A SWOT Analysis for the

Jackson Township Fire District # 3

Prepared by

Technical Fire Services, Inc.

21 South Taylor Street Bergenfield, New Jersey

November 2009

Technical Fire Services, Inc. was engaged by the Jackson Township Fire District # 3 to conduct a district wide study for Jackson Township Fire District # 3 that would examine the strengths, weaknesses, opportunities and threats of the Fire District. This type of study, commonly referred to as a SWOT analysis is an excellent tool that can be used to create a long term plan by which the District can properly plan its future. The study was completed by a team that included Gerard J. Naylis who served as principal author assisted by Dr. Robert S. Fleming, John Giancaspro and James A. Kirsch. Gerard J. Naylis is a principal of Technical Fire Services, Inc. He has a fire service background that covers more than 36 years including experience in both career and volunteer fire departments. Professionally, Mr. Naylis was employed for 10 years with the Atlantic City Fire Department before moving to Arkwright Mutual Insurance Company which later merged to become what is now known as FM Global, where he worked in the loss prevention engineering department of the company for over 15 years as an Account Engineer and an Engineering Officer. He holds the Associate in Risk Management (A.R.M.) designation from the Insurance Institute of America. He left FM Global in 2002 and served as the Eastern Regional Director for the United States Consumer Product Safety Commission for two and one-half years. He has a Bachelor of Science degree in Fire Safety from Jersey City State College and a Master of Administrative Science degree from Fairleigh Dickinson University. Mr. Naylis is an accomplished author having co-authored the most recent edition of Fire Related Human Behavior used in the college course of the same name offered by the U.S. Fire Administration in the Degrees at a Distance program in addition to having dozens of articles published in fire service and risk management publications. He was a co-developer of the original Factory Mutual training program Fighting Fires in Sprinklered Buildings. He is also a well know lecturer who has spoken and taught throughout the United States, including being a keynote speaker at the 2001 Fire Department Instructors Conference in Indianapolis, Indiana and delivering the keynote speech during the closing session of the 2008 Fire and Emergency Services Higher Education (FESHE) conference at the National Fire Academy in Emmitsburg, MD. Mr. Naylis was the President of the International Association of Arson Investigators in 2000-2001. His representative current professional activities include:

• New Jersey Fire Safety Commission (Member) • NJ Fire Safety Commission Statistics and Information Advisory Council (Chairman) • NFPA 1033, Fire Investigator Professional Qualifications Standard Committee

(Chairman) • National Fire Protection Association (Member) • New Jersey Chapter, Society of Fire Protection Engineers (Director) • International Association of Arson Investigators (Past President & Life Member) • New Jersey & New York Volunteer Firemen’s Association (Board of Directors) • Bergen County Fire Chiefs Association (Board of Directors) • Fire Engineering magazine Editorial Advisory Board

Dr. Robert S. Fleming is a highly respected researcher, author, instructor, consultant and conference speaker within the fire and emergency services community. He has been actively involved in fire and emergency management for 38 years and has served in numerous operational and administrative positions, including fire chief. In addition to a Doctor of Education in Higher Education, Dr. Fleming has earned five masters degrees, including a Master of Business Administration from Temple University and a Master of Government Administration from the Fels Center of Government of the University of Pennsylvania. The primary focus of his research, teaching and consulting has been on enhancing organizational effectiveness, with an emphasis on local, county, state, regional, and national fire and emergency service organizations. His representative current professional activities include:

• Certified Fire Protection Specialist Board (Past Chairman and current Director) • Chester County Emergency Medical Services Council (Director) • Chester County Local Emergency Planning Committee (Chairman) • Chester County Mitigation Committee (Member) • Commonwealth of Pennsylvania Fire Service Certification Advisory Committee

(Chairman) • Keystone Chapter Fire Service Instructors (President) • Montgomery County Fire Academy (Senior Instructor) • National Fire Academy, Board of Visitors (Past Chairman)

