NIMS & the Safety Section

If one of the primary purposes of the Incident Command System (ICS) within the National Incident Management System (NIMS) is to provide for the safety of those involved in mitigating an incident, why is there only one position in the system assigned to the primary role of safety? Is there an argument to be made that the function of safety within the ICS is secondary only to the role of command with respect to overall effectiveness? If the answer to these questions is yes, are there methods by which the effectiveness of the safety function could be expanded?

The Purpose of NIMS
When President George W. Bush issued Homeland Security Presidential Directive #5 (HSPD 5) in 2003, it directed the secretary of Homeland Security (DHS) to develop a national policy on the management of domestic incidents. When the DHS adopted NIMS in 2004, it stated, “NIMS is not an operational incident management or resource allocation plan. NIMS represents a core set of doctrines, concepts, principles, terminology, and organizational processes that enables effective, efficient, and collaborative incident management.” However, the similarity of NIMS to FireScope’s ICS, which was created primarily by the fire service, has caused many both inside and outside the fire service to treat NIMS–specifically the ICS–as simply an operational system.

Further, NFPA 1500: Standard on Fire Department Occupational Safety and Health Program has identified the purpose of the incident management standard as to meet the requirements not only in HSPD 5 but also OSHA’s 29 CFR 1910.120, which are principally safety-related documents. Yet the incident management system’s capacity to address safety-related matters is seen by some as secondary to its ability to support the operational aspect of an incident. This view has caused some fire service leaders to suggest that we need to expand the role of the safety function within NIMS/ICS.

The Safety Section
One method to expand the ICS could be the formation of a “Safety Section.” This new staff position could be addressed in much the same way that “Intelligence/Investigations” is currently–as a sixth option in those cases when the incident commander (IC) believes that it is required. Given the pervasive use of the ICS, it is much more likely that safety will be an issue at an incident than “intelligence/investigation.”

The new section would necessitate a change in the title of the “safety officer” to the “safety section chief,” and it would involve five functional branches: Field Accountability, Hazard Identification, Responder Intervention, Technical Assistance and Responder Care. Each of the branches of the section would carry the authority of the safety section chief to halt, suspend or terminate unsafe actions; however, the focus would be to coordinate activities with other ICS organizational elements. Let’s address each branch in detail.

The Field Accountability Branch would be responsible for tracking personnel deployed in any environment identified as imminently hazardous by the safety section chief. This will normally include interior operations, active rescue activity and hazmat incidents. “Accountability recorders” would be members deployed with division or group supervisors to record personnel accountability in a given operational assignment. Recorders would be on a separate radio channel, and in face-to-face communication with the division or group supervisor, but ultimately would be responsible to the accountability branch director or the safety section chief. The resource unit leader in the Plans Section would maintain general awareness of the unit’s location and status. By radio, this branch would be known as “accountability.”

The Hazard Identification Branch would operate more in the traditional safety officer role, in that the leader of this group would focus on identification of potential responder hazards in the field. The Hazard ID Branch would be provided resources to evaluate and mitigate certain imminent hazards. Individuals knowledgeable of not only potential violations of laws, standards and safety practices, but also tactical operations that could compromise responder safety, would fill the Hazard ID Branch. By radio, this branch would be known as “hazard ID.”

The Responder Intervention Branch would have primary responsibility for responder intervention and rescue. This branch is in charge of all the rapid intervention crews assigned to the incident. This would include the development and implementation of rescue contingency plans for responders. This branch would be implemented after the accountability process is in place. By radio, it would be known as “intervention.”

A take-off from the role currently listed under the Plans Section, the Technical Assistance Branch would be composed of technical specialists with appropriate training to identify possible safety issues associated with a specific hazards, operations or disciplines. This function would be important in hazmat and technical rescue situations, where national standards require a higher level of technical knowledge than can reasonably be expected from the traditional safety officer, and would fill the same role as the current assistant safety officer. A technical assistant would be a responder trained in a specialty discipline with a greater level of overall expertise. This “technical safety assistant” would generally advise the safety section chief or other members on the scene about specific hazards or potential threats to responder safety. By radio, this branch is known as “TA.” Individual technical safety assistants would be known as Hazmat Safety, Rope Safety, Water Safety, etc., for example.

The wellbeing of responders is a significant challenge in all major incidents; therefore, the Responder Care Branch would be implemented to address the psychological, emotional or spiritual needs of responders. This branch will include stress management resources, such as peer debriefers, chaplains or mental health professionals. This branch will also act as the liaison for other needs of responders. By radio, this would be referred to as the “care unit.”

Nearly a decade after the initiation of the presidential directive, NIMS has evolved, becoming more clear and establishing concrete training and development standards; as a result, procedural compliance has risen. However, the core component of NIMS, the ICS, has remained virtually unchanged for a generation. The IC role is initiated more than any other ICS role; in fact, there should be (and now generally is) an IC at every incident.

Interestingly, although ICS use has risen dramatically, it does not appear to have reduced the percentage of firefighter injuries and fatalities. According to the NFPA, in 1977, the percentage of firefighter fatalities that occurred at an incident was 58.6%. In 2011, it was 57.4%–a reduction of only 1.2%. This percentage has been as high as 73% (1979), but never below 35.9% (2003). Although there are legitimate reasons to maintain the consistency and effectiveness of the ICS, if the focus is really on safety, perhaps there should be a bit of exploration into alternatives that could have a statistically significant impact on the safety of responders at incidents.

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