New York State OFPC Best Practices

[nysff 18]

OFPC has developed a Fire Department Best Practice document that is available on their website. The link to the document is below. This document outlines what they consider to be the "best practice" in regards to minimum training requirements for the fire service.http://www.dhses.ny.gov/ofpc/training/documents/training-best-practices.pdf

[JM15 386]

Is this new? In essence it is Firefighter 1 to be interior and Fire Officer 1 to be an officer...

[pasobuff 38]

this is a new document.

[firecapt32 282]

As always NYS is a home rule state and each and every organization has AHJ. Having said that this is good news for the fire service. It finally lets departments have something to hang their hats on when it comes to training.

[nysff 18]

Is this new? In essence it is Firefighter 1 to be interior and Fire Officer 1 to be an officer...

Yes. This is new and was posted on their website on the 21st of June. I feel this was a long over due document, however they are only recommendations as NYS is a "home rule" state as stated above by firecapt32, and these are minimum as well. It would be nice to have a legislative law like the career side has to mandate training levels for all firefighters to be trained to the same minimum standards.

[SageVigiles 1,194]

CT is also a "Home Rule" state and the state technically cannot "require" any department to have its personnel trained for to the Firefighter 1 level, but its the accepted standard/benchmark/whatever you want to call it. Will this mean you're going ProBoard in NY?

Edited June 28, 2012 by SageVigiles

[wraftery 1,275]

This is one of the sorriest excuses for a document I have ever seen. All it does is "recommend." Yes, NY is a home rule state, but it does Require 229 hours of training for career firefighters under their document Administrative Standards for Firefighters. Where's the "home rule" in that? I believe the State could require a lot but just chooses not to. Even the 229 hours is minimal. Responsible fire departments are giving their probies somewhere in the range of 400 hours before they hit the street. Along with that, the required 100 hrs per annum cannot scratch the surface of the things they should be training on annually.

Where was home rule when the state mandated PASS devices and personal escape systems? The state jumped right over home rule when enough people demanded these items, and the state can do it in regards to training. All you have to do is get together and make a stink to enough stste legislators.

The argument for "home rule" and "recommendations instead of requirements" over the years has usually been something along the lines of "If we force too much training on firefighters, we will lose volunteers." Well, how would you rather lose them, because you require too much training, or would you rather carry them out in stokes baskets and put their name on that ever growing stone monument in Albany. (By the way, that monument sits in front of the place where they only "recommended" training. Ironic, isn't it?) This is not a salvo aimed at volunteers, either. The vols that see the need for training will stay.

I spent almost 35 years on the fire department and I cannot remember a time when I didn't want more skills and knowledge. Even in retirement, I am still learning. The Authority Having Jurisdiction should be within yourself. You should be begging your department for more training and knowledge.

How would you feel if you were personally responsible for losing a guy because you chose not to train on whatever killed your fellow firefighter? You have to live with that for the rest of your life?

Never let a man say that his training let him down.

[SageVigiles 1,194]

This is one of the sorriest excuses for a document I have ever seen. All it does is "recommend." Yes, NY is a home rule state, but it does Require 229 hours of training for career firefighters under their document Administrative Standards for Firefighters. Where's the "home rule" in that? I believe the State could require a lot but just chooses not to. Even the 229 hours is minimal. Responsible fire departments are giving their probies somewhere in the range of 400 hours before they hit the street. Along with that, the required 100 hrs per annum cannot scratch the surface of the things they should be training on annually.

Where was home rule when the state mandated PASS devices and personal escape systems? The state jumped right over home rule when enough people demanded these items, and the state can do it in regards to training. All you have to do is get together and make a stink to enough stste legislators.

The argument for "home rule" and "recommendations instead of requirements" over the years has usually been something along the lines of "If we force too much training on firefighters, we will lose volunteers." Well, how would you rather lose them, because you require too much training, or would you rather carry them out in stokes baskets and put their name on that ever growing stone monument in Albany. (By the way, that monument sits in front of the place where they only "recommended" training. Ironic, isn't it?) This is not a salvo aimed at volunteers, either. The vols that see the need for training will stay.

I spent almost 35 years on the fire department and I cannot remember a time when I didn't want more skills and knowledge. Even in retirement, I am still learning. The Authority Having Jurisdiction should be within yourself. You should be begging your department for more training and knowledge.