Dr. Fleming is a certified fire instructor in Pennsylvania and New Jersey whose many professional fire and emergency management certifications include certification by the National Board on Fire Service Professional Qualifications as Fire Instructor II and Fire Officer II, by the National Fire Protection Association/Certified Fire Protection Specialist Board as a Certified Fire Protection Specialist, and by the Commission on Fire Accreditation International as a Chief Fire Officer. He has contributed to all of the major fire service publications, regularly develops and delivers training programs for the New Jersey Division of Fire Safety, and has developed and presented numerous management and officer development programs for the Fire and Emergency Television Network. (FETN). John Giancaspro holds a Master in City and Regional Planning degree and is a graduate of the Edward J. Bloustein School of Planning and Public Policy at Rutgers, the State University of New Jersey. He also holds a Bachelor of Arts degree in history from Montclair State University in New Jersey. In addition to serving as a volunteer firefighter with the East Rutherford, NJ Fire Department, he serves as the Deputy Emergency Management Coordinator for that municipality. James A. Kirsch has been a volunteer and career firefighter and fire officer for over 20 years with the Bergenfield, NJ Fire Department. He holds a Bachelor of Arts degree in General Studies and a Master of Public Administration degree from Fairleigh Dickinson University. Mr. Kirsch is certified by the New Jersey Division of Fire Safety as a Firefighter 1, Fire Official, Level 2 Fire Instructor and a Live Burn Fire Instructor, and holds Incident Management Level 2 certification. He has been published in Fire Engineering magazine on a variety of fire service

related topics. Mr. Kirsch is the author and lead presenter in the recently released fire training DVD Live Fire Training in Acquired Structures published by Fire Engineering Books and Videos. He has lectured across the United States including being a frequent presenter at the Fire Department Instructor’s Conference in Indianapolis, Indiana. Additionally, Mr. Kirsch has been a featured lecturer for the Firemen’s Association of the State of New York traveling throughout the state to provide firefighter training. The approach taken to complete the study included statistical and document examination, survey instruments to elicit information from officers and members of the fire department and Fire District and other municipal officials, meetings with individuals to elicit information, and conduct focus groups, and site visits through the fire district. A total of thirteen specific focus areas were examined during the study. These areas included:

• Adequacy of staffing • Assessment of the current apparatus fleet and creation of a replacement plan • Current physical facilities and plant as well as new or planned facilities • Training and training programs • Records retention policy • Standard Operating Policies (SOPs), Standard Operating Guidelines (SOGs), and

operational protocols • Organizational structure, operational structure and chain of command • Fire District demographics • Volunteer recruitment and retention program • Response protocols and response times • Fire prevention programs including:

o Fire code enforcement o Public fire safety education

• Risk management review • Services provided by the Fire District

The project team would like to recognize and acknowledge the support received from the members of the Jackson Township Board of Fire Commissioners for Fire District # 3. They have supported the work of this team throughout the project. We would also like to acknowledge the efforts of Ken Byrnes who served as our main point of contact and provided documents needed during the process. Additionally, we appreciate the efforts by Chief Michael Fatovic for arranging the meetings and focus groups held with the volunteer fire officers. Also recognized are the individuals who took the time to complete survey instruments, attended focus groups and provided feedback to the project team. This includes both internal and external stakeholders of the fire district, especially those residents who provided input.

