1. DOE FIRE SAFETY WORKSHOP Argonne National Laboratory April 16-19, 2007

2. 2 Eau de Code: The Essence of National Fire Protection Codes and Standards Dennis Kubicki, P. E. Office of the Senior Advisor for Environment Safety & Health NNSA Headquarters (NA 3.6)

3. 3 Introduction Dennis Kubicki, Bill Boyce and Nicole Kidman were stranded on a remote desert island. After a couple of days pondering their fate, Nicole turns to the two men and says…

4. 4 DOE O 420.1B and 10 CFR Part 851 require compliance with NFPA Paragraph 3.a.(3) of Chapter II of DOE O 420.1B requires that contractors “meet or exceed …NFPA codes and standards…” Paragraph 2.(b) of Appendix A to 10 CFR Part 851 requires that contractors have a comprehensive fire safety program that includes “meeting applicable building codes and NFPA codes and standards”

5. 5 DOE Fire Safety and Emergency Response Implementation Guides The existing 1995 DOE Implementation Guide affirms the need to meet or exceed NFPA codes and standards. The (still pending) new DOE Fire Safety and Emergency Response Implementation Guide explicitly lists the governing NFPA codes and standards, including those for DOE Fire Departments and brigade.

6. 6 Yes. But… There are 161 specific NFPA codes and standards that are delineated in the Fire Safety and Emergency Response Implementation Guide as being applicable or “likely to be applicable to contractors” under the provisions of the Order and Rule. These 161 represent thousands of individual requirements.

7. 7 How should we assess compliance with NFPA? “Gap analyses” seem to have been the expectation in some DOE issued guidance on compliance with 10 CFR Part 851. “Line-by-line” code compliance reviews are explicitly discouraged in the DOE fire safety guide and in the answers to FAQs on Part 851 related to fire safety and emergency response.

8. 8 How DO we usually assess compliance with NFPA? By doing line-by-line reviews with the codes and standards in hand…….NOT! By having a sense of the fundamental principles and concepts in our consciousness, with the occasional use of the standards for clarification……LIKELY! But we all need routine reinforcement on the essential principles and practices.

9. 9 What are the “essentials?” Let’s consider a few NFPA standards… Take NFPA 1, “Uniform Fire Code,” 73 chapters, 531 pages Group exercise: What are some of the fundamentals of this code?

10. 10 NFPA 1 Fundamentals “Equivalency Concept” (I bet that wasn’t on your list.) Alternatives are OK when approved by the (DOE) AHJ. A comprehensive documented fire prevention program with defined goals, criteria, roles and responsibilities. Documented reviews of changes (new construction, occupancy) by a qualified individual (FPE, FD officer, FM).

11. 11 NFPA 1 (continued)… Multiple safeguards (defense-in-depth) to protect people, processes, facilities. (Documented) Identification and evaluation of hazards. Delineation of safeguards (active, passive, procedures, training) to mitigate the risk from these hazards.* *Sub-tier essentials

12. 12 NFPA 1 (Sub-tier Essentials) Procedures to control combustibles Procedures to control ignition sources Fire-resistant construction Compartmentation (storage requirements, etc.) Fire (detection) and alarms Fire fighting equipment (Fire suppression systems) Training of workers, etc.

13. 13 NFPA 1 (continued)… IT&M of the safeguards Self assessments Interim safeguards (when problems occur) Abatement plans / corrective action plans Tracking system for violations

14. 14 NFPA 1 (continued) If a contractor’s approach satisfies all of these essentials, the degree of safety concern should diminish to “secondary” issues. (e.g. A contractor has flammable liquid storage containers and cabinets, but they are not all in good working condition.) Such secondary issues can be handled less rigorously, such as by a “punch list.”

15. 15 Let’s focus on an emergency services-related NFPA Standard. Consider NFPA 1500, “Fire Department Occupational Safety and Health Program” What are its essential requirements?

16. 16 NFPA 1500 “Equivalency Principle” in Paragraph 1.4.1 Written policies, program and procedures including a “Risk Management Plan.” A (written) training, education, and professional development program. Training should address the hazards from the full spectrum of responsibilities (Note Part 851 “pilot inspection” at ORNL.)

17. 17 NFPA 1500 (continued) An (safety-focused) inspection program for PPE, apparatus, equipment, including an inspection for hazards in FD structures. Code-complying PPE. Safety-conscious emergency operations. Incident management system Adequate communication Personnel accountability RIT

18. 18 NFPA 1500 (continued) Medical and Physical Performance FD Physician Medical exams (See NFPA 1582) Annual physical qualifications /fitness for duty Health and fitness program Member assistance and stress programs

19. 19 Consider the Life Safety Code About 275 pages of explicit criteria Thousands of individual requirements How would you characterize the essentials?

20. 20 NFPA 101 “E…. P…” (Paragraph 1.4.3) Two, remote, traversable means of egress Protected travel path Adequate illumination Exit signage Stuff addressed by other codes and standards (alarms, HVAC, etc.)

21. 21 The Feared 1710 Standard DOE has issued a one-and-one-half page “Implementation Plan.” So, the answer to the following question should be easy. What are the essential requirements of NFPA 1710, “Organization and Deployment of Fire Suppression Operations and Special Operations to the Public by Career Fire Departments?”

22. 22 NFPA 1710 Equivalency (Paragraph 1.3) DOE has stated that equivalency can be demonstrated in a reasonably comprehensive Baseline Needs Assessment or comparable document. Delivery objectives (including response times) for every service component. Arguably, this should be a DOE task.

23. 23 NFPA 1710 (continued) An annual self-assessment with a quadrennial report to DOE. (A self- assessment is also a requirement of 10 CFR Part 851.) A delineation of services. (A BNA will address this.) Note EMS treatment levels. Staffing to fulfill the responsibilities. (There will never be consensus on this issue.)

24. 24 NFPA 1710 (continued) Medical oversight / review (of EMS) Training that addresses the responsibilities Implementation of the Incident Command System An occupational safety and health program A dialogue leading to a “treaty” between the DOE and the fire department.

25. 25 Summary / Conclusions 10 CFR Part 851 and DOE O 420.1B require compliance with NFPA codes and standards. The spectrum of applicable requirements is too vast to expect literal, line-by-line conformance evaluations. Contractors and DOE should focus compliance efforts on the core concepts from each code or standard.

26. 26 Recommendation The DOE Fire Safety Committee and Fire Chiefs Committee should consider identifying the core principles and practices from the applicable NFPA codes and standards. (This effort, if managed efficaciously, should require only a few weeks of effort.)

27. 27 Questions? Dennis Kubicki, P.E. 301-903-4794 dennis.kubicki@nnsa.doe.gov

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