P2 ~ Conducting NFPA 1403-Compliant Live Burn Training in Acquired Structures

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Instructor in Charge. The two most recent NFPA 1403 standards define “Instructor in Charge” and “Instructor” identically, yet there is a difference.

NFPA 1403, 2007 edition, Section 3.3.13 and 2012 edition, Section 3.3.5:

“Instructor–An individual qualified as an instructor and designated by the authority having jurisdiction to deliver fire fighter training, who has the training and experience to supervise students during live fire training evolutions.”

NFPA 1403, 2007 edition, Section 3.3.13 and 2012 edition, Section 3.3.6:

“Instructor in Charge–An individual qualified as an instructor and designated by the authority having jurisdiction to be in charge of the live fire training evolution.”

However, in the 2007 edition, Annex E considers NFPA 1041, Standard on Fire Service Instructor Professional Qualifications, as a reference only, “not a part of the requirements.”

On the other hand, the 2012 edition states: “The instructor in charge SHALL have received training to meet the minimum job performance requirements for Fire Instructor I in NFPA 1041.”

Too often, we rate “certified” as more important than “qualified.” We’ve all worked with the individual who looks good on paper. Remember, now the instructor shall have received training to meet the requirements. It doesn’t require the merit badge so to speak. There are folks in the department who took the classes, learned the trade, but never got around to taking the test. Sometimes, they are more qualified than those who have the position. Those with the title should draw on those with the background and on-the-job training to help direct the live fire evolutions. Many of the experienced members may have already made the mistakes and, hopefully, learned from them. Their experience and institutional knowledge are invaluable.

The “certified vs. qualified” debate is of concern also for local and mutual-aid company responders. The standard requires that the students provide written documentation for the aforementioned job performance requirements if they did not receive their minimum prerequisite training from the AHJ providing the live burn training. Not being an attorney, I cannot speak to the efficacy of a student providing a document stating he has received the requisite training. Even when the student provides the document or the auditors find the requisite documentation, we will never be able to verify that the job performance requirements were not “pencil whipped.”

Certainly, we ensure the members of our own departments attending the live fire training have the requisite skills to participate in training we are hosting. One way to attempt due diligence for the mutual-aid companies whose training we are unsure of is to provide a number of sessions prior to burn day if the property owner grants access. You can offer a few evening or weekend training sessions at the property reviewing the essential job skills. Or, the drills could be dedicated to practicing the SCBA, hose handling, ladder, forcible entry, and search and rescue skills, for example. The student’s ability to roll a single 50-foot section of three-inch fire hose in a “double donut with shoulder loops” or demonstrating the operation of a 30-pound dry chemical, cartridge-operated fire extinguisher can probably take a back seat to climbing a ladder with hand tools to enter a window or ventilate the roof after refreshing the skills needed to throw a ladder for rescue vs. placing one for roof access. Make these the requirements for participation in the interior training.

Another lead-by-example behavior on live burns is the proper use of protective equipment. For training institutions with tightly controlled Class A burn buildings and who continue to use long coats and three-quarter boots or fire resistant pants and leather boots because of repeated heat stress concerns, that debate is set aside for the acquired structure evolutions, and NFPA compliant turnout clothing is used. Although my career started in three-quarter boots, long coats, and no hoods, riding tailboard on open cab engines, the incidence of fires for most has diminished since the 1970s, and “on-the-job training” has been reduced to false alarms and EMS. The list of PPE requirements and associated standards is the same for training as it is for responding. Training more often in live fire conditions with appropriate staffing and rehabilitation efforts is the key to safe response instead of using body parts such as ears and the back of an ungloved hand as temperature gauges.

Fuel Load

The fuel load is a big part of the standard. Even if we use straw and pallets, common combustibles with easily predictable fire behavior, the smoke is not “clean.” Instructors are often seen entering without masks in place to set and ignite the fire. Equally disturbing is their coming out after extinguishment with smoky conditions prevailing without masks on. The younger staff members may be impressed, but we all know doing this is bad practice.

When live burn training goes wrong, it is often for the same reasons that actual alarms become newsworthy—the lack of command and control. If the instructor in charge allows other instructors to freelance by adding to the fuel load that originally was agreed on, changing the objective of the drill after entering the building, or allowing an untrained individual to shadow during an evolution, students get the message that this is acceptable. Standard incident command training aside, NFPA 1403 requires the instructor in charge to ensure correct levels of safety, maintain a manageable span of control, provide rehabilitation and communication, and conduct personal accountability reports (PARs). When our instructional staff maintains the incident command system discipline, recognizes and corrects the training anomalies, keeps the machismo or egos in check, and maintains the discipline explained in each drill preplan and pre-drill briefing, the drills typically go extremely well.

NFPA 1403, Section 4.12, “Fuel Materials,” states: “Fuels that are utilized in live fire training evolutions shall only be wood products.” And the express prohibition of pressure-treated wood, rubber, plastic, polyurethane, foam, upholstered furniture—basically ALL the materials we used to leave in place or throw on the burn pile when we were too hot and tired to go out and get additional pallets or straw. Using chemically treated or pesticide-treated straw or hay is also forbidden in the standard. If you’re not sure of the burn characteristics of material found in or around the property, do not use them for fuel.

