Public Comment No. 3-NFPA [ Chapter 7 ]
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- Millicent Matthews
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1 Page 1 of 8 Public Comment No. 3-NFPA [ Chapter 7 ] Chapter 7 ARFF Personnel Safety and Safety Management 7.1 Scope. This chapter identifies the knowledge and skills necessary to ensure ARFF personnel safety. 7.2 Competency. To reduce the risk associated with ARFF operations, ARFF personnel shall have in-depth knowledge of the exposure to the hazards associated with their occupation through training and testing of their knowledge and skills. 7.3 Criteria. ARFF personnel shall possess the knowledge to describe the following as each relates to the prevention of accidents or injuries: (1) Common fireground accidents (2) Causes of injuries in specific incidents (3) Correct lifting and equipment-handling techniques (4) Falls and tripping (5) Dangers associated with striking stationary or moving objects (6) Hazards in the presence of aircraft (7) Overexertion and other physiological factors (8) Correct donning and wearing of AHJ-approved protective clothing and equipment and their limitations (9) Correct mounting, dismounting, and riding types of apparatus (10) Basic driving (11) Behavioral health and wellness programs (12) Water rescue operations (13) Correct use of tools and equipment (14) Working from heights associated with ARFF fire- fighting New: ARFF personnel shall possess the knowledge to describe the following responsibilities towards their airport Safety Management System (1) Preliminary Risk Analysis (monitoring) (2) Evaluation of risks (3) Reporting responsibilities (4) Risk control methods (5) Implementation of control methods Statement of Problem and Substantiation for Public Comment ARFF is an integral part of the airports, ARFF members need the basic training to contribute to the overall airport responsibilities
2 Page 2 of 8 Submitter Information Verification Submitter Full Name: BERNARD VALOIS Organization: AUTOPYRO Street Address: City: State: Zip: Submittal Date: Tue Nov 12 12:01:28 EST 2013 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-2-NFPA Statement: ARFF personnel are an integral part of the overall airport safety program and need to understand their role in the process. The committee has also developed the associated annex material that has been attached to this.
3 Page 3 of 8 Public Comment No. 4-NFPA [ Chapter 12 ] Chapter 12 Extinguishing Agents 12.1 Scope. This chapter identifies the knowledge and skills required for ARFF personnel relative to the correct selection and application of extinguishing agents to be used on fires involving aircraft Selection and Application. Given all the extinguishing agents used at the airport, ARFF personnel shall be able to describe the choice and application for the following types of fires: (1) Aviation gasoline (AvGas) (2) Jet fuel (3) Interior aircraft combustibles (4) Magnesium (5) Electrically energized (6) Composite materials (7) Engine (8) Cargo (9) Wheel fires (10) Avionics bay (11) Auxiliary power unit (APU) 12.3 Descriptions of Effects. Given all the extinguishing agents used at the airport, ARFF personnel shall be able to describe the effects of agent application when the following conditions exist: (1) Wind (2) Rain (3) Freezing weather (4) Use of more than one agent (compatibility) (5) Fuel-soaked sod and flowing fuel or pressurized fuel New 12.3 Description of environemental effects ARFF personel shall be able to describe the environmental mitigation required during and after the application of agents in use at their airport. Statement of Problem and Substantiation for Public Comment The standard does not include training on the understanding of critical environmental limitations associated with the utilization of some agents. Basic understanding of the risks for the environment will contribute in a smarter usage of products. Submitter Information Verification
4 Page 4 of 8 Submitter Full Name: BERNARD VALOIS Organization: AUTOPYRO Street Address: City: State: Zip: Submittal Date: Tue Nov 12 12:18:19 EST 2013 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-1-NFPA Statement: The standard does not include training on the understanding of critical environmental limitations associated with the utilization of some agents. Basic understanding of the risks for the environment will contribute in a smarter usage of products. While the committee agrees with the submitters comment, the committee believes that the text they have developed accomplishes what the submitter was attempting to do.
5 Page 5 of 8 Public Comment No. 2-NFPA [ Section No ] 14.2 Criteria. Each ARFF personnel shall be able to involved in quaterly practical exercises involving simulated aircraft accidents with full deployment of their airport ARFFvehicle(s). In addition to the response training, these regular exercises shall be developped to test command of persons assigned command roles. The simulations scenarios shall include a debreifing to enable responders to describe how each of the following items affects an emergency response: (1) Nature of the emergency (2) Type of aircraft (3) Number of passengers and crew (4) Amount of fuel on board (5) Location of the accident (6) Nature and location of cargo (7) Wind direction and velocity (8) Weather conditions and terrain (9) ARFF vehicle status (10) Time of day or night Statement of Problem and Substantiation for Public Comment Due to the difficulty for some airports to provide on-site hot fire drills with their own equipment, putting more emphasis on regular simulated response using site specific equipment will contribute greatly in improving all elements of the response operation. Submitter Information Verification Submitter Full Name: BERNARD VALOIS Organization: AUTOPYRO Street Address: City: State: Zip: Submittal Date: Tue Nov 12 11:40:08 EST 2013 Committee Statement
6 Page 6 of 8 Committee Action: Resolution: Rejected but held The committee has chosen to reject but hold this public comment as it introduces new material that the committee can't tie it back to material that was addressed in public input and first draft portion of the revision cycle. The committee would like to see this held for the next edition so they can address it at that time.