SUMMARY This report contains explanatory material, findings and recommendations from a SWOT analysis conducted for Jackson Township Fire District # 3. During the course of this engagement the project team met with numerous public official, officers and members of the Fire District, and members of the general public. Site visits were conducted to obtain a better understanding of the service demands of the Fire District. The project team was given a single objective. Prepare the SWOT analysis without any preconceived concepts of expectations other than the findings and recommendations should be factually accurate. We believe that the report and analysis achieve that objective. An obvious concern of any governing body, including this Board of Fire Commissioners, is that they are executing their fiduciary responsibilities to the taxpayers and citizens of the Fire District. During the study, the project team learned that the Fire District had gone through a revaluation that amended the tax rate originally being considered. The new tax rate was established at $0.099 cents per $100 valuation. This equates to a fire district tax of $396 per year for a home assessed at $400,000. Examined on a daily cost basis this amounts to slightly less than $1.085 per day for fire protection. For the level of service provided, the project team believes that the value achieved is reasonable. Our examination of the budgets, revenue and expenses controlled by the Board of Fire Commissioners reveals that the Board is acting in the best interests of the taxpayers. This report contains a number of findings and recommendations that the project team believes will achieve greater operating efficiencies. These findings and recommendations can be found in the body of the report. There is a separate section for each area of focus. Additionally, we have identified several methodologies to develop alternative revenue streams to offset the burden imposed by direct taxation of the Fire District. The project team believes that the Board of Fire Commissioners should engage the boards of Fire Districts 2 and 4 to discuss cost sharing relative to the career staff. Currently, Fire District # 3 has more career staff than the other fire districts in Jackson Township. We believe that the taxpayers of Fire District # 3 pay a disproportionate amount to sustain fire protection during the work week compared to the other districts. This is because the other districts realize the benefits of Fire District # 3’s career staff when fires occur during the day while not financially contributing to sustain this level of fire protection. The project team believes that an arrangement such as the Interlocal Service Agreement with Fire District # 1 would be beneficial to the taxpayers of Fire District # 3. The project team also recommends that the District make more use of the fire official’s ability to issue monetary penalties for fire code violations. This is a funding mechanism that has been seldom used over the past five years. Additionally, we believe that the Board should immediately begin to utilize cost recovery from covered insurable property to augment its revenue stream. This is a proven and sustainable funding mechanism that the project team believes could develop between $150,000 and $175,000 annually.

There are several items that have been included in the appendices including job title specifications and information to assist in promoting recruitment and retention.

STAKEHOLDER EXPECTATIONS

Organizational stakeholders are individuals, groups or organizations that are influenced or affected by the activities of an organization and have a direct interest in the success of an organization in fulfilling its mission. The stakeholders of the contemporary fire department fall into two distinct categories: internal stakeholders and external stakeholders. Internal stakeholders include individuals, groups or organizations within the public safety community who participate in or rely on the fire department’s delivery of emergency services. Fire department members, elected and appointed officials, other emergency services organizations, and governmental entities are considered internal stakeholders of the contemporary fire department. External stakeholders include individuals who live in, work in and travel through the Fire District, as well as organizations operating within the Fire District. These stakeholders rely on and have expectations with respect to the fire protection services provided within the Fire District. Through Stakeholder Analysis, the contemporary fire department can identify the various internal and external stakeholder groups it serves, as well as the expectations of each stakeholder group with respect to the fire protection services that it provides. As part of the consulting engagement, Technical Fire Services, Inc. has performed this analysis and confirmed that the expectations of the stakeholders of Jackson Township Fire District #3 are typical of those of the normal expectations for a community fire department. The expectations that stakeholders typically have for contemporary fire departments can be categorized as follows:

Accessibility – Stakeholders expect that when they request fire department services in the time of emergency, these services will be available to respond.

Completeness – Stakeholders expect that the fire department will deliver the comprehensive services necessary to fully resolve an emergency situation. Consistency – Stakeholders expect that regardless of the day or time of the response, consistent services will be delivered by the fire department.

Convenience – Stakeholders expect that the process for requesting fire department services will be easy and understandable, such as calling 9-1-1.

Courtesy – Stakeholders expect that fire department personnel will be courteous as they enact their responsibilities.

Effectiveness – Stakeholders expect that the fire department will effectively resolve the emergency situation.

Efficiency – Stakeholders expect that the fire department will operate efficiently in resolving the emergency situation. Image – Stakeholders expect that the fire department and its personnel will portray an appropriate image.

Professionalism – Stakeholders expect that fire department personnel will conduct themselves as highly trained professionals. Responsiveness – Stakeholders expect that the fire department and its personnel will be responsive to their emergency situation.

Safety – Stakeholders expect that fire department personnel will utilize appropriate strategies and tactics to ensure the safety of firefighting personnel and the public.

Timeliness – Stakeholders expect that the fire department will arrive and mitigate the emergency situation in a timely manner.

