Report of the Committee on

Fire Service Occupational Safety and Health

John A. Sharry, Chair Lawrence Livermore Nat'[ Laboratory, CA

Donald Aldridge, Lion Apparel Inc, OH Rep. Industrial Safety Equipment Assn.

Glenn P. Benarick, Fairfax County Fire & Rescue, VA Rep. NFPA Fire Service Section

Brenda Berkman, NewYork City Fire Dept., NY Rep. Women in the Fire Service

Allan Burnham, United Plastic Fab, Inc., MA Rep. Fire Apparatus Mfrs. Assoc.

DonaldJ. Burns, NewYork City Fire Dept., NY Edward Carter, Assn. of Fire Districts/State of NewYork, NY

Rep. Assn. of Fire Districts/St. of New York Dennis R. Childress, Buena Park Fire Dept., CA Boyd F. Cole, Underwriters Laboratories Inc., IL JDames M. Connolly, M & M Protection Consultants, IL

avid W. Dodson, Fire Dept. Safety Officers Assn., CO Rep. Fire Dept. Safety Officers Assn.

Philip J. Eckhardt, Mine Safety Appliances Co., PA Rep. Industrial Safety Equipment Assn.

Kenneth R. Ethridge, TX Commission on Fire Protection, TX Don R. Forrest, United Fire Fighters of LA City, CA Jerry H. Garrett, U.S. Air Force - Fire Protection Directorate, AE Curt T. Grieve, Florin Fire Protection District, CA

Rep. IAFC/Western Fire Chiefs Assn. GerardJ. Hoetmer, Int'l City Mgmt. Assn., DC Jonathan D. Kipp, Compensation Funds of New Hampshire, NH

J~0i. hn LeCuyer, Aurora Fire Dept., CO chard A. Marinucci, Farmington Hills Fire Dept., MI Rep. Int'l Assn. of Fire Chiefs

Gary Marrs, Oklahoma City Fire Dept., OK Rep. Int'l Fire Service Training Assn.

Robert T. McCarthy, U.S. Fire Administation, MD Roger A. McGary, Montgomery County Dept. of Fire & Rescue Services, MD

Rep. Int'l Society of Fire Service Instructors Robert D. Neamy, Los Angeles City Fire Dept., CA ' William E. Perdn, Montana Fire Training School, MT

Rep. Nat'l Assn of State Directors of Fire Training & Education Jack Ross, City of Calgary Fire Dept., Canada

ReD. Canadian Assn. of Fire Chiefs Nell Rossman, Rossman, Rossman & Eschelbacher, MA Arthur C. Smith, NY Board of Fire Underwriters, NY

Rep. Pmaeric~an Insurance Services Group, Inc Philip C. Stittleburg, Jenkins& Stittleburg, WI Rep. Nat'l Volunteer Fire Council

Michael V. Vance, Southwest Toxicology Services, Inc, AZ

Alternate

Jean Adams, U.S. Fire Administration, MD (Alt. to IL T. McCarthy)

Robert IC Andrews, M & M Protection Consultants, MI (Alt. toJ. M. ConnoUy)

Dee Armstrong, Fairfax County Fire/Rescue Service, VA (Alt. to B. Berkman)

Gary L. Briese, Int'l Assn. of Fire Chiefs, VA (Alt. to 1L A. Marinucci)

Angelo M. Catalano, NY State Assn. of Fire Districts, NY (Alt. to E. Carter)

Richard Gerkin, Jr., Good Samaritan Hospital, AZ (Alt. to D. Aldridge)

James C. Goodbread, ILS. Air Force, OK (?fit. toJ. H. Garrett)

Murrey E. Loflin, Virginia Beach Fire Dept., VA (Air. to G. P. Benarick)

Ron C. Miller, Fairbank, IA (Alt. to P. C. Stittleburg)

William E. Newcomb, North Safety Equipment, RI (Air. to P.J. Eckhart)

Rick Nichols, Pike Township Fire Dept., IN (Alt. toJ. LeCuyer)

Adam Dennis Piskura, Minnesota Technical College System, MN (Air. to W. E. Perrin)

BradleyJ. Schmidt, Underwriters Laboratories Inc., IL (Alt. to B. F. Cole)

Tony M. Varela, Los Angeles City Fire Dept., CA (Alt. to R. D. Neamy)

Staff Liaison: Stephen N. Foley

This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have oceLLrrec~

Committee Scope: This Committee shall have primary responsibil- ity for documents on the occupational safety in the working environment of the fire service; and safety in the proper use of apparatus, tools, equipment, protective clothing, and protective breathing apparatus.

This portion of the Technical Committee Report of the Committee on Fire Service Occupational Safety & Health is presented for adoption.

This Report on Comments was prepared by the Technical Committee on Fire Service Occupational Safety and Health and documents its action on the comments received on its Report on Proposals on NFPA 1583-1995, Recommended Practice for Fire Fighter Physical Performance Assessment as published in the Report on Proposals for the 1995 Annual Meeting and republished in this ROC.

This Report on Comments has been submitted to letter ballot of the Technical Committee on Fire Service Occupational Safety and Health, which consists of 30 voting members; of whom 19 voted affirmatively, 4 negatively (Ms Berkman and Messrs. Forrest, Grieve. Marinucci), 1 abstained (Mr. McCarthy), and 6 ballots were not returned (Cole, Ethridge, Marrs, McGary, Neamy and Ross).

Ms. Berkman voted negatively stating: "I have voted in the negative for several reasons. Despite consider-

able improvements made to the document in response to the public comments on the ROP, the document is not ready to be submitted to the NFPA membership for adoption as a recommended practice.

First, we are being asked to vote on an incomplete document for which we do not even have the final wording. There is no "Table 5- 8.3" printed on page 8. Nor are there any diagrams for Appendices C and D on pages 14. I believe that the committee should not adopt any document until they have the full and final wording of that document. This is especially important where, as with dais docu- ment, there has been so much reorganization and rewording of the texL

Secondly, mistakes have been made in the collating of the committee's actions on the comments that have resulted in sections being omitted or included in the final draft that should have been changed or omitted according to the committee's actions on the comments. Inconsistencies between the changes made in the draft document in March and the May 26 draft version presented include:

1. The order, the therefore the letter designation, of Appendices was changed at the March. meeting in Albu q uerque ..App.endix A is "Explanatory Material," changed from "Health and Fitness Program and Health and Fitness Coordinator," which becomes Appendix B. Section A-4-1 was relocated to Appendix C as described below.

2. Appendix C should be "Employment Test Validation." The May 26 version of the draft was omitted this section entirely. The agreed upon language for the section is: Appendix C Employment Test Validation Physical performance tests as they relate to employment decisions,

have rightfully become an important issue ff the fire service. Recent public laws, including the Americans with Disabilities Act of 1990 (ADA) and the Civil Rights Act of 1991 (CRA) are having a dramatic impact on employment for government and business. These laws directly affect the use of tests for employment decisions. A more complete discussion of test development and validation can be found in the Uniform Guidelines for Employee Selection, 29 CFR, Part 1608, Chapter XIV, which are frequently cited in employment law disputes as having taken on the force of law.

Because local conditions prevail, no physical performance assessment can be validated on a national basis, including those presented in dais recommended practice. Therefore, the anthority having jurisdiction should evaluate any proposed PPA in light of the Uniform Guidelines and applicable federal and state law.

The rest of this section was deleted.

137

NFPA 1583-- F95 ROC

3. "Sample Candidate Selection Process" was redesignated Appendix D, ra ther than Appendix C, as shown in the final draft version. Accordingly, "Sample Firefighters Annual Assessment Program" should be Appendix E. In the March draft, the "Original of Physical Per formance Tasks" (pages 15 and 16) was no t included as part of the "Sample Firefighters Assessment Program," as is shown in the May 26 version of the draft. W o m e n in the Fire Service submit ted a c o m m e n t ~ that specifically criticized the "typing example" that appears in the middle of page 15. WFS's c o m m e n t also crit iqued the idea expressed on page 15 tha t if more difficult tasks can be accomplished, then the less d e m a n d i n g tasks can be performed, correctly po in t ing out tha t the s ta tement is t rue only if the tasks are identical. C o m m e n t 64 was accepted by the commit tee in principle and the wording cri t iqued by that c o m m e n t should have been deleted. Yet, t he idea mysteriously reappears on page 15 us ing sligbtly different wording than t ha t cri t iqued by Log #64.

Perhaps even more importantly, o ther ideas repeatedly rejected by the commit tee on n u m e r o u s votes reappear on pages 15 a n d 16. The terms "critical," "ardous" and "essential" reappear on page 15, despite the fact that the commit tee voted to delete those terms when they appea red in the d o c u m e n t in Section 5 because the use of the terms were no t on all fours with the requ i rements a n d defini t ions of the EEOC Uni fo rm Guidel ines that selection procedures be representative o f " im por t an t aspects of pe r fo rmance on the job."