How would you feel if you were personally responsible for losing a guy because you chose not to train on whatever killed your fellow firefighter? You have to live with that for the rest of your life?

Never let a man say that his training let him down.

One of the greatest posts on this forum, ever. Well said sir.

[nysff 18]

CT is also a "Home Rule" state and the state technically cannot "require" any department to have its personnel trained for to the Firefighter 1 level, but its the accepted standard/benchmark/whatever you want to call it. Will this mean you're going ProBoard in NY?

New York State already is ProBoard for Firefighter I and II as well as other courses.

[nysff 18]

This is one of the sorriest excuses for a document I have ever seen. All it does is "recommend." Yes, NY is a home rule state, but it does Require 229 hours of training for career firefighters under their document Administrative Standards for Firefighters. Where's the "home rule" in that? I believe the State could require a lot but just chooses not to. Even the 229 hours is minimal. Responsible fire departments are giving their probies somewhere in the range of 400 hours before they hit the street. Along with that, the required 100 hrs per annum cannot scratch the surface of the things they should be training on annually.

Where was home rule when the state mandated PASS devices and personal escape systems? The state jumped right over home rule when enough people demanded these items, and the state can do it in regards to training. All you have to do is get together and make a stink to enough stste legislators.

The argument for "home rule" and "recommendations instead of requirements" over the years has usually been something along the lines of "If we force too much training on firefighters, we will lose volunteers." Well, how would you rather lose them, because you require too much training, or would you rather carry them out in stokes baskets and put their name on that ever growing stone monument in Albany. (By the way, that monument sits in front of the place where they only "recommended" training. Ironic, isn't it?) This is not a salvo aimed at volunteers, either. The vols that see the need for training will stay.

I spent almost 35 years on the fire department and I cannot remember a time when I didn't want more skills and knowledge. Even in retirement, I am still learning. The Authority Having Jurisdiction should be within yourself. You should be begging your department for more training and knowledge.

How would you feel if you were personally responsible for losing a guy because you chose not to train on whatever killed your fellow firefighter? You have to live with that for the rest of your life?

Never let a man say that his training let him down.

Excellent post Chief. The legislature seems to use the "home rule" excuse when and where they seem fit. As far as the the 229 standard being minimal, at the time it was written and enacted, training was hap hazard at best with no standard amount or type of training provided. Over the years the hours have increased to close to 500 hours during initial training at both the state academy and the westchester academy (I have no clue how many hours "local" academies are putting in), but the law has not changed.

[JM15 386]

New York State already is ProBoard for Firefighter I and II as well as other courses.

Is that for new classes?

[drgripsthrowawaytowel 72]

Anyone who claims that an increase in training will cause volunteer numbers to drop has their head up their brown pipe. Just take a look at numerous other states that require that volunteers are at par with career. No drop in membership, but an increase in effectiveness... imagine that!

If someone wants to quit because the requirements are too strict, good. gtfo. My life, my crews life, and the life of the public is too important to place on the back of a federally mandated 10 hours of OSHA training once a year. If you personally go out and train more, excellent. What needs to happen is the state needs to grow some cajones, manup, and force training requirements that are on par with your counterparts.

Unfortunately, this state's biggest opposition is FASNY, and it will take a large army to change anything.

Anyone who thinks otherwise has drank the kool-aid.

[firecapt32 282]

you can change "home rule" and "AHJ" any time you want. AHJ means just that " authority having jursticiation" so lets as a town or village or city or fire district cnd mandate any fire training they deem appropreate for their community. all they have to do is vote and pass the requirement locally. its that easy.

The career depatments didnt want to chance that a muinicipality would back out and not pass it so they went another route they went legislatively and got a a law passed. i know because I was involved with bot the starting of the 229 and the PASS alerts.

So it can be done either way. It is up the the local towns and villages to give the best protection to the citizens.

As i like to say " Train like your life depends on it because it does"

[nysff 18]

Is that for new classes?

You have to sit for the national certification written exam and take and pass the practical skills evaluations. This is given annually at Montour Falls, as well as regionally if there is demand for it. I am sure Westchester County could get a regional exam if there was enough demand for it.

[JM15 386]

You have to sit for the national certification written exam and take and pass the practical skills evaluations. This is given annually at Montour Falls, as well as regionally if there is demand for it. I am sure Westchester County could get a regional exam if there was enough demand for it.

