BY MICHAEL L. DONAHUE
Today’s fire investigators face increasingly dangerous environments and conditions while conducting fire scene investigations because of the widespread use of building materials and furnishings manufactured from plastics, foams, and polymers that may pose numerous short- and long-term health hazards. These synthetic materials represent fuel loads that produce highly toxic by-products of combustion that have the potential to cause personal injury, illness, and chronic occupational diseases unless personnel use effective protective measures. The safety and health of fire investigators are often taken for granted; many investigators incorrectly assume that by the time they arrive at a fire scene, the potential hazards are eliminated or diminished to the point where such hazards are no longer a concern.
Some investigators have been diagnosed with disabling and debilitating injuries and chronic illnesses such as various cancers that surfaced days, months, and years after investigations were concluded. Some occupational physicians believe that these conditions may result directly from fire scene exposures that occur while investigators are working. Firefighters working in similar environments routinely wear respiratory protection equipment to prevent exposure; however, most investigators seldom wear respiratory protection devices even though they often enter scenes during or shortly after overhaul is completed when toxic combustion by-products may still be present.
FIRE INVESTIGATOR HEALTH AND SAFETY NEGLECTED TOPIC
Fire investigator health and safety is one of the most neglected areas of funding, research, training, and education throughout the fire service and law enforcement community. The majority of training programs, workshops, and seminars sponsored by professional trade associations, educational institutions, and state and local organizations seldom include any safety and health-related topics.
National Fire Protection Association (NFPA) 921, Guide for Fire and Explosion Investigations, and NFPA 1033, Standard for Professional Qualifications for Fire Investigator, contain only limited information concerning the health and safety risks associated with fire scene investigations. In addition, these documents do not offer specific guidance for organizations to develop relevant standard operating procedures (SOPs) or training and education programs. Furthermore, they do not outline the elements necessary to implement comprehensive occupational safety and health programs for fire investigators that include medical surveillance and annual screening.
FIRE SCENE HAZARDS
Over the past decade, several studies of firefighter occupational safety and health hazards associated with fire scene overhaul were conducted in Canada, the United Kingdom, New Zealand, and the United States. They documented that most fire scenes contain numerous toxic by-products of combustion, several of which are known or suspected human carcinogens, such as acrolein, acrylonitrile, benzene, formaldehyde, and vinyl chloride. These studies also noted that exposure to these toxicological hazards may result in increased incidence of cancer of the lung, kidney, bladder, and liver.
In 1998, the Phoenix (AZ) Fire Department conducted a comprehensive air-monitoring study designed to characterize firefighter exposures during overhaul operations. The study concluded that numerous concentrations of toxic air contaminants present during fire overhaul exceeded occupational permissible exposure limits (PELs). The researchers found that without the use of respiratory protection, firefighters were overexposed to irritants, chemical asphyxiants, and carcinogens; therefore, respiratory protection is recommended during fire overhaul.1
ATF/NIOSH RESPIRATORY PROTECTION STUDY
In 1996, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) participated in a health hazard evaluation in conjunction with the National Institute for Occupational Safety and Health (NIOSH). The study focused on the respiratory hazards and potential health effects of conducting fire scene examinations and the adequacy of respiratory protection equipment. During the course of the evaluation, environmental monitoring was done during the investigation of five residential fires in the Washington metropolitan area, two actual fires and three “staged” fires. During the subsequent fire scene examinations, environmental samples were collected for total and respirable dust, metals, hydrogen cyanide, inorganic acids, aldehydes including formaldehyde, polycyclic aromatic hydrocarbons (PAHs), elemental carbon, and volatile organic compounds (VOCs).
The environmental monitoring results detected formaldehyde at concentrations that exceeded the NIOSH recommended exposure limit (REL). Low or trace concentrations of acetaldydehyde, acrolein, and furfural were also detected. NIOSH considers formaldehyde and acetaldehyde as potential occupational carcinogens and recommends that exposures be controlled. These substances are used in the manufacturing of upholstered fabrics and adhesives. Other toxic by-products of combustion identified in varying concentrations were acetone, acetic acid, ethyl acetate, isopropanol, styrene, benzene, toluene, xylene, styrene, phenol, and naphthalene. Several polycyclic aromatic hydrocarbons (which are suspected human carcinogens) were also detected. These included benz(a)anthracene, benzo(b)fluoranthene, and benzo(a)pyrene [which is a major constituent of cigarette (tobacco) smoke that has been linked to lung cancer].