The commit tee emphatical ly states in file body of the Recom- m e n d e d Practice that each jur isdict ion mus t conduc t its own job task analysis (JTA), yet the language on pages 15 and 16 suggests such an analysis need no t be done because such a process is an ' expensive and laborious process." this suggest ion is in direct contradict ion to the empha t ic res ta tements in the body of the d o c u m e n t that a JTA mus t be done. Tile text tha t follows tha t suggest ion would be very confusion to any user of tbe d o c u m e n t us ing te rms like "Likert ranking," "operationalize these tasks across the spectrum," a n d other gobbledygook tha t the commit tee did no t even discuss because it was th rough to be deleted.

The mistakes in the draft that we are be ing asked to r e c o m m e n d for adopt ion by NFPA are significant errors in the edit ing process.

• Impor tan t changes e n u m e r a t e d above that go to the hear t of the commit tee ' s in tent were omit ted in file draft we are voting on.

This d o c u m e n t shou ld go back out for public c o m m e n t a n d fur ther improvemen t so tha t the spirit of the NFPA "process" as well as the letter of its s tandards-making law be met. The d o c u m e n t that we are being asked to approve is a very different d o c u m e n t f rom the one tha t the public was asked to c o m m e n t u p o n and fairness should dictate that the public be allowed to c o m m e n t u p o n this very different material.

Further, it was clear f rom the del iberat ions of the 1500 commit tee that its member s universally were interested in consider ing testing mechan i sms other than the Combat Challenge. Yet it was also clear, even f rom events that occurred in the course of the Albuquerque mee t ing when the "Gang of Five" (no t my expression) a t t empted to stifle any dissent, that the Task Group did no t permi t any o ther fitness or physical abilities options to be b rough t to the 1500 commit tee ' s at tention.

The original c o m m e n t process itself was deficient because at least 32 comment s criticizing the s tandard as a whole and the Combat Challenge specifically were rejected for failure to suggest alternative wording. Clearly, the commit tee is missing out on valuable inpu t by rejecting such commen t s out of hand. This is especially true because nowhere on the c o m m e n t form itself does it specify tha t the c o m m e n t submit ter mus t suggest alternative language or the c o m m e n t will be rejected. While technically we may be correct by rejecting those comments , I th ink the fire service would be better served if we offered t hem ano the r oppor tuni ty to suggest alternatives that are successfully being used to improve the fitness levels and physical abilities of fire fighters. We need to include more opt ions for considerat ion by the potential users of this R e c o m m e n d e d Practice in order for it to be a truly valuable document . For the

commit tee to reject the commen t s of the IAFF (Log #65) and file IAFC (Log #318) tha t more at tent ion be paid in this d o c u m e n t to fitness and health, and to the diverse needs of the fire service, is very reckless.

And finally, I believe that dais d o c u m e n t in its p resen t form is no t yet ready to be the "starting point" for America 's fire service. Al though a m u c h better d o c u m e n t than its earlier drafts, we mus t improve it fur ther before "put t ing it ou t on tile street" or we will be unfairly and illegally denying people the r ight to practice their profession. How have we answered the quest ion any reader of file d o c u m e n t will have: what happens to the i n c u m b e n t fire fighter who cannot "pass" tile PPA? We have not answered that quest ion in this draft. If we do no t answer that quest ion in the document , we will be answering it with a TIA or in a lawsuit. Let 's spend a little more t ime on "prevention" ( that unpopu l a r word) a n d we'll spend less t ime on "suppression." Let s take ano the r look at the docu- metaL"

Mr. Forrest voted negatively stating: "The proposed s tandard was significantly changed dur ing the

commit tee ' s last meet ing. I strongly urge that this d o c u m e n t be afforded addit ional public comment . I am voting in the negative on procedural g rounds since the d o c u m e n t tha t was sent to me was no t only incomplete, bu t in many areas, the text did no t reflect tile commit tee actions voted on dur ing the last meet ing. As impor tan t a d o c u m e n t that dais s tandard is for the fire service, it certainly merits proper review and completeness."

Mr. Grieve voted negatively stating: "I voted initially in the affirmative on tile premise that this

d o c u m e n t was a " r e c o m m e n d e d practice" a n d represen ted a start ing point for the fire service. After revisiting the process our commit tee adop ted by virtually rewriting a d o c u m e n t on the floor tha t is hardly recognizable f rom the draft submi t ted for public comment , I changed myvote . Based on the historical NFPA process, I believe this revised d o c u m e n t warrants going back th rough the public c o m m e n t process in an effort to insure that the commit tee forwards work tha t is both comple te and adheres to the process."

Mr. Marinucci voted negatively stating: "This d o c u m e n t was originally titled " R e c o m m e n d e d Practice for

Fire Fighter Physical Per formance and Condi t ioning Programs." This leads me to believe tha t the d o c u m e n t had a different directive t han is p resen ted in the final documenL The proposed recom- m e n d e d practice is primarily des igned as an entry level assessment program. Its major componen t s are no t des igned for overall heal th and safety of fire fighters. The d o c u m e n t does no t provide adequate help to fire depar tmen t s and may fur ther add confusion an d potential problems. It still does no t address the diverse needs of the

• fire service by offering adequate alternatives for a physical perfor- mance assessment program, t h o u g h its s tated purposes include physical fitness, hea th enhancemen t , and rehabilitation, there is inadequate direction on these areas.

The d o c u m e n t is significantly different t han the one distr ibuted for public comment . Inc luded in tile public comment s were many suggest ions to reject the entire document . These comm en t s were disregarded . . . . because there were "no suggested, wording changes." It Is unrealistic to t h m k that s o m e o n e who thinks file d o c u m e n t should be rejected would offer complete rewriting of the draft. Since there has been significant changes, the public should be given ano the r opportuni ty to comment . If this cur ren t draft is acceptable to the Technical Committee, I would sugges t tha t it be resubmit ted for public c o m m e n t to allow appropriate feedback on the document . "

Mr. McCarthy absta ined stating: "Voting policy u n d e r review."

138

:Nm'.A

NOI'l~-Sim~herevlaloaofNlqPAlfdk~ippedfromthe 1995 '

[ewe ff~z'vke ~ ' ~ f e t y attd Health

Lawrence Livermore N ~ l Laboratory, CA

Don d ,Lion OH Re D. Industrial Safety F~uipme'nt Assn. .

• Glenn P. Bemui©k, Fairfax Cnty Fire & Rescue, VA Rep. NFPA Hre Service Section r

Brenda lSerltman, New York City Fire DeDt., NY Rep. Women]n the Fire Service

Alidh j . ~omick, "IX Commission On Fire Protection, "IX DonaldJ. Burns, NewVork City Fire Dept., NY Edward Car~er, Assn. of Fire Districts/State of NewYork, NY

Rep. Assn. of Fire Districts/St. of NewYork Dennis It. Children, Buena Park Fire Dept., CA Bo~d F. Cole, Underwriters Laboratories Inc., IL

e, M. Comtolly~ M & M Protection Consultants, IL B. ffeitz, Br0okhaven Nat'i LaboratOry, NY

Rep. NTPA lndu~dal Fire Protection Section : David W. Dodson, Fwe DeDt. Safety Officers Assn., CO

Re D . Fire Dept. Safety Officers Assn. Phil]D J. Eekh~t,MAne Safety Appliances Co., PA Re D. I n ~ S~fety F~lulpment A~Isn.

J err;j,~. G ~ U.S: Ai¢ Force-Hre Prote~'on Directorate, AE ~ j . Hoeu~, tnt~ City ~ n ~ Arm., De Jonatlgah IZ Kipp, Compensatl6/~ Funds of New Hampshire, NH John LeCuye¢, A~rora' Hre . ~ p t , CO Richard A. Marlaucd, Farmington Hills Fire DeDt., MI

Re D. Intq Assn. of Fire Odefs Gray Marra, Oklahoma City Fire Dept., OK Re D. Int'l Fire Service Traildng A~n.

Robert T. MCCarthy, U~. Irtre Administation, MD " ' Roger A. McGary, Montgomery Coty Dept. of Fire & Rescue Services, MD.

Re D. int'l Society of Fire Service Insu-uctot~ Robert D. Neamy, Los Angeles City Fire Dept., CA Romeo Nod, City of Montreal Fwe Dept., Ganada

Re[~. Canadian Assn. of Fire Chiofs grdl]am g. Perrin, Montana Fire Training School, MT

Re D. Nat'l Assn of State Directors of Fire Training & Education Floyd L. ~ OR '

Pep. IAFC~,.estem F'u'e C131e~, Assn. _ , Nell Romma~ Rossman, Romman & Eschelbacher, MA Arthur ~ Smith, NY Board of Fire Underwriters, NY .