Oh ok I knew that. I thought that you meant at the end of FF1 it was automatically Proboard. Thanks!

[ex-commish 490]

If I am not mistaken the original FF1 was supposed to be 150 hours which in my opinion was a step in the right direction and as an instructor during that transaction I was very pleased to see something more challenging and useful than the Basic and Intermdiate FF class. But there was the usual battle cry from many leaders in the volunteer fire service as well as FASNY that we can't make it to hard for volunteers so it was watered down to what it is now. There is nothing more important than training. There is nothing more important than knowing how to use the skills needed to get the job done and keep you safe. I have to laugh when I see a parade thread and I see departments going to 10 + parades. That's alot of time that can be devoted to keeping you and your brothers/sisters safe. This is not to take away from the many departments that spend alot of time in training nor am I knocking parades, FASNY or anyone else as FASNY has done alot of good and parades do have a place but it is 2012 we need to wake up.

[Bnechis 3,961]

If I am not mistaken the original FF1 was supposed to be 150 hours which in my opinion was a step in the right direction and as an instructor during that transaction I was very pleased to see something more challenging and useful than the Basic and Intermdiate FF class. But there was the usual battle cry from many leaders in the volunteer fire service as well as FASNY that we can't make it to hard for volunteers so it was watered down to what it is now. There is nothing more important than training. There is nothing more important than knowing how to use the skills needed to get the job done and keep you safe.

Very Well!Said. Now consider I wrote this in the IFD thread (some one said the state sets the standard): "FASNY has always complained that the training requiremens are too much, so OFPC reduced the number of hours in the FF1 class. OFPC for 20 years said it took at least 15 hours to teach the NYS and Federally mandated Hazmat Operations course. When the current FF1 class came out the kept the 15 hours of material and only allow for 3 hours to cover it. Since NYS Law says all firefighters (not vol, not career, not interior, not exterior, but ALL Firefighters) must be certified by their employer (and the courts have ruled that VFD's are employer for this) prior to responding to ANY Calls. So if you only follow NYS and your members have not had at least another 12 hours (inhouse) they are in violation of the law."

When I was told to cover 15 hours of material in 3 hours, I said this was just wrong and someone was going to get hurt, killed or a stupid error with hazmat could wipe out a dept or a community (look up the Summerville MA incident, where they kept putting more and more water on the product, until the whole area needed to be evacuated). I was then told I could teach the 15 hours as a stand alone course, but we could not include it in the FF1.

With the current number of hours in FF1 are they covering building construction? Its one of the big killers of firefighters. More detail can be found in the Hackensack LODD thread.

If NYS will not even teach to the level that is required by NYS Law, how can we expect qualified firefighters?

[tonyc856 16]

It is really interesting that OFPC labeled this as a best practice. A best practice is legally viewed lower then a recommendation. That means OSHA/PESH can not use this under the General Duty Clause, and could make it hard to be used by unions and others to say that NY is requiring this, because in reality they are not.

[JM15 386]

OFPC for 20 years said it took at least 15 hours to teach the NYS and Federally mandated Hazmat Operations course. When the current FF1 class came out the kept the 15 hours of material and only allow for 3 hours to cover it. If NYS will not even teach to the level that is required by NYS Law, how can we expect qualified firefighters?

Excellent point!! So often I hear people say oh I took hazmat Ops in Fire 1 im good to go for Hazmat Tech. Wrong.. there is a huge difference. I have taken the 15ish hour standalone class that OFPC has and it is a great class I know Westchester offers it occassionally. Bnechis do you have any more legal information regarding this? CFR 1910.120 goes into detail about the requirements is that where it is federally mandated as you stated?

I guess what it comes down to is if the training recieved in FF1 satisfies the requirement for Operations level training?

Edited August 13, 2012 by JM15

[everybodygoes 331]

What changed since the original essentials class? Fires still burn and water still puts them out. The more they add the harder it will be to get more members. You know who is competent in your fire dept regardless of if it is paid or not, you also know that if you live in Chappaqua the chance that your new member has ever worked on a ladder is going to be much slimmer than if you lived in some of the less affluent areas, and by mean work off a ladder I don't mean changing spot lights. Time not at work is extremely valuable to people. It would be great if we could all train for 10 weeks non-stop but in reality when you work 40 hours a week and have a family going to the firehouse for 10 hours a week and going on calls really taxes your life!