7 Page 7 of 8 Public Comment No. 1-NFPA [ Sections 15.1, 15.2, 15.3 ] Sections 15.1, 15.2, Scope. This chapter identifies the recurrent live fire training required * Competency. ARFF personnel shall be subjected to live fire training This drill shall include a pit fire with an aircraft mock-up or similar device, using enough fuel to provide a fire intensity that simulates realistic fire-fighting conditions to simulate a type of fire that could be encountered on an air carrier aircraft at an airport Criteria. During the drill the ARFF personnel shall meet the training requirements defined in the following: (1) * The control and extinguishment of a simulated aircraft fire using handlines and/or turrets from an ARFF vehicle using both primary and secondary agents (2) Using fire streams to protect fire fighters and aircraft occupants, using an ARFF vehicle (3) ARFF personnel shall be able to attack a simulated fire in the interior of an aircraft while operating as a member of a team and given a team, PPE, an assignment, a fire-fighting vehicle handline, an extinguishing agent, and a ladder or other means of accessing the aircraft to satisfy the following: (4) Team integrity is maintained. (5) The attack line is deployed for advancement. (6) Ladders or other means are used. (7) Access is gained into the fire area. (8) Effective agent application practices are used. (9) The fire is approached. (10) Attack techniques facilitate suppression given the level of the fire. (11) Hidden fires are located and controlled. (12) Hazards are avoided or managed. (13) The fire is brought under control. Additional Proposed Changes
8 Page 8 of 8 File Name Description Approved 405_live_fire_training.doc Ch 15 as proposed by the Task Group of the Technical Committee formed at the last meeting of the committee Statement of Problem and Substantiation for Public Comment Revision of Chapter 15 proposed by the Task Group of the ARFF Technical Committee. Submitter Information Verification Submitter Full Name: John Maddox Organization: Lakeland Fire Department Street Address: City: State: Zip: Submittal Date: Tue Sep 10 12:11:11 EDT 2013 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-5-NFPA Statement: The coommittee has chosen to use the attached text for Chapter 15, which includes associated annex text and a new table to be placed in annex A, as they believe this text meets the requirements for recurrent training for live fire training.
9 15.1* Live fire spill training shall utilize hydrocarbon based fires. A15.1 Federal, state, or local restrictions may prohibit or restrict the use of hydrocarbon based fires for training. In these circumstances, the AHJ may substitute simulated aircraft fire trainer (SAFT) props utilizing propane or a combination system utilizing both propane and hydrocarbon fuels ARFF personnel, when conducting live fire spill training, shall utilized the minimum burn area based on airport category listed below Airport Rectangular Burn Category Area X 64 ft (26 X 20m) x 77 ft (31 X 23m) x 89 ft. (36 x 27m) x104 ft. (42 x 32m) 9, x 116 ft, (47 x 35m) Circular burn area Diameter ft. (m) 84 (26) 101 (31) 116 (35) 136 (41) 152 (46) ARFF personnel shall demonstrate, individually and as teams, their ability to control and extinguish spill fires associated with aircraft accidents. The following shall be done annually ARFF personnel shall extinguish an aircraft fuel spill fire utilizing the appropriate sized burn area, given PPE, an assignment, an ARFF vehicle hand line flowing a minimum of 95 gpm (359 L/min) of ARFF extinguishing agent, so that the agent is applied using the proper techniques and the fire is completely extinguished.
10 ARFF personnel shall be able to extinguish an aircraft fuel spill fire utilizing the appropriate sized burn area, given PPE, an ARFF vehicle turret, and a fire sized to the ARFF category, so that the agent is applied using the proper technique and the fire is completely extinguished The following live fire training shall use hydrocarbon, simulated aircraft fire trainer (SAFT) utilizing propane, or a combination of both ARFF personnel shall demonstrate, individually and as teams, their ability to control and extinguish fires associated with aircraft accidents. The following shall be done every two years ARFF personnel shall be able to extinguish a live fire, given appropriate PPE, a hand line flowing the proper extinguishing agen,t and simulating at least two of the following five aircraft emergencies: 1. Interior fire 2. APU fire 3. Engine fire 4. Wheel well fire 5. E&E compartment fire ARFF personnel shall be able to extinguish a three-dimensional aircraft fuel fire, given PPE, an assignment, using dry chemical agent, so that the agent is applied using the proper technique, the fuel source is secured, and the fire is extinguished.
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