NFPA 1500 Compliance Audit

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NFPA 1500 Compliance Audit

• William Ruting, STA
• Emergency Planning Specialist
• Argonne National Laboratory

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Overview

• Rationale
• NFPA 1500
• Audit Process
• NFPA 1500 Deconstruction
• Assessment
• Findings
• Final Report

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Rationale

• 10 CFR Part 851, Worker Safety and Health
  Programs
• DOE Part 851 Rules require
• Compliance with NFPA 1500
• FDs to determine compliance
• Submit plan on achieving compliance
• DOE Orders 420.1 440.1

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10 CFR 481 Requirements

• This compliance includes meeting the
  applicable building code and National Fire
  Protection Association (NFPA) Codes and Standards
  or exceeding them, when necessary, to meet safety
  objectives, unless explicit written relief has
  been granted by DOE.

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Some Wiggle Room in 481!

• DOE agrees that any requirement that is not
  directly related to the safety and health of
  workers is not applicable in the context of this
  rule.

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Equivalencies

• DOE agrees in part and concludes that, beyond
  the definition of a formal exemption process to
  this rule, no explicit reference to
  equivalencies is necessary, as this concept is
  an integral part of all NFPA codes and standards
  and DOE fire safety directives.

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Which NFPA Codes?
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Thats 80 Codes Standards, not including cross
references.
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Other 10 CFR 481 Requirements

• Industrial Hygiene
• Biological Safety
• Occupational Medicine
• Motor Vehicle safety
• Electrical Safety
• Workplace Violence Prevention

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A. Subpart AGeneral ProvisionsSection
851.1Scope and Purpose

• to minimize the burden on contractors by
  clarifying that they need not establish redundant
  worker protection programs to protect workers
  from occupational safety and health hazards.

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Appendix AWorker Safety andHealth Functional
Areas 2. Fire Protection

• DOE agrees that a more pragmatic and less
  prescriptive approach to the delineation of
  requirements for fire protection and emergency
  services is appropriate. Consequently, the final
  rule has been revised to include the text from
  the fire protection portion of DOE Order 440.1A,
  which has been in effect since1998.

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Primary NFPA Standard

• NFPA 1500 Standard on Fire Department
  Occupational Safety and Health Program

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NFPA 1500

• First publication 1987
• Current version 2007
• Designed for public fire departments
• National Standard
• No regulatory force
• Used as legal exhibit

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Changes in 2007 Version

• Added protective ensembles for technical rescue
  and chemical/biological terrorism
• An updated section on risk management
• Revised and reorganized chapter on training and
  education
• Enhanced chapter on operating fire apparatus
• First-time sections on operations at traffic
  incidents, establishing control zones, and
  fitness for duty evaluations
• Added section on appointment of a health and
  safety officer

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1500 Overview
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Public Fire v. DOE Fire

• DOE primary coverage non-residential
• Predominance of fixed suppression systems
• Smaller total protected area
• Private roads quicker responses
• Fire experience lower
• Personal concern over fire losses

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DOE Considerations

• Unique facilities
• Extremely high value
• Irreplaceable
• Unique hazardous materials
• Radiologcial
• Non-Radiological
• Security concerns

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The 1500 Pound Taco

• Whole is greater than sum of parts
• More convoluted than the Mississippi River
• Is a moving target
• Was developed by a committee
• The camel is a horse designed by a committee

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This is ONLY 1500
and doesnt even include External references
such as ASTM, ANSI, etc.
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ANL 1500 Compliance Audit

• Completed in 2006

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Methodology

• Deconstruction of 1500
• 2002 Version
• 406 individual criteria
• Each criterion individually evaluated
• Interview with Chief Staff
• Review of Department Materials
• Policies, procedures, SOPs, Etc.
• Site-wide materials
• Personnel policies, safety rules

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Methodology, Continued

• Compliance level determined
• Full
• Comply With Intent
• Equivalencies
• Partial
• Non-Compliant
• Not Applicable
• Detailed description of compliance status

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Methodology, Continued

• Developed plan to improve or achieve compliance
• Date by which compliance could be achieved
• Projected costs for compliance
• Initial
• On-Going
• Exhibits
• Title of document
• Other supporting material

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Sample Form
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Assessing Results

• Numerical data
• Percent in each category
• Cost to achieve full compliance
• Non-Numerical
• Compliance issues
• Obstacles to compliance
• Other issues

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Final Report Contents

• Executive Summary
• Introduction
• Results by Section
• Discussion of Results
• Cost of Compliance
• Conclusions Recommendations

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Results

• 73.9 Full
• 8.9 Comply With Intent
• 4.2 Partial
• 3.4 Non-Compliant
• 9.6 Not Applicable

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Results By Chapter
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Compliance With Applicable
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Major Compliance Costs

• Annual testing of ground ladders
• Fire resistant uniforms
• Changes to communications center
• Traffic cones
• Fitness trainer certification
• Fitness program

Total Projected Cost Year 1 326,213
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Recommendations

• Develop a structured fitness program
• Annual testing of ground ladders
• FD respiratory protection program
• Develop additional written policies
• In-depth review of partial items

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