The researchers concluded that fire investigator exposures to irritants cause acute effects and that exposure to carcinogens may lead to potential chronic effects. The environmental sampling results and observations made during the study indicated that the use of appropriate respiratory protection and mechanical ventilation equipment can reduce the potential for exposure. Several fire investigators present at the scene who did not wear respiratory protection experienced eye and respiratory irritation.
NIOSH RECOMMENDATIONS
As a result of the data collected and observations made during this study, NIOSH issued the following recommendations for future consideration:
- Establish policies that require investigators to wear appropriate respiratory protection when performing fire scene investigations. Since the use of self-contained breathing apparatus would not be practical during most fire scene investigations, the use of half-face, air-purifying respirators equipped with combination filter cartridges (high-efficiency particulate, VOCs, acid gases, and formaldehyde) or powered air-purifying respirators with the appropriate filter cartridges should be used. If half-face respirators are used, they should be used in conjunction with eye protection to help prevent eye irritation.
- Organizations should establish written respiratory protection programs for fire investigators and ensure that they comply with the requirements described in the OSHA Respiratory Protection Standard (29 CFR 1910.134).
- Whenever possible, mechanical ventilation equipment (e.g., positive-pressure fans) should be used to remove atmospheric contaminants from the areas where fire investigators are working. Altering the fire scene (removing windows, doors, and so on) to promote natural ventilation should also be considered when it would not compromise the integrity of the fire scene.
- Implement the use of other personal protective clothing. To reduce the potential for fire investigators to carry contaminants away from the scene (e.g., home, office, for example), disposable coveralls, boots, and gloves should be considered. If disposable items are not used, a contractor who is aware of the contamination potential should launder or dry clean potentially contaminated clothing. Investigators should also be familiar with the use of appropriate decontamination procedures for emergency responders.2 NFPA 1851, Standard on Selection, Care, and Maintenance of Structural Fire Fighting Protective Ensembles, provides specific guidance and recommendations concerning the decontamination of various types of personal protective clothing and equipment.
Note: NIOSH made this same recommendation in a similar study conducted in cooperation with the Massachusetts State Police Fire and Explosion Investigation Unit in 1999.
A copy of the ATF/NIOSH Health Hazard Evaluation (HETA 96-0171-2692) is available at http://www.firescenesafety.com/downloads.html.
HOW SERIOUS IS THE RISK FOR FIRE INVESTIGATORS?
The real question that has spawned debate and concern within the fire investigation community that remains to be answered is, Are investigators subject to the same increased incidence of heart disease, cancer, and other serious medical conditions as firefighters because of exposure to harmful atmospheric contaminants while performing their duties?
(2) The question that remains to be answered is whether fire investigators are subject to the same increased risks of heart disease and various types of cancer as firefighters.
Unfortunately, the answer at the moment is “no one really knows for sure” because there is little or no research being funded to determine the extent of the risk and if a causal link exists. If we step back and focus on this issue from a “common-sense” perspective, we can easily recognize that standing or crawling around fire scenes for several years, constantly being exposed to acrolein, benzene, formaldehyde, hydrogen chloride, and hydrogen cyanide may not be the most healthful or smartest thing to do.
OSHA REGULATIONS
All public and private sector employers have a responsibility to provide a “safe” workplace and to protect their employees from recognized hazards, as required under the General Duty Clause of the Occupational Safety and Health (OSH) Act of 1970. Most organizations are operating under the assumption that since the term “fire investigator” is not specifically mentioned in occupational safety and health regulations that their activities are not subject to OSHA scrutiny. This belief could not be further from the truth. In fact, investigators and their employers are expected to comply with all OSHA regulations, standards, and practices applicable to the tasks and activities conducted at their workplace, which most often will be at fire scenes. In addition, there have been a number of cases over the past several years in which OSHA has cited investigators (and their employers) for failure to comply with specific regulations such as the OSHA Respiratory Protection Standard (29 CFR 1910.134).
RESOURCES
There are few resources available that offer specific guidance to assist organizations in developing the necessary policies, procedures, and training/educational programs for investigators to comply with applicable federal, state, and local occupational safety and health requirements. The key to compliance with occupational safety and health regulations and the foundation of an organization’s standard operating procedures, policies, and employee training program is a comprehensive written Occupational Safety and Health Program based on NFPA 1500, Standard on Fire Department Occupational Safety and Health Program. Organizations that fail to comply with applicable safety and health regulations could be subject to civil and criminal penalties.
