—OSHA Briefing Paper—
Citations for U.S. Forest Service
|Name *||Position for Cramer Fire||Normal USFS Position|
|Bates, Patty||District Ranger, involved with other fires on other Ranger District||District Ranger, both the North Fork RD and the Middle Fork RD|
|Fogel, Dennis||Rappel Spotter for H-2. Cove Creek Helibase Manager||Assistant Helitack Foreman, Indianola Helibase, North Fork RD|
|Hackett, Alan||Incident Commander, Type 3. July 21 a.m. to July 22 after fatalities.||Assistant District Fire Management Officer (ADFMO), North Fork RD|
|Hafenfeld, Rick||Forest-wide Operations Staff Officer||Supervisors Office|
|Hand, Heath||Strike Team Leader, Over ground crews near H-1 and Cramer Creek||Acting Helicopter Foreman, Moyer Helibase, Salmon-Cobalt RD|
|Mills, Gary||Forest-wide Fire Management Officer (FMO)||Supervisors Office|
|Raddatz, Ray||Helispot-1 Manager, July 22
IC Type 4 Trainee July 20
|Helitack Crew Member/Rappeller, Moyer Helibase, Salmon-Cobalt RD|
|Sever, Paul||Manager, Central Idaho Dispatch (CID) and Logistics Coordinator / Warehouse Manager|
|Shaddle, Matt||Cove Creek Asst. Helibase Manager, July 22
IC Type 4, July 20 to July 21 a.m.
|Crew Leader, Moyer Helitack
Moyer Helibase, Salmon-Cobalt RD
Federal agencies, including the U.S. Forest Service, under section 19 of the OSH Act and Executive Order 12196, are required to follow 29 CFR Part 1960 - Elements for Federal Employee Occupational Safety and Health Programs. Many of the issues regarding safety inspections other adequate safety resources are addressed in Part 1960.
OSHA does not have specific standards addressing wildland firefighting safety and must address most aspects of fire safety under the general duty clause paragraph 29 CFR 1960.8(a) "to furnish each employee employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm."
The National Wildfire Coordinating Group (NWCG), the Federal Fire Leadership Team (FFLT), as well as each respective firefighting agency frequently propose, revise and issue their own guidelines and policies for firefighting.
Fire safety for federal firefighting agencies, such as the Forest Service, Bureau of Land Management (BLM) and National Park Service (NPS), and Fish and Wildlife Service (FWS) is detailed in several documents including, but not limited to:
The Interagency Standards for Fire and Fire Aviation Operations
(Also commonly referred to as the "Red Book" or "Fireline Handbook")
The Incident Response Pocket Guide (NWCG, NFES 1077, PMS
The Forest Service also has many of its own documents relating to safety which include:
National Headquarters Forest Service Manual (FSM) 5100-
Fire Management Chapter 5130-Wildland Fire Suppression, Interim Directive
2130-2003-3, Effective April 24, 2003, Expires October 24,2004
Covers requirements under the Thirtymile Hazard Abatement Plan
- The Forest Service Health and Safety Code Handbook (FSH
U.S. Forest Service Fire & Aviation Management Wildfire Safety Homepage
The hazards associated with wildland firefighting are well known. In 1910 in North Idaho, 72 federal firefighters were killed from a burnover. In 1957 the Ten Standard Fire Orders were developed by a task force studying ways to prevent firefighter injuries and fatalities. Shortly after the Standard Fire Orders were incorporated into firefighter training, a list of Watch Out Situations was developed. There are currently 18 Situations that Shout Watch Out identified. The Ten Standard Orders are never to be violated. The Watch Out situations are more specific and cautionary than the Standard Fire Orders and may be present, but must be mitigated to ensure fire safety. These Orders and Watch Outs are considered core 'principles of firefighting safety. (NIFC website, www.nifc.gov/safety_study/10-18-lces.html )
A Forest Service study on wildland firefighter entrapments, including Federal, State and rural firefighters, found from 1976 to 1999 that 28 different fire entrapment incidents occurred resulting in 105 burnover fatalities. In that same period, 240 different entrapments were reported involving 1,692 firefighters. Note: These were statistics were compiled before the Thirtymile and Cramer fires, each resulting in multiple fatalities.
It is believed by safety experts that for every serious accident, many more near misses and even more unsafe conditions go unreported. Based upon the number of fatalities and entrapments, the Forest Service report estimated approximately 23,000 unsafe conditions occurred on wildland fires between 1976 and 1999 (Wildland Firefighter Entrapments, 1976 to 1999, October 2000).
The Salmon-Challis NF has a history of known entrapments and shelter deployments from three other fires in the Forest. Two shelter deployments with one fatality on the Ship Island Fire in 1979. 82 shelters were deployed with no fatalities on the Lake Mountain Fire in July 1985. Also in July 1985, there were 73 deployments with zero fatalities on the Butte Fire (Records SCNF Fire management Plan (FMP), MTDC Investigation, NIFC website www.nifc.gov/reports).
To date, OSHA has conducted over 300 inspections of the Forest Service nationwide. Related to firefighter entrapments within the past 10 years, Notices of Unsafe or Unhealthy Working Conditions were issued to the Forest Service for two very similar high-profile fatality investigations. Most recently, notices were issued in the state of Washington involving the deaths of four firefighters in the Thirtymile Fire (#303757231). Prior to the Thirtymile Fire, notices were issued in Colorado involving the deaths of 14 firefighters (5 BLM and 9 USFS) in the South Canyon Fire (a.k.a. 'Storm King') (#116185406). The conditions, circumstances, findings, causal factors, and violations issued in these two fatality investigations were extraordinarily similar and in many respects compare very closely to conditions found surrounding these fatalities on the Cramer Fire.
The South Canyon Fire in 1994 brought to national attention many of the longstanding problems with wildland firefighter safety including the core problem that basic firefighting rules were not followed on an almost routine basis.
Willful violations issued from OSHA's Denver, CO Office to the Chief of the Forest Service and Director of the Bureau of Land Management included:
In addition, serious violations included:
In response to the South Canyon Fire, the main firefighting agencies including the Forest Service chartered a study to identify and change aspects of the underlying organizational culture that negatively impact firefighter safety. The TriData Report of March 1998 identified the lack of safety accountability as the major factor in need of change. Six suggested strategies for implementation of safety accountability were as follows: (1) A policy of removing safety violators from the job; (2) Follow Up on reported safety infractions; (3) Consider safety performance In performance reviews and promotions; (4) Add training accountability; (5) Include accountability in operational guidelines; (6) Provide guidelines for accountability.
Seven fire seasons later, the fatalities from Thirtymile Fire in 2001 revealed that many of the core safety policies and procedures continued to be disregarded and that serious unnecessary risks were still considered to be simply a part of firefighting. A system of accountability was still lacking within the Forest Service.
Willful violations issued from OSHA's Bellevue, WA Office to the Forest's Regional Office included:
In addition, serious violations included:
As one learns about each of these three fires, South Canyon, Thirtymile and Cramer, the similarities between conditions, violations of safety rules, and failures of management and accountability become readily apparent.
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