Fire departments and other emergency services organizations face a number of unique challenges in meeting the above stakeholder expectations. Although the fire department will respond to many routine calls, there will be a subset of those calls that are true emergencies and require time critical services, which result in immediate service consumption. The services that the fire department provides are often labor intensive and usually intangible in nature. A significant and ever present challenge that fire departments face is that transaction volume can fluctuate significantly over time and it is extremely difficult to predict when services will be required and requested, resulting in unscheduled service delivery. Last but certainly not least is the challenge of organizational visibility in that fire departments and other emergency response organizations are constantly viewed and judged by the public. Analysis of the findings of the study indicates that while there are times that staffing is sufficient to meet the above expectations which stakeholders should rightfully have for fire protection within Jackson Township Fire District #3, there are other times where the lack of an assured reliable staffing pattern challenges the ability of the Jackson Township Fire District #3 to meet a number of stakeholder expectations. The categories of stakeholder expectation that potentially may not be fully met include accessibility, consistency, effectiveness, efficiency, responsiveness, safety, and timeliness. As the Board of Fire Commissioners enact their responsibilities to ensure the adequacy of fire protection to the stakeholders of the District, they should focus on enhancing the District’s ability to fully meet, and where possible exceed, these reasonable stakeholder expectations. This goal should provide essential strategic direction for a number of mission-critical decisions that the Board of Fire Commissioners should address in a timely manner.

ROLE-RELATED ISSUES

The success of the contemporary fire department in fulfilling its mission, achieving its goals, and meeting and where possible exceeding the expectations of its stakeholders, requires that each member of the organization correctly understand and properly enact his or her role within the organization. Failure to properly define and communicate organizational roles and responsibilities can compromise organizational success in many ways. It is essential that the organization properly design each position within the organization. Roles and responsibilities, both on and off the incident scene, must be delineated for all positions, from the rank of firefighter through that of fire chief. Role theory defines three roles: the sent role; the received role; and the enacted role. The “sent role” articulates the expectations of the organization with respect to a given position. This definition of what the organization expects in terms of performance from each position in the organization should be specified in a “job description” that details the duties, responsibilities and activities of the position. The job description, once developed, provides valuable guidance in determining the requisite qualifications to be able to successfully perform the job. These qualifications should then be documented in a “job specification.” Job descriptions and job specifications should exist for all positions within the fire department. The expectations of a position must be effectively communicated to the job incumbent in order to ensure that there is a shared understanding between the job incumbent, the organization, and others with whom the job incumbent will interact in performing the job. The resulting understanding on the part of the job incumbent is referred to as the “received role.” The role that the job incumbent actually enacts or performs is called the “enacted role.” Throughout the consulting engagement it was both apparent and obvious that much confusion existed with respect to the roles and responsibilities of the various positions that currently exist within Jackson Township Fire District # 3. The lack of current job descriptions and job specifications for the various operational and administrative positions within the volunteer fire department and the counterpart career staff have caused significant problems that have resulted in misunderstandings, a dysfunctional organizational climate and morale, communication difficulties, and a lack of visionary leadership. While role-related problems are not unusual in contemporary organizations, including fire and emergency services organizations, they are of such intensity and significance within the Jackson Township Fire District #3, that they have the potential for compromising the District’s ability to fully achieve its service mission to the community in terms of providing an acceptable level of fire protection services. The consultants found that both role ambiguity and role conflict exist within Jackson Township Fire District #3. “Role ambiguity” exists when there is a discrepancy between the understanding of the position incumbent and that of the organization with respect to the role and responsibilities of the position. “Role conflict” results when a position incumbent fails to enact the roles and responsibilities of a position in accordance with his or her understanding of the expected role. Role ambiguity thus represents a discrepancy between the sent role and the received role; whereas role conflict manifests itself as a discrepancy between