Pep. American Iflsurance ~ervicesGroup, Inc Phill D C. Stittleburg, Jenkins & Stittleburg, W1

Re D. Nat'l Volunteer Fire Council Michael V. Vaace, Southwest Toxicology Services, Inc, . ~

Alternate

Robert K. Andrews, M & M Protection Consultants, MI (Alt. toJ. M. Gonnolly)

Dee Armatrong, Fairfax Cnty Fire/Rescue ~ervice~ VA (Alt. to B~ Be~)

Gary L B ~ Int'l Assn. of Fire Chiefs, VA (Alt. to R. A..Marinucci) .

Aogelo M. Camalan0, NY State Assn. of Fire Districts, NY (AILto E. Carter)

James ~ Gauerke, Sawyer-Tower/Safetywear, OH (Alt. to D. Aldridge)

James C. Goo¢~yead, U~S. Air Force, OK (Alt. toJ. H. Ga~ett)

Murrey E. Loflln, Virginia Beach Fire Dept=, VA (Alt. to G. P. Benariek)

Ron C. MYller, Fairbank, IA (Alt. to P. C. Sfittieburg)

WlHiam E. Newcomb, North Safety Eqifipment, RI (Alt. to P. Eckhart)

Adam Demds Pidmra, Minnesota Tech/dcaJ College Sy~em, MN (Alt. to W. E- Perrin)

j ~ g o ~ aty of c~gary Fir~ nept, AT (AIr to IL Noel)

Gmdoa 1~. ~ U~q. l~n'e ~ o n , MD (Alt. to IL T. McCarthy)

Bradley J, Sehmldt, Underwriters ~ e s Inc.,,IL • -- : (AIt. to lB. F. Cole)

Tony M. Vm'ella, Los Angeles City Fire Dept., CA (Aft. to R. D. Neamy).

StatfLiaison: Stephen N. Foley

on titr~.ewt o f tbis a t i l i ~ Sincs that tirae, changss in tl~ m s m & n ~ - ~ur,]haeeoc~waL

Committee Scope: This Comn~ttee ~ have primary responsibil- ity for documenm on the occupational safety in the working environment of the fire service; and safety in the proper use of apDaratm, tools, equipment, protective clothing, and protective brcatking apparatus.

The 1 ~ of the Technical C~mmietee on lrtre Service OcSulm- tional Safety and Health is presented for adoption in 3 pal~"

Part l of this Report w~ prepared by the Tedmiud ~ m m ~ m e on Fire Service Occupaliomd Safety aml Health and p~_ olmses for -- adoption a ¢emplete revision to N I ~ p A I 5 6 1 - 1 @ 9 0 , . ~ oQ-l~e

h ~ k ~ ~ t S , y m e m L NrPA 1.~x.x990 is DuHished inVolunm 8 of the 1994 N a ~ n a l Fire Codes and in separate pamphlet form.

Part I of this Re]~rt has been submitted to letter ballot of the Technical Committee on lrtre Service O c e u ~ f f ' e t y and Health which comists of 29voting member& of whom 2*3 voted aflirm~atitady, and 4 ballots were not retumed(MemrS. Dietz, Childrest; Noel~ and Vance).

Part II of this Report was prepared by the Technical Committee on Fire Service Occupational Safety and Health and proposes for adoption a complete revision to NFPA 1581-1990, Standard on Fire Depm'tatent Infection Control ~ . NFPA 1581-1990 is Dublished in Volume 8 of the 1904 National Fire Codes and i n separam~pamphlet form.

Part H of litis Report has been submitted to letter ballot ofthe~ Teclmic.al Committee on. Fire Service Occupational &fie W mu l Health cOmtm of,29 voting memben; of whom 25 voted a t r m a - tively, aBd4 ballolz were not returned-(Mes~,.Dietz, Childress, Noel, arid V ~ e ) . - . "

Part m of this Report waspt_~_epared by the Tedmkal C~om~t~e on lrwe Sertk~ Oceol~thnml ~ , i y aml Health and p~po~es for adoptioo a new dochm~-nt NFPA~ 158~-1995, Reeommemted Prentice for Fire Fighter Ph~ical P e r f o ~ a m t C~mditiom~ Program~

Part Hi of this Report has been submitted to letter ballot of the Teclmical C~atmlttee on Fire Service Oceupmional Safety and Health consi~ of 29 voting members; of whom ~3 affirmatively, 2 negatively (Ms. Berk~aan and Mr. Marinucci), and 4 ballots were not returned (Messrs. Dietz, Childress, Noel, and Vance).

Ms. Berkman-voted negatively stating: "This "Recommended ]h~tice" needs more work before it should ~

be issued for public o~mn,mt The teconunended p r a n c e requires theme of the one ~test" of a private'for-profit firm and does not offer other (available) options for testing for needed abilities. The test faii~'to memu~e important flrefighting physical abilities ; including aerobic capacity. ~

Mr. Marinucci voted negatively stating~ ~The ii~ting~of m ~ one q~ecific ph~ical performance ~ummnent is

misieading and may imply that only one ~ t is be'm~ ' . recommended. O t h ~ alte.n~ttives need to be investigated.

159

NFPA 1 5 8 3 - - F95 RO C "

(Log #a) 1583- 1 - (1-2.4): Accept in Principle SUBblITrF~R: Leigh G. Hm~sen, Blue Cross & Blue Shield of New Hampshire RECOMMENDATION: Revise text as follows:

"Local level is defined a s . . . (whatever is the definition, city, country, etc.)" SUBSTANTIATION: Validated at the local level should be defined as to what is the local level, especially for very rural areas with small departments. COMMITrEE ACTION: Accept in Principle. COMMITTEE STATEMENT: The committee agrees with the context of the submitters proposal, and has included that as the "Authority Having Jurisdiction'. The committee uses the standard "Authority Having Jurisdiction" that is included in the definition section of the document. This could mean any level of goverment which has the responsibilityofenforcement.

(Log #14) 1583- 2 - (1-3): Reject SUBMITrER: Lelgh G. Hansen, Blue Cross & Blue Shield of New Hampshire RECOMMENDATION: Revise text as follows:

"Move Body Composition Determination to Sept. and Cardiovascu- lar conditioning to May. ~ . ' SUBSTANTIATION: By placing Body Composition before Cardiovascular conditioning, this implies one should diet first rather than start a conditioning program. A conditioning program should not only improve physical performance, but also address body composition, therefore education on conditioning should be placed first. COMMITTEE ACTION: Reject. The committee has rewritten this section.

COMMITTEE STATEMENT: The commilttee rewrote this section and the information is contained in Appendix A and is only presented as an example.

(Log #4) 1583- 3 - (1-4.2): Accept in Principle SUBMITrER: Leigh G. Hansen, Blue Cross & Blue Shield of New Hampshire RECOMMENDATION: Clarifywho signs medical release form. SUBSTANTIATION: Not clear as to who signs medical release form, candidate or physician. Is this defined in NFPA 1589? In the fitness industry, the physicians signs a medical clearance form.. I am assuming here that you mean the candidate signs. I have not read NFPA 1582 in a while. COMMI'I'rEE ACTION: Acceptin Principle. COMMITrEE STATEMENT: The committee agress with the submitter's proposal and added language to clarify the intent. The committee added langanage in 2-9.2, and 2-9.3 that also meets the specifics of the ADA requirements.

(Log #5) 1583- 4 - (1-5.3): Reject SUBMrITER: Leigh G. Hausen, Blue Cross & Blue Shield of New Hampshire RECOMMENDATION: Add:

(e) Working knowledge of exercise prescription and fitness conditioning programs. Revise: (c) Working knowledge of test protocol, physical fitness assessment

and administration. Add: (0

SUBSTANTIATION: This area is very weak in regard to minimum standards for the spedalist, especially if this person is a firefighter with minimal fitness knowledge and the department is not able to hire an exercise physiologist/specialist as a consultant. Knowledge of conditioning programs is not addressedand is an obvious outcome of the process. COMMrITEE ACTION: Reject. COMMITYEE STATEMENT: The committee rejected the submitter's proposal, and added Appendix A. The commiittee has rewritten Apopendix A and expanded it to address the submitters comments.

(Log #6) 1583-5- (3-2.1): Reject SUBMI~rER: Leigh G. Hamen, Blue Cross & Blue Shield of New Hampshire RECOMMENDATION: Revise textas follows:

"understands the test, "understands the risks inherent in the test, "can...." Add the word "informed" before consent form in the second

sentence. S ~ A N T I A T I O N : An informed consent must state the potential risks of the test, thus the candidate is informed.

