate PPE designed according to NFPA standards. All other on-scene personnel are expected to wear high-visibility garments, and firefighters are expected to don high-visibility gear when they are not exposed to heat, flame, fire, or hazardous materials. This interim rule does NOT say that NFPA-compliant turnout gear is a substitute for ANSI-compliant high-visibility garments under all circumstances, as some have tried to interpret it.13
On December 16, 2009, the FHA published a final rule adopting the 2009 edition of the MUTCD. The 2009 MUTCD now requires high-visibility safety apparel for workers in the right-of-way of any road—not just federal-aid roadways. The wording adopted previously in Interim Federal Rule 634 for emergency responders as described above was also carried over into the 2009 MUTCD. The new version of the MUTCD also recognizes and allows the use of ANSI 207-2004 high-visibility public safety vests as an option for emergency workers on roadways.14
NFPA 1500 states, “The fire department shall provide each member with protective clothing and protective equipment that is designed to provide protection from the hazards to which the member is likely to be exposed and is suitable for the tasks that the member is expected to perform.”
The Occupational Safety and Health Administration (OSHA) also has regulations that address PPE. Fire departments that operate in any of the states that have an OSHA plan must comply with OSHA regulations. Fire departments in states covered by federal OSHA rules are not presently required to comply with OSHA regulations, but they can certainly look to the OSHA regulations as “best practices.”
OSHA 1910.132(d) covers hazard assessments and equipment selection and states, “The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE).”15 It further requires employers to do the following if such hazards are present or likely to be present:
- Select and have each affected employee use the PPE types that will protect the affected employee from the hazards identified in the hazard assessment;
- communicate selection decisions to each affected employee;
- select PPE that properly fits each affected employee; and
- verify that the required workplace hazard assessment is performed through a written certification identifying the workplace evaluated; the person certifying that the evaluation is performed; the date(s) of the hazard assessment; and that which identifies the document as a certification of hazard assessment.
In completing and documenting a PPE hazard assessment, you will identify under which conditions you expect your personnel to be exposed to heat, flame, fire, and hazardous materials as more of a direct hazard than exposure to moving traffic. You will also clarify and document which operations should require high-visibility garments for your personnel. Perform any operations involving fire attack from inside the protected safe zone established by properly positioned fire apparatus.
Remember that all this talk about roadway incident safety is not just about high-visibility vests. Evaluate your department’s other roadway incident safety elements to make certain you are taking all possible precautions to protect your personnel at every roadway incident. Drivers are more distracted than ever out on the roadways and, unfortunately, the hits involving our personnel and apparatus just keep on coming.
ENDNOTES
1. www.bls.gov/news.release/history/cfoi_08102006.txt.
2. www.cdc.gov/niosh/docs/2001-143.
3. www.respondersafety.com.
4. www.nfpa.org.
5. http://mutcd.fhwa.dot.gov/HTM/2009/part6/part6i.htm.
6. http://tinyurl.com/yzz4js.
7. http://tinyurl.com/7s5dbw.
8. www.safetyequipment.org/c/highvis.cfm.
9. http://bit.ly/6uD3p2.
10. www.respondersafety.com/Training/Downloads.aspx.
11. http://tinyurl.com/5oz8nk.
12. http://tinyurl.com/9hsd8l.
13. http://edocket.access.gpo.gov/2008/E8-27671.htm.
14. http://mutcd.fhwa.dot.gov/htm/2009/part6/part6d.htm#section6D03.
15. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9777.
JACK SULLIVAN, CSP, CFPS, is the director of training for the Emergency Responder Safety Institute and a retired lieutenant and safety officer of Lionville (PA) Fire-Rescue. He works to protect firefighters and other emergency responders at roadway incidents through the International Association of Fire Chiefs—Safety, Health, & Survival Section; the National Coalition; and the National Committee on Uniform Traffic Control Devices.
