Bailout Law Regulation Interpretation

[Guest alsfirefighter]

The proposed rule as well as the Law itself talks about providing ropes and

system components "appropriate for the risk"

The rule would require a hazard assesment to determine the level of risk in

the area you provide fire protection to and then equip those who are exposed

to a hazard.

There is no intent to just require the protection for anyone who has no

risk. I keep failing to understand why anyone would think we would require

you to equip individuals who don't enter the building and would never be

expected to need the equipment. ( pump operators, fire police, those not

interior qualified) We are asking the employer to make that determination.

If your hazard assesment show that only 1 and 2 story buildings are in the

area and there are other procedures which can be used to insure the safety

of fire fighters operating in the building ( ladders placed for emergency

egress as a matter of SOP on each call) then you may not have to provide

anything.

The proposed rule is clear that you only provide to those who have

exposure.

Be conservative in your purchase. Generally you only need a rope and a belt

if you are going to rappel with your feet against the building You need a

harness if you are going to lower yourself without touching the building

surface.The rope can be as long as you want. You will need a couple of

carabiners and decender.

Some interesting equipment is listed on the web at reasonable cost. You do

not need the $500.00 NYC rig unless you have NYC hazards so don't let the

suppliers sell you a bill of goods. You should be able to provide a pretty

good rig for under $100.00 a person. All components of the system should

meet the 2006 edition of 1983 and the supplier should provide you evidence

that the equipment meets that standard. Everything but the rope must have a

lable and the reciept for the rope should state that that conforms.

If you need further assistance please contact Thomas Rath in the Rochester

District Office of the Public Employee Safety and health Bureau 585 258-4573

David Ruppert

Assistant Director

Div. of Safety and Health

(518) 457-3518

_____

From: john_wicka@dps.state.ny.us [mailto:john_wicka@dps.state.ny.us]

Sent: Wednesday, September 19, 2007 4:11 PM

To: Ruppert, David (LABOR)

Subject: Rope Safety Draft Regulations

Mr. Ruppert - please advise me of the time frame for submitting comments on

the draft rope safety regulations. I am a Fire Commissioner with the Lake

View Fire District (Erie County) and also Vice President of the Erie County

Fire District Officers Assoc and we have many questions and concerns about

how the law was written and the pending promulgated regulations.

Specifically, unclear to us is whether we need to outfit ALL our

firefighters with the required equipment OR if we just need to equip those

firefighters who are qualified for "interior" fire attack or operations.

I've been seeking this clarification from legislative resources for the last

several weeks and have yet to get an answer. Also, after reading the draft

regulations, this question still has not been answered.

Your response and assistance would be appreciated.

John Wicka

Commissioner/Secretary

Lake View Fire District

716-863-3756 (cell)

[E1E2TL3 0]

Thank you ALS

[HFD750 6]

So do we need a "system" or just rope and a biner? like we used in ff survival. Who's is going to access the district to determine what system you need? The chief? We have tall buildings in our response area does this mean every interior ff needs a system like the EXO or RIT?

[Remember585 815]

By "interpreting" this I take it that since the majority of the district we protect is only 1 1/2 story private dwellings, we only have to come up with about 10' of rope per member?

Or by "interpreting" it a different way, our tallest building is five stories tall, so we should outfit everyone with at least 50' of rope.

The one time where I had to make a retreat I would of needed a rope to get down from the 8th floor. Luckily we were grabbed by a Tower Ladder (always greatful TL38! ) and didn't have to make a quick descent. The "risk" in my eyes would be more so in the way of Mutual Aid responses to our south (Ossining) and north (Peekskill) where buildings are eight stories.

Yo no comprendo!!!!

[Monty 35]

So do we need a "system" or just rope and a biner? like we used in ff survival. Who's is going to access the district to determine what system you need? The chief? We have tall buildings in our response area does this mean every interior ff needs a system like the EXO or RIT?

In my non-lawyer eyes, an NFPA personal escape rope combined with an NFPA approved carabineer makes a 'system'.

Who has responsibility for complying with other laws? (OSHA etc). I imagine they would be the ones that have to defend the decision - my guess is that it's the Dept Chief.

[HFD23 37]

They come up with a great law on paper to help protect firefighters saying we need an escape system then they drop the ball with leaving the AHJ to interpret the law. This leaves them the ability to take the short cut way out and only purchase a piece or rope and a carabiner or as stated below they can say

"Other procedures which can be used to insure the safety of fire fighters operating in the building (ladders placed for emergency egress as a matter of SOP on each call) then you may not have to provide anything."

It’s still not enough why we cut costs when it comes to FF Safety as long as we continue cutting corners with our safety we will continue to kill over 100 FFs a year......

[x129K 1,393]

I bet the manufacturers are scrambling to come out with a system "kit", with a belt device, for around $100....and who ever does could stand to make a butt load of money.

[RDUNC67 1]

I bet the manufacturers are scrambling to come out with a system "kit", with a belt device, for around $100....and who ever does could stand to make a butt load of money.

There are kits available now, but they are along way from $ 100.00, depending on what equipment FD's have now as far as Class II harnesses (Gemtor 541 or RIT Class II) you can probably buy ala carte for less than $ 100.00 minus the harness as mentioned.