the received role and the enacted role. Both types of role-related issues have the potential of compromising organizational success and must be addressed in a proactive and deliberate manner. While the lack of formal job descriptions and job specifications for each position is certainly a contributing factor to the fairly widespread presence of role ambiguity and role conflict within Jackson Township Fire District #3, this issue is more problematic in that it is in large part based on a lack of clarity of the roles of the Board of Fire Commissioners, the volunteer fire department, and the career staff employed by Jackson Township Fire District #3. The importance of understanding, clarifying and properly enacting roles is of paramount importance. This understanding should be ensured through: job descriptions; organizational structure; and laws, regulations and ordinances. This process of clarifying roles and responsibilities must begin with the Board of Fire Commissioners, in that they must ensure a full and complete understanding of their mandated role and responsibilities and be proactive in enacting their role and its accompanying responsibilities. The responsibility of this elected board dictates that they set clear expectations for the effective, efficient and safe delivery of fire protection services within the District. A major role-related issue is the lack of unity of command with respect to the position of fire chief. Management principles and practice dictate that there needs to be a unity of command, wherein each person reports to one supervisor only and one position is designated as the top position within the organizational hierarchy. The existence of two chiefs – one career and one volunteer - is problematic. It is imperative that the Board of Fire Commissioners address this situation promptly and not allow this dysfunctional situation to continue. There should be one fire chief, with reporting subordinate officers from both the volunteer and career ranks. This is a decision for the Board of Fire Commissioners to make, rather than one where we as consultants should recommend one approach, a career chief versus a volunteer chief. This decision, however, is of paramount importance and should be made with due diligence based on the establishment of a comprehensive job description and job specification for the position of fire chief. These documents will provide the necessary guidance to enable the Board of Fire Commissioners to make an appropriate decision with regard to the position of fire chief that best serves the needs of Jackson Township Fire District # 3 and its stakeholders.

SWOT ANALYSIS

SWOT Analysis is a process utilized by successful contemporary organizations, including fire and emergency services departments, to monitor relevant aspects of the organization’s internal and external environments in the interest of formulating realistic goals, objectives and strategies that will enable the organization to achieve its mission and to meet and where possible exceed the expectations of its stakeholders. Through SWOT Analysis the contemporary fire department can be proactive in terms of developing an understanding of its organizational strengths and weaknesses in light of the environmental opportunities and threats that it faces. This understanding furnishes the necessary insights to develop realistic plans for the future of the fire department through strategic planning. This proactive approach has been proven to enhance organizational success, in comparison to its alternative – a reactive stance wherein the organization does not concern itself with or plan for the future. Under such a management approach, the organization is basically expressing a willingness to accept any and all future outcomes uninfluenced by the absence of planning. Through adopting a proactive management approach, the contemporary fire department can properly position itself to pursue strategic opportunities that have the potential of contributing to its future success and its ability to more fully serve its stakeholders. The acronym SWOT stands for Strengths, Weaknesses, Opportunities, and Threats. A comprehensive SWOT Analysis provides the understanding of the organization and its environment required in the formulation of realistic organizational plans. The goal of SWOT Analysis is to provide the necessary information to ensure that organizational plans build on organizational strengths and minimize organizational weaknesses, while pursuing environmental opportunities and avoiding environmental threats. Through SWOT Analysis the contemporary fire department can enhance its effectiveness, efficiency and safety, as well as its ability to fulfill its mission. Organizational strengths include distinctions of the organization from which it can potentially benefit. Organizational weaknesses are organizational limitations from which the organization can potentially suffer harm. Environmental opportunities are positive situations in the environment from which the organization can potentially benefit. Environmental threats are negative situations in the environment from which the organization can potentially suffer harm. Organizational strengths and environmental opportunities thus contribute to organizational success, whereas organizational weaknesses and environmental threats have the potential of compromising that success. The strengths/weaknesses continuum ranges from organizational attributes that are major strengths to those that represent major weaknesses. Major categories of analysis in applying SWOT Analysis to a fire department include: apparatus; equipment; facilities; financial situation; human resources; internal climate and morale; leadership; personnel training and qualifications; response capability; response readiness (preparedness); and other organizational factors. The opportunities/threats continuum ranges from major environmental opportunities to major environmental threats. Relevant environmental elements in applying SWOT Analysis to a fire

department typically include: changing laws, regulations and standards; changing social and cultural norms; economic developments; fundraising potential; municipal support; new initiatives; new technologies; political developments; redistricting/regionalization/consolidation; and other environmental factors. As an integral component of this consulting engagement Technical Fire Services, Inc. performed a SWOT Analysis of the Jackson Township Fire District #3. The necessary data and information was assembled through the administration of survey instruments, conducting interviews with relevant stakeholder groups, and review of documents furnished by the Jackson Township Fire District #3 and related organizations. The findings of this SWOT Analysis are presented in this report and created the basis for the recommendations contained herein.

