In Episode #103, we replayed the recording of a Dust Safety Academy training session held by Glen Saraduke, principal owner of Saraduke Technical Services. In this episode, we’re going to replay the Q&A that took place after the training was over. These are all questions submitted by the attendees, who welcomed the opportunity to benefit from Glen’s extensive experience.
What is Your Recommendation for Remote Sites in Regards to Organic Firefighting?
Glen recommended that remote facilities look into having a fire brigade consisting of onsite, trained people, as response times from the fire department can be lengthy. There are some NFPA standards for in-house teams as well as local rules that may apply depending on what’s been adopted in that particular jurisdiction.
Who Enforces the DHA Requirement? What’s the Penalty of Non-Compliance?
According to Glen, anything mandated by the Fire Code is enforced by the fire department, but responsibility for compliance is with the facility owner. The fact that the fire department didn’t enforce it isn’t a defense.
“The penalty of non-compliance can be huge,” he warned.
Do You See Most Sites Utilize the Incident Command System When an Event Occurs?
When a fire department arrives on scene in urban areas, they are going to be the incident commander, or IC. This means that they take over and direct all extinguishing activities. In rural environments, the facility owner may have to set up their own fire brigade and have their own internal incident command system to manage events.
Glen confirmed that basic ICS training is available on the FEMA website. One course is IS-315.A: CERT and the Incident Command System (ICS)
What Information Should a Pre-Planning Document Contain?
NFPA 1620 talks about what information should be on the document and goes over the different levels of pre-planning, which vary according to site complexity.
“So for simple facilities, it’s just a very simple pre-plan,” Glen explained. “For more involved sites, where there are processes and valves and pressurized piping, it might be more complex.”
He added that it’s important to get the fire department out and start the pre-planning process immediately. That way, they can be aware of any immediate issues and get those resolved before doing the DHA.
“You have to be proactive with them, because again, it can fall off their radar pretty easily when they get busy with COVID-19 or other more pressing issues. So it really is up to your EH&S folks or insurance folks to really take the lead and make sure that they’ve always got that information.”
If the fire department can’t come out for any reason, Glen recommended engaging a fire safety consultant or contacting the International Association of Fire Chiefs to see if any retired chiefs are in the area.
“You can hire somebody like that on a part-time basis to come in and develop that relationship and run interference between you and the fire department and that’s a good thing. You may even find a retired person from that particular department. It’s not an expensive endeavor but worth its weight in gold when you have an issue.”
Do You Have Any Tips Or Strategies for Communication During an Incident?
Glen explained that when a fire department arrives on site and sets up its incident command, it will, provided that proper pre-planning has occurred, have a list of contact numbers for key facility personnel, such as the manager who knows where all the electrical vaults are located and how to shut them down.
“Communication is always a common factor in problems with incident response, but part of how you can deal with that is training,” Glen said. “(You should) conduct regular trainings with the fire department. You might arrange a mock explosion in your silo and let them respond and see how it works. See how ICS works in the command system, see how those radios work and then tune it up from there. Fire departments are always up for that. They’re always up for training, hands-on real training to improve their safety and your safety. So take them up on that, they’ll love it.”
What Do I Do if the Authority Having Jurisdiction Has Rejected My DHA?
“I don’t know that I’ve seen that too many times,” Glen admitted, “but I have seen DHAs that were in the middle of the process that weren’t being received very well by the fire department and needed to be updated or corrected.”
He recommended that any facility with a rejected DHA look closely at the reason why it was disapproved? Was it a concern over a reactive metal that wasn’t being dealt with or just some punch list items the AHJ wanted to see addressed in the DHA?
“If it’s something more systemic or more critical, and they really just aren’t comfortable, then I think you have to go back to square one and sit down with them in a meeting with the consultant and find out what their concerns are.”
Conclusion
“Hopefully I’ve made a case for being transparent and teaming up with (a consultant) early on, especially in the DHA process,” Glen concluded. “Tell the consultant that you expect them to really educate the fire department and the building department. I think any of the major consultants would be happy to do that. Again, build a relationship. It protects everybody, it protects your equipment, minimizes your downtime.”
If you would like to discuss further, leave your thoughts in the comments section below. You can also reach Glen Saraduke directly:
Email: [email protected]
If you have questions about the contents of this or any other podcast episode, you can go to our ‘Questions from the Community’ page and submit a text message or video recording. We will then bring someone on to answer these questions in a future episode.
Resources mentioned
Dust Safety Science:
Combustible Dust Incident Database
Dust Safety Science Podcast
Questions from the Community
Dust Safety Academy
Companies:
Saraduke Technical Services
Organizations:
NFPA
International Association of Fire Chiefs
FEMA
Standards:
NFPA 1620: Standard for Pre-Incident Planning
Publications:
OSHA Firefighting Precautions at Facilities with Combustible Dust
Training:
FEMA/ICS Training
Course: IS-315.A: CERT and the Incident Command System (ICS)
Previous Episodes:
DSS103: Pre-planning and Working with Firefighters with Glen Saraduke | Part 1
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DSS104: Pre-planning and Working with Firefighters with Glen Saraduke – Part 2