Federal, state, and local occupational safety and health regulations vary. Coverage depends on several factors, including the following: whether the state in which the investigators are employed is an “OSHA state plan state”; whether the investigators are employed by federal, state, or local agencies or are self-employed; and whether local safety and health legislation (ordinances) have been passed. A list of the OSHA state plan states and specific information concerning covered activities can be accessed at www.osha.gov/fso/osp/.
FIRE INVESTIGATOR OCCUPATIONAL SAFETY AND HEALTH PROGRAMS
The safety and health of fire investigators is a key issue that is slowly becoming a priority within some segments of the fire investigation community. However, many public and private organizations have failed to adequately address this issue by developing occupational safety and health programs, implementing mandatory medical surveillance programs, modifying their standard operating procedures, purchasing and issuing personal protective clothing and equipment to investigators, and conducting safety-related training and education programs.
OSHA has identified the following critical elements that have consistently proven successful in helping organizations reduce the incidence of occupational injuries, illnesses, and fatalities and that are necessary to develop and implement an effective fire investigator occupational safety and health program:
An effective fire investigator occupational safety and health program includes provisions for the systematic identification, evaluation, prevention, and control of general workplace hazards and less obvious hazards that may arise during on-site activities. Although compliance with specific federal, state, and local OSHA regulations is an important objective, an effective occupational safety and health program goes beyond legal requirements to address all foreseeable employee safety and health hazards. It seeks to prevent injuries, illnesses, exposures, and fatalities whether or not compliance is at issue. The extent to which the program is described in writing is less important than how effective it is in practice.
Investigators who respond to fire and explosion scenes must be appropriately trained in accordance with their duties and responsibilities based on their job performance requirements as set forth by their employer. All organizations should familiarize themselves with the applicable OSHA requirements that apply to the safety and health of personnel conducting fire scene investigations. Compliance with the applicable OSHA regulations is essential to ensure that organizations have the ability to safely conduct investigations into the origin and cause of incidents without the fear of receiving citations for violations of occupational safety and regulations.
The development and implementation of a comprehensive fire investigator occupational safety and health program, standard operating policies and procedures, and OSHA/NFPA-compliant training programs will serve to reduce the likelihood of serious injury and an organization’s susceptibility to criminal or civil penalties for noncompliance with federal and state safety and health regulations. Organizations need to realize that fire investigators may face some of the same hazards as firefighters, even though they usually enter fire scenes to conduct investigations after overhaul is completed. Therefore, investigators need to be properly trained, equipped, and protected to prevent potential injury, illness, and exposure from numerous physical, chemical, and toxic hazards.
Note: Additional health-related information on the hazards and short- and long-term health effects associated with firefighting can be obtained at http://toxnet.nlm.nih.gov. Information on investigator safety and health-related topics can be found in Safety and Health Guidelines for Fire and Explosion Investigators available from Fire Protection Publications (FPP)/International Fire Service Training Association (IFSTA). Copies may be obtained by contacting FPP/IFSTA at 1-800-654-4055 or through the Web at www.ifsta.org.
Endnotes
1. Bolstad-Johnson, Dawn M., et. al, Characterization of Firefighter Exposures During Fire Overhaul, Phoenix Fire Department/University of Arizona Prevention Center/Arizona State University, 1998.
2. Kinnes, Gregory M. and Gregg A. Hine, NIOSH Health Hazard Evaluation Report No. 96-0171-2692, Bureau of Alcohol, Tobacco and Firearms, Washington, D.C., May 1998.
MICHAEL L. DONAHUE, IAAI-CFI® is an International Association of Arson Investigators (IAAI) certified fire investigator (CFI) and a nationally certified hazardous materials technician. He has more than 20 years of experience in fire investigation, law enforcement, and occupational safety and health. He is an adjunct professor at Montgomery College in Rockville, Maryland, where he teaches courses in fire and arson investigation. He is the author of Safety and Health Guidelines for Fire and Explosion Investigators [Fire Protection Publications/International Fire Service Training Association (IFSTA)] and moderator of www.firescenesafety.com, a Web site dedicated to occupational safety and health-related issues for fire and explosion investigators.