STAFFING Findings: Jackson Township Fire District # 3 is an organization in transition. One view is that this is a volunteer fire department supplemented by a handful of career staff. A second view is that this is actually two fire departments; career during the day hours and volunteer at night and on weekends. The third view, which was articulated by the fewest people, is actually the most accurate. This is a combination fire department whether applying the United States Fire Administration definition of at least one career member and one volunteer member, or the more stringent National Fire Protection Association (NFPA) definition of at least 15% career members and more than 15% volunteer membership. For purposes of this report, the project team is considering the organization a combination fire department. Jackson Township Fire District # 3 is a combination fire department that utilizes a limited cadre of career staff to supplement its volunteers during the daytime hours. Through the use of the career staff the Fire District seeks to provide coverage to respond to fires and other emergencies when an adequate number of volunteers are not available to respond. The desired level of response used for purposes of determining adequate staffing for deployment is to attain the required minimum staffing of 10 members within 10 minutes for 80% of their incidents. While the existence of the career staff has certainly contributed to attaining the required minimum staffing levels during the day, the current work schedule results in gaps in coverage during some periods during the day. Achieving the required minimum staffing is also problematic at times during the time periods covered by the volunteer staff given the nature of their status. While duty crews are utilized during the evening shifts covered by the volunteers, in the event of a working structure fire or other significant emergency incident the duty crew personnel complement may prove insufficient in terms of meeting required minimum staffing. Failure to address the aforementioned issues of appropriate coverage will compromise the effectiveness, efficiency, and safety of the Fire District, as well as its ability to meet the expectations of its stakeholders. Currently, the career staff has one crew of an officer and three firefighters on duty from 6:00 a.m. to 2:00 p.m. The remaining career members report for duty at 8:00 a.m. and work until 4:00 p.m. This schedule is followed five days a week (Monday through Friday) except for holidays as specified in the collective bargaining agreement between the labor unions and the Fire District. This means that there are four firefighters on duty from 6:00 a.m. to 8:00 a.m., then between 10 and 14 firefighters on duty between 8:00 a.m. and 2:00 p.m., then between 7 and 10 firefighters on duty from 2:00 p.m. and 4:00 p.m. There are typically no career members on duty after 4:00 p.m. although throughout the study it was typical to find the career chief on duty past the 4:00 p.m. time. The fluctuation in on duty presence is attributed to vacation time, sick time and off site training such as fire code enforcement classes. The career staff is comprised of one chief officer, three lieutenants, nine firefighters and one fire official of the local enforcing agency for fire code enforcement. The total uniformed complement is 14 members. There is also one clerical position.

The volunteer staff is comprised of approximately 45 members. The abridged roster provided to the project team reflected a membership of 51. The information provided on the web site for the volunteers reflect that there is a chief, an assistant chief, one captain, three lieutenants, a safety officer and an engineer. Recently, there has been one additional lieutenant position established in the volunteer officer ranks for a total of four lieutenants. For clarification purposes it should be noted that the lieutenants are distinguished as lieutenant and second lieutenants. Recommendations: Consider changing the work schedules of the career staff to 12-hour shifts in the interest of addressing the current gaps in coverage that exist at certain times during the day and of attaining required minimum staffing. Empower dispatchers and other appropriate emergency response personnel to upgrade calls when necessary by adding additional mutual aid resources, including personnel. Likewise, downgrade calls when appropriate based on the nature of the call and the corresponding personnel needs.

