When it comes to compliance with OSHA 1915 Subpart “P” 1915.505 Fire Response, many shipyards believe that all they need to do is call 911 and the local fire department will handle the fire or rescue. However, this approach is not considered compliance.
Shipyard employers and safety managers must be prepared for the worst-case scenario and develop a written plan that will provide the appropriate firefighting and rescue strategies to prevent catastrophic loss.
So, shipyards must first decide what type of fire response is needed and who will provide it. Will the fire response be an in-house team, a local fire service provider, or a combination of both? What equipment will be needed? Who will have to be trained? Several more questions must be answered before a shipyard can effectively provide fire and rescue protection for its employees.
Requirements of In-House Fire Teams
In-house fire teams must be properly trained in tactical marine firefighting techniques, equipped with the proper firefighting gear and personal protective equipment, and perform regular firefighting drills to maintain their skills to ensure success when needed for emergency response. The internal team must also have enough members to effectively attack a fire or rescue within 15 minutes or less. During an emergency, time is the difference between life and death. All fire response employees must satisfactorily pass an annual medical examination to prove they are physically fit to handle the responsibilities of fighting a fire or performing a rescue. Additionally, the extinguishing equipment and personal protective equipment must be maintained in a state of readiness.
Using Outside Fire Response Resources
For most shipyards, having an internal fire team is extremely costly and hard to maintain. It also poses a greater risk of injury to employees conducting the firefighting that most shipyards are not willing to assume. Therefore, shipyards will often rely on the local fire departments as their fire response service. But even choosing an outside fire service provider has its challenges when trying to provide employee protection and meeting compliance requirements, since not all fire service providers are equipped to handle all the obstacles and challenges a shipyard emergency presents.
When choosing an outside fire response service provider, there are several elements that must be put into action. The first is establishing a strong liaison between the shipyard and the fire service provider to fully define the responsibilities of both organizations. The shipyards must still have a written plan that identifies the various types of fire and rescue emergencies that the fire service provider is capable of handling and the equipment that is readily available. The most critical element in the plan is the fire service provider’s response time which, as a general rule, should be no more than 15 minutes. If the response time is greater than 15 minutes, then the shipyard must have some form of modified response until the service providers arrives on scene.
Next, the fire service providers must have a full understanding on the layout of the employer's facility or worksite, including access routes to controlled areas, site-specific operations, number of employees, vessels or vessel sections, and hazards associated with the current emergency situation. They must also determine which equipment at the facility is available for use by the service provider and ensure its compatibility with the provider’s equipment.
Lastly, the two organizations must perform drills of the plan at least once per year to ensure the plan meets the expectations of both parties. All drills should include documentation of any deficiencies in the execution of the plan as well as changes needed to eliminate the deficiencies or improve the processes used to address the emergency. When changes are made to the plan, both organizations should retrain fire response participants on the changes.
More details on pre-emergency planning and preparation can be found in our blog post on working with outside response agencies.
A Hybrid Approach to Fire Response
The last option available to shipyards is the one used most frequently: a combination of both an internal team and an outside fire service provider. In this format, the two organizations develop a written plan establishing modified responsibilities to be performed by the internal team until the fire service providers arrives on scene. The internal team still must comply with the standards for having an internal team and both organizations must conduct joint training exercises as often as necessary to become proficient in their responsibilities when called to respond to an emergency. All training and drills must be documented and kept on file for regulatory verification.
Shipyards should take time to review their current fire response policy to ensure it is current and will be effective when asked to respond to the worst-case scenario. No shipyard ever wants to have a fire or rescue emergency but must prepared to handle one should one occur.
29 CFR Part 1915 - Occupational, Safety, and Health Standards for Shipyard Employment - Subpart P 1915.505 - Fire Response
ABOUT THE AUTHOR
Terry Guidry is a Senior Loss Control Manager with The American Equity Underwriters, Inc. Prior to joining AEU in 2010, he served as the Corporate Safety Director for a large shipyard with 12 locations. Terry is a certified Occupational Safety Specialist. He is the chairman of the Marine Chemist Qualification Board, as well as the Shipyard Representative on the Occupational Safety and Health Administration (OSHA) Negotiated Rule Making Committee for Subpart “P” Fire Protection for Shipyard Employment. He attended Nicholls State University, where he studied safety engineering.