[SageVigiles 1,194]

1910.120(q)(6)(i)

First responder awareness level

. First responders at the awareness level are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying the authorities of the release. First responders at the awareness level shall have sufficient training or have had sufficient experience to objectively demonstrate competency in the following areas:

1910.120(q)(6)(i)(A)

An understanding of what hazardous substances are, and the risks associated with them in an incident.

1910.120(q)(6)(i)(

An understanding of the potential outcomes associated with an emergency created when hazardous substances are present.

1910.120(q)(6)(i)©

The ability to recognize the presence of hazardous substances in an emergency.

1910.120(q)(6)(i)(D)

The ability to identify the hazardous substances, if possible.

1910.120(q)(6)(i)(E)

An understanding of the role of the first responder awareness individual in the employer's emergency response plan including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook.

1910.120(q)(6)(i)(F)

The ability to realize the need for additional resources, and to make appropriate notifications to the communication center.

1910.120(q)(6)(ii)

First responder operations level

. First responders at the operations level are individuals who respond to releases or potential releases of hazardous substances as part of the initial response to the site for the purpose of protecting nearby persons, property, or the environment from the effects of the release. They are trained to respond in a defensive fashion without actually trying to stop the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures. First responders at the operational level shall have received at least eight hours of training or have had sufficient experience to objectively demonstrate competency in the following areas in addition to those listed for the awareness level and the employer shall so certify:

1910.120(q)(6)(ii)(A)

Knowledge of the basic hazard and risk assessment techniques.

1910.120(q)(6)(ii)(

Know how to select and use proper personal protective equipment provided to the first responder operational level.

1910.120(q)(6)(ii)©

An understanding of basic hazardous materials terms.

1910.120(q)(6)(ii)(D)

Know how to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit.

1910.120(q)(6)(ii)(E)

Know how to implement basic decontamination procedures.

<a name="1910.120(q)(6)(ii)(F)"> 1910.120(q)(6)(ii)(F)

An understanding of the relevant standard operating procedures and termination procedures.

[JM15 386]

Thanks Sage! I am familiar just wanted to clarify

[JM15 386]

This excerpt is from the PESH Fire Department Training Guide version 1.3 from 2/16/2006:

The PESH interpretation of 29 CFR 1910.120 (q) requires fire departments to be First Responders Operations Level ready. The standard requires any fire fighter that responds to a potential hazardous materials incident to maintain at least this level of competency. One way to achieve this level of competency is by successfully completing the 8-hour Operations Level course offered by the NYS Fire Academy. To maintain this level of competency, section 120(q)(8) states that employees that have received the Operations level training shall receive annual refresher training of sufficient content and duration to maintain their level of competencies.

If a fire fighter receives the initial 8-hour course, he is in compliance with the training directive for the next year. If a fire fighter received the training some years ago and no refresher training in the interim, how does this Department come into compliance with this individual? Provide refresher training “of sufficient content and duration” and ensure that the individual is proficient in the subjects described for Awareness Level and Operations Level 1910.120(q)(6) of the standard.

[Bnechis 3,961]

What changed since the original essentials class? Fires still burn and water still puts them out.

Except if water makes it give off a toxic cloud or causes it to burn hotter...but whats the chance will run into those exceptions...you do not need to know about them. And yes water puts out fire, so its ok to stick the nozzle in the window and push the fire around...or do we need more training than that?

The more they add the harder it will be to get more members. You know who is competent in your fire dept regardless of if it is paid or not,

So quantity is more important than quality?

We all know of depts with a 100 members, but only 20% have the ability to do anything. 20% is doing 95% of the work. If an individul has only minimum training, how can they judge who is competent.

With only FF1 training you do not even know, what you do not know.

The more and more training.......hmmm ISO has required 100's of hours of training for all firefighters for over 100 years. It was just ignored by many depts. who were too busy claiming they were the best.

Time not at work is extremely valuable to people. It would be great if we could all train for 10 weeks non-stop but in reality when you work 40 hours a week and have a family going to the firehouse for 10 hours a week and going on calls really taxes your life!

Yes this is one of the biggest issues for the volunteer fire service, but how do they manage this in most states outside NY (where volunteers are held to the same standards). Really taxing ones life is if you get hurt/killed because you or your dept. do not have the skills to do the job.