Although NFPA 1403, Section 4.12.3.1, states flammable or combustible liquids as defined in NFPA 30, Flammable and Combustible Liquids Code, shall not be used in live fire training evolutions, it does allow combustible liquid with a flash point under 100˚F for engineered fire training props. Rational thought might say when the training is over and the objective now is to burn the property down, this liquid might be an acceptable accelerant. Don’t use it! Why run the risk of inadvertent use of the liquid fuel during training? Instead, order enough dry straw to get the remaining wooden fuel load going at the end of the day. Know the difference among hay, straw, and silage. While providing a class at a well-known western safety symposium, I found the baled material provided was extremely dry but was cut in such small pieces that it would not stay in place in the burn sets long enough to ignite the pallets.

NFPA 1403, Section 4.12.5, addresses ignition and the acceptable methods for igniting the proper fuel load. The methods include “propane lighters, butane lighters, fusees (safety flares), kitchen type matches, and similar devices … if … removed immediately after ignition of the training fire.” My choice is five-minute-rated safety flares; they can be used one time and can be extinguished by grinding them out on the floor or ground.

The following is one of the most intriguing sections in NFPA 1403, Chapter 4: “Fuel materials shall be used only in the amounts necessary to create the desired fire size ….” We hear the students keep calling for “bigger and hotter.” The instructors keep flashing back to the good old days before “rules” and the stories the old guys tell of being lucky enough to come out without injury to themselves or their students.

Be careful. What we consider a fire of desirable size may be far more than the student considers a desirable size. The student’s sudden discomfort may turn to hoseline abandonment and a scramble to extinguish and account for retreating troops.

Another unacceptable tradition from the “how much fuel” debate is that many of us have purposefully “seasoned” our department-supplied PPE to give the appearance of a grizzled veteran by remaining in the room too long or standing up adding fuel to the pile. The disfiguration of the reflective trim on the coats, the deformed flip-down shields, and the completely melted and inoperable flashlight banded to the helmet SCREAM of experience as we exit the fire behavior lesson that went just a little too long—right? Seriously? Demonstrate that experience with safe behavior and proper care of your gear.

The key lies in NFPA 1403, Section 4.12.7: “The fuel load shall be limited to avoid conditions that could cause an uncontrolled flashover or backdraft.” Nothing says a flashover demonstration is prohibited. It needs to be set up in such a manner that students are observing from an exterior vantage point.

Since dry, untreated straw, hay, and pallets constitute the accepted fuel in an acquired structure, the key to realistic fires is in the method in which the fuel is configured. Too often, the fuel is stacked in the center of the room with the fuel load entirely within three feet of the floor. You must consider certain factors regardless of where the fire set is placed. Creating a platform in the corner of a room with the majority of fuel stacked above the three-foot level will produce a rolling fire throughout the room. Having the fuel set higher also minimizes the damage to the room. When the pallets are simply stacked or arranged on the floor in the middle, it takes a longer preburn phase to generate conditions of a flameover or rollover. This extended period from ignition to rollover tends to preheat other areas of the room such as the linoleum (if left in place), window, and door trim and often compromises the ceiling and intact windows. The premature failure of the ceiling or heat-driven window ventilation changes the fire dynamics and, often, the desired fire effect for training.

Pallets and straw set higher in the room allow the fuel to ignite more rapidly after the straw flashes and produce a volume of fire similar to a typical room-and-contents fire, without the uncontrollable contents. If set properly, the fuel left after extinguishment can often be used again after a short period of drying and the addition of more dry straw (photo 3).

Live Burn Training

When locating the fuel set, consider the following: the anticipated path of travel in the room and out; the proximity to windows, doors, and other preengineered openings; and the integrity of the wall and ceiling surfaces. Avoid placing a fire set next to the openings with decorative trim that essentially hide a rough opening where fire can travel. If the room configuration makes that fire set location unavoidable, when writing the objectives for a drill in that room, account for the necessary overhaul, the use of a thermal imaging camera, and extinguishment when the spaces are breached.

Exterior Preparations

Firefighters have died because buildings were inappropriately prepared. The National Institute for Occupational Safety and Health and Federal Emergency Management Agency reports remind us that two firefighters perished in a flashover because fuel was in the exit path and wall coverings were left intact. Three died as a result of a partial building collapse when improper fuel was ignited after vapors spread into voids in a balloon-frame, two-story home.

I was once trapped in a room above the training fire. Fast-moving heated gases caused the door to slam shut. The doorknob came off as I attempted egress. I escaped by kicking out the bottom panels of an old “Christian” door. For me, this clearly identified and reinforced the need to ensure secondary exit from upper floors as well as to “assess the selected fire room environment for factors that can affect the growth, development, and spread of fire.” (NFPA 1403, Section 4.12.8)

Some trainers consider NFPA 1403 standard requirements for preparation too daunting to undertake. Since, as noted previously, bread-and-butter fires are few and far between in many areas of the country, acquired structure live burn training has become very important. Dividing the process tasks into manageable categories makes them more easily handled.

Structure Condition. Begin with the condition of the structure. Consider factors such as structural instability, the presence of asbestos or other environmentally questionable materials, exposures that are too close, or the potential of a political or social hotbed of controversy for the department when evaluating an offer to use a property for training. Consider specifically the suitability of the house for live fire training. It must be able to support the load of firefighters, hoselines, fuel loads (which must be compliant), and accumulated water (photo 4).

Live Burn Training

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