APPARATUS Findings: The Jackson Township Fire District # 3 has a fleet of apparatus housed at the two stations from which it provides fire protection services. The apparatus complement consists of three 1500 gallon per minute (gpm) pumpers (1986 Pierce, 2000 HME and 1993 Pierce), one 250 gpm brush truck (1995 Ford pick-up truck), one 95-ft. aerial truck with 2000 gpm pump (2008 Pierce), one rescue truck (1990 Ford), two pick-up trucks used as command vehicles by the career chief and the volunteer chief (2003 Ford F-250 and 2004 Ford F-250 respectively), one sport utility vehicle used by the assistant chief as a command vehicle (2005 Ford Excursion), one 2006 Dodge vehicle assigned to the fire official and one sport utility vehicle (1995 Chevrolet Suburban) designated as a spare vehicle for the District. Additionally, the District has a 1999 fire safety trailer used in its public education efforts. During the site visitation by the project team, several other box type trailers were noted at the District fire station on Kierych Memorial Drive. The District fleet inventory also shows a 1983 Hahn 1500 gpm pumper that was noted to be out of service permanently. The ladder truck was a recent addition to the apparatus fleet in 2008. Prior to that time the District did not have an aerial apparatus. The 1986 Pierce pumper is equipped with a tele-squirt device, but this is not considered an aerial device for truck company type operations. Additionally, the apparatus inventory provided reflects that the squirt device is out of service. Review of departmental records revealed that the Fire District has an effective program of requisite testing of its apparatus and equipment. However, it was found that a significant portion of the operating budget is being dedicated to vehicle repairs. Review of the layout of the equipment on the apparatus revealed a lack of consistency in the placement of equipment on the pumpers. The utilization of compartment space on the ladder truck could be improved by not carrying the confined space equipment, particularly given the lack of training and certification of department personnel in that technical rescue discipline. This compartment space could be better utilized for the placement of such equipment as that used in salvage and overhaul and other typical truck company operations. In at least one instance the layout of the equipment in addition to compromising the efficient placing of the equipment into service, has the potential of compromising response personnel safety. Specifically, the arrangement of small ground ladders in the ladder bed at the rear of the apparatus and the assorted hooks that contact the ladders when they are removed create the potential for serious injury when the ladders are removed because they strike the hooks that are hanging down and in the path of the ladder being withdrawn from the ladder bed. Currently the ladder truck is being used to respond to medical calls, which will contribute to a reduced service life of the vehicle. A more appropriate use of resources at the current time would be to utilize the pumpers as the primary response vehicle for emergency medical calls. However, in the future, if all of the District’s fleet assets were responding from a single location, it may be appropriate to consider the use of some form of utility vehicle for emergency medical responses.

The arrangement of equipment, tools and appurtenances on the apparatus is inconsistent from apparatus to apparatus. There are instances where the equipment is laid in a cabinet and not secured in place. When several cabinet doors were opened, some of the equipment started to fall out. To the extent possible each apparatus should be set up to facilitate its use by all appropriate Fire District personnel. This includes the location and layout of attack handlines and supply hose. Equipment in cabinets should be held in place by mounting brackets to prevent damage to the equipment and to prevent the equipment from dislodging and falling out when the cabinets are opened. There is one pumper equipped with a compressed air foam system (CAFS). This is Engine 5511, the 2000 HME. The use of compressed air foam as a primary extinguishing agent on structure fires has been advocated within the fire service because of its ability to reduce surface tension and permeate the outside surface of combustibles. This is the same attribute that makes CAFS desirable for large brush fires. Obviously there are also downsides to this firefighting approach. The most obvious of these is cost. There is also the maintenance of the foam system and the ongoing training that is associated with fighting fires using CAFS as compared to using water. Prior to purchasing another apparatus with CAFS a stringent evaluation program with identifiable criteria should be undertaken to determine if the use of CAFS technology is appropriate for this Fire District. The Fire District does not currently have a comprehensive apparatus replacement program and schedule that corresponds with the needs of the District in a cost effective manner. It will be important that in future apparatus purchases, the specifications developed fully comply with all appropriate government regulations and standards in the interest of avoiding potential liability. It should be noted that in order to avoid the potential of any appearance of impropriety, apparatus specifications should not be based on criteria obtained from a vendor. Rather, specifications should be developed using in-house expertise or a third party that has no interest in the sale or purchase of any particular make or model of apparatus. Recommendations: Rethink the appropriate apparatus to dispatch to the various types of calls, particularly the medical assist runs. Implement use of pumpers as medical response call vehicle. Develop a realistic apparatus replacement plan that corresponds to the present and future service needs of the Fire District. With five major pieces of apparatus that should have a reliable useful life of 20 years, the Fire District should expect to purchase one new apparatus every four years. The replacement of the 1986 Pierce pumper should be held off until 2012 so that the apparatus replacement cycle of one truck every four years can be strengthened. The replacement of the rescue truck should take place in 2016 and the 1993 pumper in 2020. The 2000 HME pumper should be anticipated for replacement in 2024. Points considered in establishing this timeline for replacement include the desire to create and maintain a 20-year replacement plan for apparatus, realization that as a new pumper is acquired and placed into service the older pumper will likely see less intensive duty as a first line apparatus, and the desire to maximize the reliable useful life of the Fire District’s fleet.

