“What matters most is how well you walk through the fire.” – Charles Bukowski
A firefighter’s instinct in a fire scenario is to extinguish it, to throw water on it, to do whatever it takes to bring the situation back to a safe state. Sending a firefighter to an industrial fire without knowledge of what is on site is a scenario that can ultimately lead to firefighters dying in vain.
Prefire plans are documents that aid firefighters by providing them with knowledge specific to each building, helping them to perform more effectively. These plans allow them to create strategies for incidents that would otherwise have to be created off the cuff, allowing firefighters to save valuable resources, minimize losses, and possibly save human life.
NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, is a governing standard for hazards associated with the grain handling industry. Among other things, this standard requires that employers include the fire department prefire plans inside their emergency action plan (EAP).
What NFPA 61 does not say is what needs to be included inside the prefire plans. Also, it does not explicitly state who is responsible for creating the fire department’s prefire plans, leaving facilities wondering how their EAP is supposed to appear as a finished product.
NFPA can’t make you do it
The NFPA has developed hundreds of standards for the prevention of uncontrolled fire and the damage fire causes. Unlike OSHA standards, the NFPA has no enforcement authority. If a company should choose to adopt an NFPA standard to comply with OSHAs general duty clause, which states that a company must provide its workers with a safe work environment free of known hazards for their workers, then the NFPA standard, becomes enforceable.
What does a prefire plan include?
When a company adopts NFPA 61 to comply with the General Duty Clause and its emergency action plan does not include a pre-fire plan, the facility will be vulnerable to citation. To keep that from occurring, it is important to that a pre-fire plan is prepared as soon as possible. Two standards which can be used as a good reference are NFPA 1620, Standard for Pre-Incident Planning, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations. Both standards cover the requirements and responsibilities for prefire planning. Following the requirements of these two standards as they apply will satisfy this clause, but in the end, it will be the local fire department that will decide what is useful.
An effective fire plan will include collecting and providing information to the local fire department including some of the following:
- A title sheet containing facility name, facility address, most efficient route from fire department, and keybox locations
- Building features sheet containing building type (including roof and ceiling types), building size, building age, all access points, material of construction for the building (floor, roof, foundation, exterior, etc.)
- A sheet to include information on utilities containing utility providers with contact information, boiler room locations, and fuel used in the building
- A sheet for site considerations including intended use of buildings, location areas of rescue, occupied stories of the building
- A hydrants’ location sheet with map location
- A fire protection sheet that includes information on alarms, sprinklers, fire control system locations, stand pipe locations, and fire department connections
- A map of hazardous locations on site
Who is responsible for the prefire plan?
It is the facilities responsibility to ensure that prefire plans are included inside the emergency action plan, but the responsibility of creating the prefire plan is a multiple party effort between the facility and the local fire department. NFPA 1620 and NFPA 241 both call for a party that must cooperate with the local fire department.
Prefire planning goes by another name in NFPA 1620 and is known as pre-incident planning. The pre-incident plan developer can be an individual, group, or agency responsible for developing or maintaining the pre-incident plan decided by the authority having jurisdiction. The pre-incident plan developer must be competent and familiar with the basic information to be collected and included in the final pre-incident plan. However, the responsibility of the pre-incident plan is a cooperative effort among the pre-incident plan developer, facility management and operations staff, and responding personnel. This standard explicitly states that it is not applicable to structures undergoing construction, alteration, and demolition operations.
NFPA 241 states that the owner is responsible for selecting a fire prevention program manager that will ensure that the fire prevention program is carried out to completion. The fire prevention program manager is responsible for the development of prefire plans in conjunction with the fire agencies. This standard applies to structures during construction, alteration, or demolition, including those in underground locations. These same requirements can be found again in NFPA 1.
Do you have a prefire plan?
If your grain handling facility does not have a prefire plan included with its EAP, it’s time to find out where your prefire plan is located and include it. If there is no prefire plan, ask your local fire department if they would cooperate on creating one. If your local fire department decides that it does not want to work together on creating prefire plans, create some form of documentation to relieve your facility of fault for when OSHA needs to inspect your facility.