Industry standards indicate that the consent form should be an "infqrmed" consent, outlining the risks which the candidate is assuming as his/her own. COMMITTEE ACTION: Reject. COMMFITEE STATEMENT: This section no longer addresses consent. The committee addresses the issue of consent in Section 2-9, and includes the waiver of liability. The committee does not feel informed consent is appropiate in this setting.

(Log #7) 1583- 6 - (3-3.4): Reject SUBMITrER: Leigh G. Hansen, Blue Cross & Blue Shield of New Hampshire RECOMMENDATION: Delete:

"general stretching." Insert: "should warm-up light aerobics activity followed by circular

movements to take each jo in t through its full range of motion." SUBSTANTIATION: Absolutely notl Stretching does not belong in a warm-up. One needs to "lube" up the joints through their full range of motion and increase body temperature 2-3 degrees to the point of light perspiration. Stretching implies static stretches which are not warm-up material! COMMITFEE ACTION: Reject. COMMITTEE STATEMENT: The committee removed references to stretching in the document. The committee has removed all references to stretching from the document.

(Log #8) 1583- 7 - (3-3.5): Reject SUBMITTER: Leigh G. Hansen, Blue Cross & Blue Shield of New Hampshire RECOMMENDATION: Delete: "near resting levels ~ Replace with: "at least below 100 beats per minute (BPM)"

SUBSTANTIATION: Near resting is too general. Standard fitness practice uses 100 BPM as tile minimum to be reached to end cool- down. Practical experience indicates that candidates need a specific BPM to achieve. COMMITTEE ACTION: Reject. COMMITI~E STATEMENT: The committee no longer addresses this issue in the document. The committee has removed this issue from the document.

(LogaO) 1583- 8 - (4-1.6): Accept in Priudple SUBMITTEl~ Leigh G. Hansen, Blue Cross & Blue Shield of New Hampshire RECOMMENDATION: Clarify who determines that progress has been made. SUBSTANTIATION: Not clear as to who determines if progress is made? COMMITTEE ACTION: Accept in Principle. See new text Section 4-1.6.

COMMIITEE STATEMENT: The committee agrees with the submitters proposals and has added text to clarify the section.

(Log #1) 1583- 9 - (6-3.2.1): Accept in Principle SUBMrVrER: Jeff Haas, MN Division of Forestry RECOMMENDATION: Add to existing text:

"The individual may strike the railroad tie as many times as necessary to drive it a total of 5 ft." SUBSTANTIATION: Present wording might be interpreted as requiring a single blow from the sledge hammer to move the tie 5 ft. COMMITTEE ACTION: Accept in Principle.

140

NFPA 1583~ F95 ROC

COMMITrEE STATEMENT: The committee changed the wording to indicate repetition. New wording is included in Sec 5-3.2.1. The committee agrees with the submitter, and has included this in a new section.

COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: The committee has addressed these issues in Chapter 5 of the document.

(Log #10) 1583- 10 - (A-l): Reject SUBMIT'rE]R: Leigh G. Hansen, Blue Gross & Blue Shield of New Hampshire RECOMMENDATION: In line 3, pg 52: delete "computerized".

In hne 14, pg. 52 define "RISKO". SUBSTANTIATION: Not everyone will have computerized results available (especially in NH) I Not everyone knows what RISKO is and there are a few different versions out there, some of which require medical input. COMMITrEE ACTION: Reject. COMMITrEE STATEMENT: The committee has addressed these issues in Chapter 5 of the document.

(Log #12) 1583- 11 - (Appendix B): Reject SUBMITTER: Leigh G. Hansen, Blue Gross & Blue Shield of New Hampshire RECOMMENDATION: Revised text as follows:

Insert" B. "Five minute USFS" step test. SUBSTANTIATION: There are many step tests and the USFS step test allows conversion to estimated VO2. I believe that is the only one which does. All other tests can convert to est VO2, also COMMITTEE ACTION: Reject. COMMrI~rEE STATEMENT: The committee has removed these references from the document.

(Log #15) 1583- 14 - (Appendix C): Reject SUBMIT'I~R: Leigh G. Hansen, Blue Gross & Blue Shield of New Hampshire RECOMMENDATION: None. SUBSTANTIATION: Line 2: What evolutions listed below?? COMMrI['rEE ACTION: Reject. The committee rejected this proposal.

COMMrI'rEE STATEMENT: This section no longer exsists, and has been removed by the committee.

(Log #2) 1583- 15 - (Entire Document): Reject SUBMITTER: DonaldJ. Burns, NewYork City Fire Department, NY RECOMMENDATION: Add new text:

NFPA 1583 Draft Standard SUBSTANTIATION: The draft standard, NFPA 1583, has been reviewed and found to be laudable in its goals, but substantially lacking in reality, i.e. It places all responsibility burdens on Fire Department management and none on employee. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The task group disagrees with the submitters comments, and feels there are several areas that address the responsibility of the individual The committee rejected the submitters comments, and references the responsibility of the individual in Sec 2-9,2-6.1, and 2-7.1.

(Log #11) 1583- 12 - (Appendix B-E): Reject SUBMITTER: Lelgh G. Hansen, Blue Cross & Blue Shield of New Hampshire RECOMMENDATION: Define 6 and 7. Like 4. SUBSTANTIATION: These acronyms mean nothing to me and as an Exercise Physiologist consultant to FDs, I feel these should be

elled out (As theysbould be in anytest with first use). MMITrEE ACTION: Reject.

COMMITI'EE STATEMENT: The committee has renmoved these references from the document.

(Log #13) 1583- 13 - (Appendix C)' Reject SUBMITTER: Leigh G. Hansen, Blue Cross & Blue Shield of New Hampshire RECOMMENDATION: Revised text as follows:

"emphasizing aerobic "and muscular conditioning, including flexibility training with training for deficiencies brought forth througb the evaluation process". SUBSTANTIATION: As much of the PPA was muscular in nature (with, of course, a strong cardiovascular component), emphasizing aerobic conditioning will not prepare a candidate to be successful with the PPA. Sug..gest rewording to give more "weight" to. those elements wluch will help them to pass the PPA. (Specificity of Training principle).

( Log #CP 1 ) 1583- 16 - (Entire Document): Accept SUBMITTER: Technical Committee on Fire Service Occupational Safety and Health, RECOMMENDATION: Adopt a new Recommended Practice NFPA 1583, Recommended Practice for Fire Fighter Physical Performance and Conditioning Programs. The text of the document is shown at the end of this report. SUBSTANTIATION: In 1987 the Techmcal Committee on Fire Department Occupational Health and Safety undertook a variety of

rojects to expand the umbrella of NFPA 1500, Standard on Fire epartment Occupational Safety and Health Programs. Beginning

in 1992 with the adoption of NFPA 1582, Medical Reqmrements for Fire Fighters the technical committee members looked at adding this document to the series of safety and health documents. A Task Group of content experts, along with committee members, worked over the past two years in developing this recommended practice It will become a valuable tool for the"AHJ" in developing physical performance and conditioning programs. COMMITrEE ACTION: Accept.

141

N F P A 1583 - - F95 R O C

NOTE: This portion o f the Report containes the Comments on the Report on Proposals that appears on the preceding pages regarding NFPA 1583.

(Log #167) 1583- 1 - (Entire Document): Reject SUBMITrER: Patr ida Doler, Local 1165 Santa Clara County Central Fire District COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: Review and revision of the entire text seems to be necessary before a r e c o m m e n d e d national s tandard is established. SUBSTANTIATION: 'Task or iented time completion tests do no t test the physical fitness of the new or incumbent candidates, therefore put t ing the individual at risk, as well as the depar tment at risk of liability, in addition, this type of test seems to favor taller, heavier individu'als without accurately assessing o ther traits (i.e., flexibility, aerobic capacity, and strength necessary for the position of fire fighter.) COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee hag carefully considered the many comments that suggested improve- ments to the documen t as published and has incorporated changes where it felt they s t rengthened the document . The committee discussed wilether it should withdraw the documen t from its cycle and start dyer and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title o f the documen t and file purpose have been refined to better reflect what the document covers.

(Log #168) 1585- 2 - (Entire Document): Reject SUBMITrER: Jane Wannan Edwards, Prince George's Co. Fire Dept. COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: The implementat ion of the proposed NFPA 1583 standard would have a t remendous impact on fire depar tments across the country. There is no question that there is a need for the fire service to focus on fire fighter fitness, however, I believe that the 1583 standard as it now standard is unreasonable. The requi rement of 14 METs (5-$A) to continuously perform the

job safely seems to be rather stringent, considering that a normal room and contents fire makes up a relatively low percentage of what fire fighters actually do on the job (less than 10 percent) . 1585 should be an oudine of the baseline fitness level that is needed to do thdjob, and the focus should be on the development of an entire wellness program th roughout a persons career. Perhal~s 1583 would be better if it were based on a total reflection of needs m all the sectors of the fire service including jobs involving persons involved in: hazardous materials, EMS, prevention, and so forth.