Tell the fire that your too busy to learn all about it, fire will understand.............

[Bnechis 3,961]

Bnechis do you have any more legal information regarding this? CFR 1910.120 goes into detail about the requirements is that where it is federally mandated as you stated?

I guess what it comes down to is if the training recieved in FF1 satisfies the requirement for Operations level training?

Sage gave you the federal mandate and yes its very detailed (plus it says you also must add the awarness competency which requires 4 hours) as to what needs to be covered. Based on the definitions in the regulation how can it?

1910.120(q)(6)(i) First responder awareness level. First responders at the awareness level are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying the authorities of the release. First responders at the awareness level shall have sufficient training or have had sufficient experience to objectively demonstrate competency in the following areas:

1910.120(q)(6)(i)(A) An understanding of what hazardous substances are, and the risks associated with them in an incident.

1910.120(q)(6)(i)( An understanding of the potential outcomes associated with an emergency created when hazardous substances are present.

1910.120(q)(6)(i)© The ability to recognize the presence of hazardous substances in an emergency.

1910.120(q)(6)(i)(D) The ability to identify the hazardous substances, if possible.

1910.120(q)(6)(i)(E) An understanding of the role of the first responder awareness individual in the employer's emergency response plan including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook.

1910.120(q)(6)(i)(F) The ability to realize the need for additional resources, and to make appropriate notifications to the communication center.

1910.120(q)(6)(ii) First responder operations level. First responders at the operations level are individuals who respond to releases or potential releases of hazardous substances as part of the initial response to the site for the purpose of protecting nearby persons, property, or the environment from the effects of the release. They are trained to respond in a defensive fashion without actually trying to stop the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures. First responders at the operational level shall have received at least eight hours of training or have had sufficient experience to objectively demonstrate competency in the following areas in addition to those listed for the awareness level and the employer shall so certify:

1910.120(q)(6)(ii)(A) Knowledge of the basic hazard and risk assessment techniques.

1910.120(q)(6)(ii)( Know how to select and use proper personal protective equipment provided to the first responder operational level.

1910.120(q)(6)(ii)© An understanding of basic hazardous materials terms.

1910.120(q)(6)(ii)(D) Know how to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit.

1910.120(q)(6)(ii)(E) Know how to implement basic decontamination procedures.

1910.120(q)(6)(ii)(F) An understanding of the relevant standard operating procedures and termination procedures.

1910.120(q)(8)(ii) A statement shall be made of the training or competency, and if a statement of competency is made, the employer shall keep a record of the methodology used to demonstrate competency.

So in other words the members must pass a test on all of the above information. There is no way to learn all that material and pass a test in 8 hours, when the state scheduled double that and they did not include: SOP's and termination procedures or equipment (PPE and other) since its dept. specific.

This excerpt is from the PESH Fire Department Training Guide version 1.3 from 2/16/2006:

The PESH interpretation of 29 CFR 1910.120 (q) requires fire departments to be First Responders Operations Level ready. The standard requires any fire fighter that responds to a potential hazardous materials incident to maintain at least this level of competency. One way to achieve this level of competency is by successfully completing the 8-hour Operations Level course offered by the NYS Fire Academy. To maintain this level of competency, section 120(q)(8) states that employees that have received the Operations level training shall receive annual refresher training of sufficient content and duration to maintain their level of competencies.

If a fire fighter receives the initial 8-hour course, he is in compliance with the training directive for the next year. If a fire fighter received the training some years ago and no refresher training in the interim, how does this Department come into compliance with this individual? Provide refresher training “of sufficient content and duration” and ensure that the individual is proficient in the subjects described for Awareness Level and Operations Level 1910.120(q)(6) of the standard.

1st OFPC does not offer an 8 hour course. The current catalog lists it as 16 hours (they also say that the 16 hours is included in FF1).

2nd I always find it interesting when PESH's interpretation is weaker than the federal law states, particularly when both NYS and Federal law says that PESH must enforce all OSHA regs to the same or more stringent standard than OSHA does.

3rd The above statement does not cover the fact that OFPC can not and never has covered the dept specific material that is mandated.