Should this regulation be so dependen t on performance times due to the fact that the test is admittedly no t a predictor o f j o b perfor- mance? Since safety is also stressed th roughout the document , should individuals be pu t in situations where they may push themselves past their limits? This is even more questionable in that we r ecommend that those who do not complete the Physical Performance Appraisal (PPA) successfully be restricted f rom fire suppression functions. Many depar tments do no t have "alternate d u t ~ positions available, and the result may be the loss of a job. This is another reason why the PPA must be made as reasonable as possible.

in my opinion, a fimess standards goal should be to keep fire fighters fit for their entire career. The result o f a well developed and well implemented program would include a heal thy work force with fewer injuries. To promote the idea of hiring from the top performer down seems to contradict the emphasis placed on safety. The persons hired, as a result o f such a process, may simply push themselves above and beyond their ability. Additionally, it seems to be unreasonable to suggest that a person that f inished 3rd will be a better employee than one who finishes 16th.

For these reasons, I believe that the s tandard needs to be 'revisited to develop a realistic and holistic approach to fitness in the fire service. SUBSTANTIATION: None. C O M M i T r F ~ ACTION: Reject. COMMITrEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the documen t as published and has incorporated changes where it felt t heys t reng thened the document . The committee discussed wilether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title o f the

document and the purpose have been refined to better reflect what the document covers.

(Log #169) 1585- 3 - (Entire Document): Reject SI..~MITYER: Cynthia L. Starr, Louisville Fire Deparmaent COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: Develop a program that would improve fire fighter effectiveness or form the basis for a positive, progressive, non- punitive approach to promoting health and fitness.

1. Focus on the t0tal health and well-being of all personnel. 2. Emphasize prevention and fitness programs, not the physical

performance assessment. 3. Replace the PPA tasks that fail to meet the stated criteria for task

selection. 4. Score the PPA on a pass/fail basis.

SUBSTANTIATION: 1. ".,.new and separate chapters on health enhancemen t and physical conditions would reinforce the impor- tance of positive health and fitness programs and help balance the documrnt ."

2. "The draft fails to consider the physical condit ion of the fire fighter foUowingthe test. Programs that use education and training to promote the benefi ts of health and fitness are unquestionably the preferred approach to maintaining a productive andeffect ive

-workforce. COMMITrEE ACTION: R~ect. COMMITTEE STATEMENT: The submitter has 'offered the committee no suggested wording changes. The committee has carefully COtlsidered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt they s t rengthened the document . The committee discussed whether it should withdraw the documen t from its cycle and start over and concluded that there was a need for the docu- men t and that it was suitable as revised. Note that the title of the documen t and the purpose have been refined to better reflect what the document covers.

( Log #178) 1583- 4 - (Entire Document): Reject SUBMIT~ER: Tori L.Jennings, Littleton Fire Depar tment COMMENT ON PROPOSALNO: 1583-16 RECOMMENDATION: None. SUBSTANTIATION: NFPA 1583 should no t be accepted in present form. Document is gender biased, height biased, age biased. This form of testing places individuals at substantial cardiac risk. There is too much emphasis on performance rather than wellness. It is clearly a conflict of interest for Paul Davis to have his test as an NFPA standard. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the documen t as published and has incorporated changes where it felt they s t rengthened the document . The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the tide of the documen t and tile purpose have been refined to better reflect what the document covers.

(Log #197,) 1583- 5 - (Entire Document): Reject SUBMITrER= Donald W. F u l l City of Lincoln Fire Dept., IL COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: I disagree with NFPA 1582 as written. SUBSTANTIATION: None. COMMITrEE ACTION: Reject. COMMITrEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt theys t reng thened the document . The-committee discussed whether it should withdraw the documen t from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the document covers.

142

NFPA 1583 m 1 0 5 RO C

(Log #194) 1583- 6- (Entire Document): Reject SUBMITI'ERa RobertJ. Washam, Local 3092 COMMENT ON PROPOSAL NO: 1583.16 RECOMMENDATION: I sWongly disagree with NFPA 1583 as it is written. SUBSTANTIATION: None. COMMITYEE ACTION: Reject. COMMrI"rEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt they strengthened the document. The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that itwas suitable as revised. Note that the title office document and the purpose have been refined to better reflect what the document covers.

(Log #198) 1583- 10 - (Entire Document): Reject SUBMITTER: Richard G. O'Hara, Lincoln Fire Dept., IL COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: 1 believe in physical fitness. However, I do not agree with 1583 as worded. SUBSTANTIATION: None. COMMI'I'TEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt they strengthened the document. The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the document covers.

(Log #195) 1583- 7 - (Entire Document): Reject S U B ~ Orville Lolling, Lincoln City Fire Dept., IL COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: I oppose the NFPA 1583 standard as it is currently written. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITI?EE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many conaments that suggested improve- merits to the document as published and has incorporated changes where it felt they strengthi.~ned the document. The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the document covers.

(Log #199) 1583- 11 - (Entire Document): Reject SUBMITTER: Roger L. Adams, Local ~Y32 COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: I oppose the NFPA standard 1583 as currently written. $UI~TANTIATION: None. COMMITTEE ACTION: Reject. CO MITrEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt they strengthened the document. The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the-document covers.

( Log #196) 1583- 8 - (Entire Document): Reject SUBI~TTER: Lester S MacLaughlin, JL MacI~ughlin & Co COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: I strongly disagree with NFPA standard 1583 as it is written. SUBSTANTIATION: None. COMMITFE~ ACTION: Reject. COMMITTEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt they strengthened the document. The committee discussed whether it should withdraw the document from its cycle and start over and concluded, that there was a need for the docu- ment and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the document covers.

(Log #200) 1583- 12 - (Entire Document): Reject SUBMITTER: Ken Molt, Fireflghters Local 3092 COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: I disagree with NFPAstandard 1583. SUBSTANTIATION: None. COMblrI'rEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated cbanges where it felt they strengthened the document. The committee discussed whether it should withdraw the document from its cycle and start over and conduded that there was a need for the docu- ment and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the document covers.

(Log #197) 1583- 9 - (Entire Document): Reject SUBMITTER: Tom Martin, City of Lincoln Fire Dept., IL COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: I strongly disagree with NFPA 1583, this needs to be changed. SUBSTANTIATION: None. COMMrVrEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt they strengthened the document. The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the document covers.

(Log #201) 1583- 13 - (Entire Document): Reject SL1BM/TrEFa Mark Visintine, Lincoln City Hre Dept., IL COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: I disagree with the NFPA standard 1583 as written. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITrEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt they strengthened the document. The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the tide of the document and the purpose have been refined to better reflect what the document covers.

145

NICPA 1583 1 F 9 5 R O C

(Log #202) 1583. 14- (Entire Document): Reject SUBMITTER: JeffSingleton, Lincoln Fire Dept.,IL COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: I strongly disagree with NFPA 1583. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the documen t as published and has incorporated changes where it felt they s t rengthened the document . The committee discussed whether it should withdraw the documen t from its cycle and start over and concluded that there was a need for the docu- men t and that i twas suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the document covers.

(Log #206) 1583. 18 - (Entire Document): Reject S U B ~ Steve Dahn, Lincoln Fire Dept., IL COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: I do not agree with many points that the NFPA 1583 has in it. SLrl~TANTIATION: None. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The submltter has offered the

, committee no suggested wording changes. The committee has carefully cons!dered the many comments that suggested improve- ments to the document as published and hfis incorporated changes where it felt they s t rengthened the document . The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- m e a t and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the documen t covers.

(Log #203) 1583- 15 - (Entire Document) : Reject S U B M I ~ Kenneth E. Ebelherr, Lincoln City Fire Dept., IL COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: I oppose the NFPA 1583 standard as it is currently written. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITrEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt they s t rengthened the document . The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the document covers.

(Log #207) 1583-19- (Entire Document): Reject SUBMITTER: Dallas Millard, Lincoln City F'tre Dept., IL COMMENT ON PROPOSAL NO: 1585-16 RECOMMENDATION: I do no t like the NFPA 1583 at all. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITrEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt they strengthei~ed the document . The committee discussed whether it should withdraw the documen t from its cycle and start over and concluded th~it there was a need for the docu- men t and that it wag suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the document covers.

(Log #204) 1583. 16 - (Entire Document) : Reject SUBMITTER: Don Cecil, Lincoln City F'we Dept., IL COMMENT ON PROPOSAL NO: 1583-16

RECOMMENDATION: I do not agree with NFPA 1583 standard. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The sulamitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- merits to the documen t as published and has incorporated changes where it felt they s t rengthened the document . The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title o f the document and the purpose have been refined to better reflect what the document covers.

(Log #208) 1583. 20 - (Entire Document): Reject SUBMITTER: Tom Cecil, Lincoln Fire Dept., IL

COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: I oppose the 1583 standard. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has offered tl~e committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- merits to the documen t as published and has incorporated changes where it felt they s t rengthened the document . The committee - discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the documen t covers.

(Log #205) 1583- 17- (Entire Document): Reject SUBMITTER: Don Buss, Lincoln Fire Dept., IL COMMENT ON PROPOSAL NO: 1583.16 RECOMMENDATION: I do no t agree with NFPA1583. SUBSTANTIATION: None. COMMITI?EE ACTION: Reject. COMMITrF.~ STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the documen t as published and has incorporated changes where it felt they s t rengthened the document . The committee discussed whether i t shou ld withdraw the documen t from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the document covers.

(Log #209) 1583- 21 - (Entire Document): Reject SUBMITTI~R: James L. DavisJr., Lincoln Fire Dept., 1L COMMENT ON PROPOSALNO: 1583.16 RECOMMENDATION: I believe that this is discriminating against the older fire fighters. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. C O M M I T r ~ STATEMENT: The submitter has offered the committee no suggested wording change~ The committee has \ carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt theys t reng thened the document . The committee discussed whether it should withdraw the documen t fi'om its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the documen t covers.

144

N F P A 1583 ~ F95 R O C

(Log #289) 1583- 22 - (Entire Document) : Reject SUBMITTER: P. Lamont Ewell, Oakland Fire Deparunent, CA COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: The draft does not focus on its primary goal - "Firefighter Performance and Longterm Health". As I interpret the draft standard, we would in effect be excluding many qualified candidates without having ever proven that the fastest time in each task directly correlates to being the "best" candidate(s). A more reasoned approach would be to de termine the minimum time necessary to achieve a given task, based on job requirements, and consider everything below that time as failing, and anything above as having successfully passed. Any other methods would clearly result in an adverse impact to many potential candidates. SUBSTANTIATION: None. COMMITI'EE ACTION: Reject. COMMITI'EE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- merits to die document as published and has incorporated changes where it felt they s t rengthened the document . The committee discussed whether it should w~thdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the document covers.

(Log #292) 1583- 23 - (Enure Document) . Reject SUBMITTER: Kathy Campbell, Oakland, CA COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: Revise text:

"Fire fighting is a strenuous and multi-facetedjob. It is necessary for depar tments to establish clearly defined minimum fitness standards. These standards should be met by entry level candidates and maintained by incumbent fire fighters. Departments should support their members in maintaining their health. The problem that I have with proposed 1583 is that al though "task" oriented", some of the events do not resemble what is actually done in the associated task, some of the events are dangerous to an individual's back a n d / o r cardiac function, endurance is neglected, strength is over emphasized and there are possible negative impacts on incumbent fire fighters There will definitely be an adverse impact on women competing in a rank ordered strength test against men. I also question the ethical implications of allowing a businessman that markets physical agility tests being allowed to have so much input into a national s tandard that encourages deparm~ents to purchase a

~ roduct that he produces." UBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITI'EE STATEMENT: The committee has carefully considered the many comments that suggested improvements to the documen t as published and has incorporated changes where it felt they s t rengthened the document . The committee discussed whether it should withdraw the document f rom its cycle and start over and concluded that there was a need for the document and that i twas suitable as revised. Note that the tide of the document and the purpose have been refined to better reflect what the document covers.

(Log #293) 1583- 24- (Entire Document) : Reject SUBMITTER: J o h n tL Scott, Aurora Fire Department , CO COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: I am a very enthusiastic p roponen t of physical fitness and very much appreciate the importance of physical condit ioning for Fire Fighters and i t s contributions to health, and safety in the industry. I am, however, opposed to the adopt ion of the Davis-Dotson "Combat Test" as a model physical performance assessment. My concerns are as follows:

1. This PPA is extremely stature exclusive. Due to heights in railings used in the hoisting event, small-statured fire fighters are at a t remendous disadvantage. In many cases small-staturedfire fighters must incorporate /develop dangerous techniques, causing fall hazards or injury hazards to overcome lack of leverage. I question the weight of the anatomically correct rescue prop. Again, this favors large-statnred fire fighters. Victim size on the f ireground cannot be predicted. As a 175 Ib fire fighter, I f ind the 165 lb rescue drag event manageable. However, as a fire fighter, if I were faced

with a 300 lb victim, I would be forced to seek help, just as a 120 lb fire fighter needs assistance with 165 Ib victim.

2. This PPA as a t imed event does not represent a true simulation of f i reground work pace. Fire fighting t e ~ are assigned tasks; i.e., ventilation, fire attack with hose l lnes or search and rescue. It is counter to safe f i reground procedure for an individual to perform all these tasks alone and continuously. Fire fighting is done in teams of no less than two individuals and when one task is completed, teams report to a f i reground manager for reassignment to prevent freelancing.

3. This PPA is an athletic event designed for well-trained athletes It is dangerous to the health and safety of average citizens from which fire depar tments must recruit their employees. I witnessed more'f ire fighters become incapacitated and in need of medical treamaent in one af ternoon than in any fire in fourteen years of experience.

4. The adoption of this PPA by this Fire Deparmaent has daanaged morale and has segregated groups of employees. Manysmall- statured fire fighters have been recruited and have passed the previous physical agility test which theywere told measured their ability to perform the tasks of a fire fighter. They have served many years in good faith as effective fire fighters. With this arbitrary change in standards their job security has been unfairly threatened.

5 This PPA does no t accurately measure f i reground ability. While watching the administrataon of this test, I witnessed a small-statured fire fighter fail the test with an approximate time of 8:00 mln. This fire fighter then removed personal protective equipment and rendered aid to larger statured fire fighters who crossed the finish line well under the allotted time and collapsed from exhaustion unable to conlanue any form of work. I ask the NFPA Comnuttee which fire fighter was more effective? SUBSTANTIATION: In summary, I believe this PPA is enurely too stature exclusive and does not accurately measure f i reground ability I urge the NFPA not to adopt this PPA and continue research. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has offered the committee no suggested wording changes The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt they s t rengthened the document . The committee discussed whether it should withdraw the documen t from its cycle and start over and concluded that there was a need for the docu- ment and that i twas suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the document covers.

(Log #295) 1583- 25 - (Entire Document): Reject SUBMITTER: John Hayford, National Hospital For Orthopaedics and Rehabilitation COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: None. SUBSTANTIATION: For the past decade, I have been the director of programs for the physical fitness assessment and medical surveillance of firefighters from many public safety agencies in Northern Virginia, including the Fairfax County Fire and Rescue Department, the Arlington County Fire Department , the Metropoli- tan Washington Airports Authority, and the City of Fairfax Fire and Rescue Service, and have served as a consultant to several others In the last ten years, these firefighters have made great and progressive smdes towards achieving enhanced health, fitness, safety, and job performance.

So it was with great concern that I read the recent draft of NFPA 1583. While the National Fire Protection Association has served well as a governing body that issues statements and guidelines that represent a consensus, meant, to address, the concerns and well being of the majority of this nalaon's fire fighting force, it is clear that NFPA 1583 will serve as a mass marketing and publicity tool for the private enterprise that developed this particular "performance test."

Aside from the fact that it is very troublesome to know that private business should be allowed to use a national organization as its mouthpiece, this kind of excessively competitive "performance testing" more resembles a brief and overly intense "American Gladiators" for firefighters rather than a realisuc and defensible simulation of j ob tasks. Its be-all-you-can-be approach may be very appealing to that small subfraction of firefighters who are already highly motivated and fit, but in the long run serves to alienate, injure, and unfairly jeopardize the careers of the vast majority It seems to me that NFPA 1583 should be designed to reach and develop this vast majority of fire fighters. A true and reliable performance test is carefully developed and validated to reflect actual fire fighting tasks per formed in a job-specific pace and

145

N F P A 1583 - - F95 R O C

manner . But the sort o f contest described in NFPA 1583 should remain jns t that, and certainly should no t be misconstrued as a benchmark for de termining employ'ability or retention. Any real, usable guidelines for physical fitness training and health

enhancement are ~rtually absent in NFPA 158S, focusing instead on a lengthy endorsement for one particular contest that has hardly received universal acceptance as the ultimate-measure of fire fighting capability. How the individual fire fighter is supposed to achieve this is largely left up to him or her. Was this the original intent of this document?