[SageVigiles 1,194]

If it has 16 hours you're good, it just cannot be LESS than 16 hours. That's just the minimum required by OSHA. OSHA only requires Technician to be 24 hours, but most state's OSHA-Technician course is 40 hours. Even that is too short. During my EPA/OSHA Tech course, I learned just about enough to get myself killed. I had to go out and actively pursue extra training to make myself ready for an actual tech-level response.

In CT the NFPA 472 Technician course is like 180 hours, which is damned near impossible even for most career departments in the state. As a result, Connecticut now offers a full certification to Operational Level for HAZMAT/WMD Mission Specific Competencies under NFPA 472. I'm not sure how many hours it is, but I'm pretty sure its above 40. They're going to roll out a new, shorter Technician program that reflects some of the skills that have been moved down to the Operational Level.

The problem is that CT doesn't require a refresher to keep your 472 Ops certification the way they do the 472 Tech one, so I've heard some departments saying "Great, lets certify our guys to the new Ops, then we won't have to do annual refreshers." Those departments are wrong. NFPA may not require refreshers, but OSHA does. And last I checked NFPA doesn't send investigators up your 4th point of contact after an LODD or LODI, whereas OSHA will.

Its really confusing and they're working out the kinks still, but I think its a step in the right direction if its managed correctly.

Edited August 13, 2012 by SageVigiles

[JM15 386]

Bnechis some great information there. The PESH interpretation I found was from 2006 so it is a bit outdated so that may be where the discrepency is.

I also believe that hazmat in FF1 can not meet this standard...

[everybodygoes 331]

You are assuming EVERYONE only has just the minimum amount of training. Would you allow two probies to go in to a fire with just 40 hours of training? I didn't think so. You have senior members showing them what and how to do it. And how often do you encounter water reactive materials on a daily basis? Maybe a bit of magnesium in a car fire here or there, but eventually the water puts that out too. And I would much rather have a guy who has the minimum training and the wits and common sense over the guy who takes every class in the world and can't figure out how to change the blade on the roof saw. Everyone over complicates this job, and in the last ten years it has become ridiculous in the amount of BS you need. 90% of the class material could be done online, with the practical evolutions done in 5 or 6 nights and a saturday. Make things easier for people not harder. They even cut the hours on EMT cause they knew no one could commit to the amount of hours.

[mstrang1 213]

You are assuming EVERYONE only has just the minimum amount of training. Would you allow two probies to go in to a fire with just 40 hours of training? I didn't think so. You have senior members showing them what and how to do it. And how often do you encounter water reactive materials on a daily basis? Maybe a bit of magnesium in a car fire here or there, but eventually the water puts that out too. And I would much rather have a guy who has the minimum training and the wits and common sense over the guy who takes every class in the world and can't figure out how to change the blade on the roof saw. Everyone over complicates this job, and in the last ten years it has become ridiculous in the amount of BS you need. 90% of the class material could be done online, with the practical evolutions done in 5 or 6 nights and a saturday. Make things easier for people not harder. They even cut the hours on EMT cause they knew no one could commit to the amount of hours.

The problem is, is that you must ASSUME that, especially in a volunteer organization, the entire first due crew MAY be rookies. I have been on calls at work where the average age of the crew from TORFD cannot legally have a beer. The senior guys that can teach those younger guys do not always make it to all of the calls. Yes, more stuff can be done online, but even 5 or 6 nights and Saturday equates to about 28 hours. The "ridiculous amount of BS" that you need is not nearly enough to put someone on the street. My first day at the CT Fire Academy, they told us, "CT requires 400 hours (10 weeks) of training to become a firefighter. CT also requires 800 hours (20 weeks) of training to become a hairdresser".

By the way, I believe CT just raised the number of hours for EMT from 120 to the 150 range, plus increased ride-along and ER time.

[Bnechis 3,961]

Bnechis some great information there. The PESH interpretation I found was from 2006 so it is a bit outdated so that may be where the discrepency is.

The regs were set in 1996 and have not changed since then and they are based on the 1976 & 1986 EPA SARA Title III regs. Nothing has changed, I just find PESH always downplays the regs, until challenged...remember when OSHA came out with 2 in / 2 out and PESH said 2 in 1 out was ok, until they were threatened with loss of millions in federal OSHA funding.

And while failing to follow OSHA / PESH regs could result in fines...they lay a huge ground work for litigation, and with hazmat there are plenty of lawyers who will go after all the parties to recover "spill and remediation costs". These are very easy to prove.