If NFPA 1583 remains as it is, this will be a great disservice and a . giant step backward for many fire fighters who have only recently begun to realize the many benefits to themselves (as well as their deparunen t and the public they serve) in devoting time and care to the maintenance of their most important piece of equipment. COMMITI'EE ACTION: Reject. COMMITI'EE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the documen t as published and has incorporated changes where it felt they s t rengthened the document- The committee discussed whether it should withdraw the documen t f rom its cycle and start over and concluded that there was a need for the docu- ment and that i twas suitable as revised. Note that the title of the document and the purpose have been refined to better reflect what the documen t covers.

( Log #297) 1583- 26 - (Entire Document) : Reject SUBMITTER: E. Randolph Sod Hod, Western Occupational Health Centers COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: None. SUBSTANTIATION: This documen t addresses a variety of issues regarding physical fitness, physical performance, and outline concerns in administering testing programs in light of the Ameri- cans with Disabilities Act (ADA). Although this document appears relatively complete, I feel that there are serious flaws that may cause potential problems in the future.

Emphasis has been placed on the Physical Fitness Assessment (PFA) evaluation of basic physical abilities to de termine if a person can perform Physical Performance Assessment (PPA) safely. There is a basic assumption that if a person is physically fit, they they can safely perform the PPA.

While I do not disagree with this inference, the proposed NFPA 1583 ruling does not specifically address how to measure the PFA. In my experience, there are numerous programs which claim to be able to provide an accurate assessment of an individual's physical fitness status. Unfol-tunately, because the measuring techniques for each of these programs are different, no specific correlation f rom one program to another can be made, nor can one program effectively claim to be more effective than the other program. Furthermore, al though several of these programs have claimed to have a correlation of assessment of physical fitness to-"the perfor- mance of fire fighting related tasks and have reportedly s tood up to legal challenges, they have not been sufficiently validated through the scientific community or th rough peer review. It is possible that as more awareness is heard on this issue, the legal precedence previously set will be overturned in the future.

Chapter 5 - Recommended Criterion Task describes specific criterion tasks for assessing the physical performance of a fire fighter. I think this section should be more appropriately rifled "Content Validity Task ", based on the definition provided on page 991. Since there are no studies proposed in this document , I question whether or no t they are a t rue representat ion of essential

i ob functions in all the fire depar tments of this country. While it is eft up to each fire depar tment to perform their own j o b task analysis (JTA), caution must be given to the credentials of such individuals. It has been my experience that many well-known individuals claiminl~ to be knowledgeable of.JTA are actually providing incomplete information regarding these recommendat ions and are actually placing the employer at a high risk for litigation. It is, therefore, my recommendat ion that a warning be presented to employers and that a selection criteria for experts be identified. The body drag and ventilation task emphasizes the use of u~per

body s t rength . If these tasks are used as a selection or re tent ion criterion, ttaese tests will gender discriminate against women and will "screen out" potentially qualified individuals. Because women will have more difficulty performing these tasks, a rank order rating will certainly eliminate more women then men. Furthermore, since women may not be able to lift the dummy to an effective height, more contact will be between the d u m m y a n d the ground, and will

create an adverse testing situation and increase the potential for injury.

Section 5-S.1 describes energy demands "apj~roaching 14 METS" as an "output r ecommended by some experts... There is no reference made as to whom these experts are and under what situations these recommendat ions were made. Furthermore, this s tatement is confusing since this activity may "require" a certain level o f energy expendi ture rather than the individual having the ability to "provide" a minimal level of energy. Appendix B makes reference to establish "Cut-Points" and bases the scnssion on four court cases. One of these cases is at least 20 years

old. If not already done, a formal legal opinion regarding the application of this discussing establishment of a min imum cut-point based on the poorest performance may result in liability to the employer. Establishment of too high of a cut-point may result in discriminatory employment practices. With either situation, NFPA and the authors of the NFPA 1583 Guidelines may be ultimately liable. COMMIT1T.~ ACTION: Reject. COMMITFEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt they s t rengthened the document . The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- men t and that it was suitable as revised. Note that the title o f the documen t and the purpose have been refined to better reflect what the documen t covers.

(Log #306) 1583- 27 - (Entire Document): Reject SUBMITrF_.R: Donna P. Brehm, Virginia Beach, VA COMMENT ON PROPOSAL NO: 158S-16 RECOMMENDATION: Recommend complete review of entire document . SUBSTANTIATION: This documen t places far too much emphasis on the PPA. If the Physical Fitness Assessment is so important why weren ' t r e commended assessment procedures given. If such evaluative measures do exist, then why can' t they also fulfill tile need for the annual physical per formance evaluation of personnel? Chapter 3 is extremely important and seems to have been glossed over. This is one area that has historically been neglected by most fire depar tment physical fitness programs over the years and I feel .th!s g.eneral oversight has been responsible for many fire fighter injuries.

The PPA proposed represents a totally unrealistic sequence of evens or tasks that would be expected of a single fire fighter. It encourages, if no t demands, people to work beyond their physical limits and invites injury. You can say in the documen t that fire fighters should not push themselves beyond their abilities, but when you j o b is potentially on he line that is exactly what the fire fighter will do.

The documen t also stresses the need fo rprepara t ion and practice. It is unrealistic to suppose that the lar~er depar tments will be able to provide the necessary "props" to practice the tasks at all their work sites. And it is evident from recent public televised "combat" events that practice does indeed make a difference.

There has got to be a bet ter way to evaluate fire fighter physical readiness than at proposed in NFPA 1583. It is an extreme and I believe dangerous "fad" that will have enormous impacts on fire depar tments by eliminating potentially excellent prospective employees and causing injuries to existing fire fighters. I urge you to reconsider your approach to physical performance appraisal~ COMMITTEE ACTION: Reject. COMMITFEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorporated changes where it felt they s t rengthened the document . The committee - discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- men t and that it was suitable as revised. Note that the title o f the document and the purpose have been refined to better reflect what the document covers.

146

N F T A 1583 - - ln)$ R O C

" (Log #slg) 1583- 28 - (Entire Document): Reject SUBMIT1"E~ T. L Siegfried, International Association of Fire Chiefs COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: On behalf of the members of the IAFC, we would like to offer the following comment and observation on NFPA 158~.

The IAFC stands firmly behind the need for fitness and wellness standards in the fire service, but it is our opinion that NFPA 1583, as written, does not adequately address the diverse needs of the American fire service.

Therefore, we strongly urge the NFPA to return this standard back to the committee for ~-urther study and development.

The IAFC remains committed to the NFPA standards making process and we strongly urge the Standards Council to cominue to promote realistic andreasonable standards for the fire service. SUBSTANTIATION: None: COMMrrIT.E ACTION: Reject. C O ~ S T A ~ : The submitter has offered the committee no suggested wording changes. The committee has carefully considered the manycomments that suggested improve- ments to the document as published and has incorporated changes where it felt they strengthened the document. The committee . discussed whether it should withdraw the document from its CyL~, and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note that the tide of the document and the purpose have been refined to better reflect what the document covers.

p "nnmrily.anaerobic activities executed in the shortest possible Ig-ne. Not only does this fail to take into account the reablife extenuating drcumstances under which most of these tasks would be performed (i.e., billowing smoke, frightened victims), but it fails more importantly in two other ways.

First, through speed of performance is certainly important, my consideration is endurance. The initial rush of adrenaline when first arriving at the scene of a fire could get a fire fighter moving faster

an any amount of training for a Combat Test. And second, by isolating the physical response and ignoring not only t_F/at adrenal . rush, but all subsequent emotional responses, one tends to analyze an automation and not ~ human being.

I would also like to suggest ~ t , while the Combat Test may indeed demonstrate fire fighting abilities, it may have the same testing flaw as self-help seminars- what you end up being good at is a Combat Test or aself-help course. SUBSTANTIATION: None. COMMrFrEE ACTION: Reject. COMM][TrRE S T A ~ : The submitter has offered the committee no suggested wording changes. The, committee has carefully considered the many comments that suggested improve- ments to the document as published and has incorpo/ated changes where it,felt they strengthened the document. The committee - discussed whether it should withdraw the document from its cycle and mart over and concluded that there was a nee~l for the docu- ment and that it was suitable as revised. Note that the tide of the document and the purpose have been refined to better reflect what the document covers.

(Log #o5) 1583- 29 - (Entire Document): Reject SUBMITrER: Richard M. Duffy, International Association of Fire

ON PROPOSAL NO: 1583-16 RECOMMENDATION: Delete the entire document. SUBSTANTIATION: The IAFF befieves that the issuance of a

~ hysical performance testing program that largely relies on a task- ased timed test is extremely dangerous. There have been reported cases of public safety recruits thathave died during such test activities. Additionally, the US military has experienced numerous deaths during task based testing. The rusks required in the document have not been legally validated by either the EEOC or through judicial review. The IAFF is not against physical fitness within the fire service - - but

rids is not a physical fitness document. The IAFF's~olicy is that we will and do provide the necessary guidance and assmance in implementing physical fitness programs for any IAFF local and ' affiliate which requests such assistance. Such progrmm may be mandatory, however, agreement to initiate it must be mutual between the administration and its members represented by the local union. Any program a physical fitness must b e a t a minimum positive and not punitive in design; allow for age and position in the department; allow for on-duty time partidpation'~iilizing facilities provided or arranged by the department; provide for retiabilitatlon and remedial support for those in need; and be reasonable and equitable to allpartidpants. COMMITIT.E ACTI ON: Reject. COMMITTEE STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the manycomments that suggested improve- ments to the document as published and has inc6rporated changes where it felt they strengthened the document. The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu- ment and that it was suitable as revised. Note~that the title of the document and the purpose have been refined to better reflect what the document covers.

( Log #1 ee) 1583- 30 - (Entire Document): Reject SUBMITTER: Marilyn Holbeck, Total Health Center COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: In reading NFPA 1585, I am struck by how, in yet another professional simatinn, the attempt is being made to reduce overall performance to mere physical response. While it's very true firefighters should be in top physical shape, I question the validity of testing only this as a major employment consideration. As I understand this testing procedure, the tasks performed require

(LOg#~Sg) 1583-31 - (EntireDocument): Reject SUBMITrER: William Peterson, Piano Fire Department COMMENT ON PROPOSAL NO:/1583-16 RECOMMENDATION: Return to Committee. SUBSTANTIATION: Inadequate information is included in the document for the authority having jurisdiction to set minimum cut points in the PPA or PFA or to determine how to validate the PPA or PFA for their specific jurisdiction. Inadequate guidance is also present to address increasing fitness levels and rehabilitation. COMMYITEE ACTION: Reject.

" C O ~ STATEMENT: The submitter has offered the committee no suggested wording changes. The committee has carefully considered the many comments that suggested improve- merits to the document as published and has incorporated changes where it felt they sffengthened the document. The committee discussed whether it should withdraw the document from its cycle and start over and concluded that thereyxas a need for the docu- ment and that itwas suitable as revised. Note that the title of the document and the purposf have been refined to better reflect what the document covers. --

(Log #214) 1583- 32 - (Other): Reject S U B ~ Mark S. Wheatley, Fail'fax County Fire & Rescue

ON PROPOSAL NO: 1583-10 RECOMMENDATION: None. SUIg.qTANTIATION: The number of tasks should be increased and moved to the appendices. Increasing the number of examples and providing varlatiom of those listed will allow a deparunent to develop their own PPA, rather than simply relying_ on the standard. Additionally, havingthe task listed in the standard does not permit increasing the number of task(s) or variation (s) of those listed. The limited number of tasks will certainly measure explosive strength for a sllort duration, but it does little to measure stamina or endurance. Fire suppression activities require both.

F t r~e rmore , of the six tasks listed, five are the components of the currently popular Combat Challenge Test. In my opinion, this places the NFPA in the position of essentially'endorsing this product, rather than meeting the scope's purpose and spirit of the standard. CoMMrI ' rEE ACTION: Re|ect. COMMITTEE b T A ~ The submitter has offered the commiRee~o suggested wording changes. The committee has carefully considered the many comments that suggested improve- merits to the document as published add has incorporated ~:htmges where it felt they strengthened the document. The committee discussed whether it should withdraw the document from its cycle and start over and concluded that there was a need for the docu-

147

NFPA-1583 - - F95 R O C

merit aad that it was suitable a~ revised. Note that the tide of the document and the purpose have been refined to better reflect what the document covers.

1583- 33 - (Title): Accept ' (Log #190) SUBMITTER: GordonM. Sachs, Responder Publications COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: Change title of document to: Recommended Practice for Fire Fighter Physical Performance

Assessment SUBSTANTIATION: The main emphasis of the document is physical performance testing. It only minimally addresses condition- ing programs, and is totally devoid of mentioning a wellness

~ rngram. This document shall not imply that it relates to a physical tness or wellness program. This shou'ld be in a separate document. COMMITTEE ACTION: Accept.

(Log #26) 1583- 34- (1-1.3): Accept in Prindple " SUBMITTER: Terese M. Floren, Women in the Fire Service, Inc. COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: Add the following sentence:

"This includes any member, regardless of current job assignment or classification, who may be required to wear and SCBA in 'emergency operations". SUBSTANTIATION: The recommended practice is intended to apply to all memb~ers of the department who may be required to wear and SCBA. The addition of this second sentence serves to clarify this point. COMMIq[TEE ACTION: Accept in Principle. Language now included in renumbered i-1.4.

COMMITYEE STATEMENT: See Committee Action on Comment • 1583-?,5 (Log #66).

(Log#06) 1583. 35 - (1-1.4): Accept in Principle SUBMITTER: Richard M. Dutfy, International Association of Fire Fighters COMMENT ON PROPOSAL NO: 1583.16 RECOMMENDATION: Change "all" fire fighters to "candidate and cu trent fire fighters". Delete the words "who could be required" and "that involve

wearing serf-contained breathing ap,,paratus (SCBA)". Change the phrase "to participate to "that participate".

SUBSTANTIATION: This change makes the document consistent with NFPA 1500 (8-2.1) and NFPA 158 (1-2.1)2. The requirements of dais standard must be consistent with the parent document (1500). COMMITTEE ACTION: Accept in Principle. Revise 1-1.4 to read: "This recommended practice applies to candidates and current fire

fighters who partidpate in emergency operations that involve wearing self-contained breathing apparatus (SCBA)." ' COMMITrEE STATEMENT: The committee agreed with the intent of the submitter'but warned to leave the reference to SCBA in the document as it better defines the personnel to be covered.

' (Log #67) 1585- 36 - (1-1.5): Accept in Principle SUBMITTER: Richard M. Duffy, 'International Association of Fire l ters

T ON PROPOSAL NO: 1583-16 RECOMMENDATION: Change to read:

"The administration of the health and fitness program and associated physical performance practices shhL1 be the responsibility of the fire departmentphysician. The physician shall be permitted to utilize a health and fitness coordinator to assist in the implemen- tation of such programs". SUBSTANTIATION: This change makes the document consistent with NFPA 1500 (8-6.1) which clearly identflies the fire department physician's responsibilities.

COMMrrFEE ACTION: Accept in Principle. Now included in renumbered $-4.

COMMITTEE STATEMENT: The committee has revised the requirement to be consistent with the change in title [see Comment 1583.33 (Log #190) ] and has changed the statement from a mandatory statement to a permissive statement as this is a recom- mended practice and not a standard,

(Log #27) 1583- 37- (1-2): Reject SUBMrITER: Terese M. Floren, Women in the Fire Service, Inc. COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: Substitute the following wording:

"The purpose of this document is to provide guidelines for the establishment of (1) a fire service physical fitness and health " enhancement program, and (2) a physical performance assessment

~ rogram". UBSTANTIATION: Guidelines for the establishment of a physical fitness and health enhancement program are included in the document. This should he reflected in its stated purpose. COMMYITF_~ ACTION: Reject. COMMITIT~ STATEMENT: See Committee Action on Comment 1583-40 (Log #139).

(Log #68) 1583- 38 - (1-2): 'Accept in Principle SUBMITTER: Richard M. Duffy, International Association of Fire Fighters COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: Delete all references that this document containsguidelines for the establishment of a fire department physical fitness program. SUBSTANTIATION: The document does not contain such

Uoidelines. MMITI'EE ACTION: Accept in Principle.

COMMITTEE STATEMENT: See Committee Action on Comment 1583-40 (Log #139).

(Log #215) 1583- 39 - (1-2): Reject ,. SUBMITrER: Glenn A. Gaines, Fairfax County Fire and Rescue Department, VA COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: Revise the text to the following:

"The purpose of this document is to provide guidelines for the establishment of a fire service health enhancement, physical fitness, and physical performance assessment programs." SUBSTANTIATION: Health enhancement programs are addressed in Chapter B-and should be stated in the purpose. COMMIT'rEE ACTION: Reject. COMMITI'EE STATEMENT: See Committee Action on Comment 1583-40 (Log #139).

(Log #139) 1583- 40 - (1-2 (New)): Accept in Principle SUBMITTER: Dawn M. Smith, Pike Township Fire Department, IN COMMENT ON PROPOSAL NO: 1583-16 RECOMMENDATION: New text to he added after the existing sentence:

"The recommendations in this document are not meant to he interpreted as describing the only way in which such a program may be developed and administered, but as an exampl