The Fire District has three chief officers. It is appropriate for each chief officer to have a command vehicle at their disposal outfitted with appropriate equipment and technology to perform the command function at a fire or other emergency incident. The transition to pick-up trucks with caps rather than more expensive sport utility vehicles as command vehicles may reduce the acquisition cost of new command vehicles. However, the design of command portion of the vehicle should be given serious evaluation prior to committing to the pick-up as the vehicle of choice for command vehicles. Create a more effective planning mechanism for the design of apparatus and placement of equipment. New apparatus acquisitions should be directed by the Board of Fire Commissioners. The board should establish the workgroups necessary to design new fire apparatus. These workgroups should reflect the entire make-up of the organization so that the views of all stakeholders are identified, considered and incorporated as appropriate into the design of all new apparatus. Establish consistent equipment placement on all of the pumpers, particularly during the design phase so that the location of hoselines and equipment is the same to the greatest extent possible on all apparatus. Anticipate the need for a consultant, rather than relying on manufacturers, to assist the Fire District in the design of future apparatus to ensure full compliance with NFPA 1901, as well as federal regulations. Finally, the Board needs to understand that changes to the fire apparatus standard (NFPA 1901) and federal regulations have had and will continue to have a significant cost impact on fire apparatus. The Fire District needs to monitor changes and provide their input during the public comment period so that associated cost considerations are taken into account during the development of standards and regulations affecting fire apparatus.

FACILITIES Findings: There are two fire stations servicing the Fire District. The Fire District owns and operates the fire station on Kierych Memorial Drive. The fire station on Larson Road is owned by the Jackson Township Volunteer Fire Company # 1. Because the ownership rests with the volunteer fire company as a private not-for-profit corporation, the project team is not making any comments regarding the future use of and/or disposition of this physical asset. That is a decision for the not-for-profit corporation to make. The Fire District also owns a parcel of vacant land on Brewers Bridge Road intended for future use. The current facilities of the Fire District appear to be undersized and overcrowded. Operating out of two stations increases maintenance expenses. The current facilities at both stations are showing aging and each has a significant amount of deferred maintenance that will need to be addressed over the next few years. There is a “two station” mentality that has produced a certain level of discontent between personnel at the respective stations in terms of facilities use, such as the training and exercise rooms. The Fire District is fortunate in that it currently owns the necessary property to construct a combined station to house the operations of both of the current fire stations. Such a construction project with require voter approval in the form of a referendum. Recommendations: Build a single new station on the property currently owned by the Fire District located on Brewers Bridge Road. This would provide for the consolidation of the human and physical resources of the Fire District. The implementation of a single station would result in synergies in such areas as training and response, and would enhance the working relationships between the volunteers and career staff. It would also result in a common ownership on the part of all members of the Fire District. Part of the construction cost could be offset by the sale of the existing fire station that is owned by the Fire District. This initiative would require voter approval and it would be necessary for the Fire District to inform and educate the electorate on the need for this new fire station and the corresponding benefits to the stakeholders of the Fire District.

TRAINING Findings: Member interest in training is reported to be high. This should allow for an open-minded approach to increased and improved training opportunities.

The fact that the department has invested in computer software and hardware, and maintained updated computer infrastructure, the keeping of training records in a computerized data bank should be a relatively easy accomplishment. Additionally, the updating of individual training records and the retrieval of such information should be made easier with the available computer system.

Given the fact that the department currently has existing property adjacent to the volunteer fire company on Larson Road, the opportunity for an improved training ground exists at no cost for land acquisition. While this location is the current home to the training tower with questionable stability, the fact remains that after the removal of that tower, the land remains and can be reused.

An additional strength is the career staff. Through task assignments as time permits, this staffing should be used, and supported by the administration, to create and maintain a pre-plan and an all hazards database of properties in the district. Through the use of digital photos and even video, hazards of existing properties should be documented. Construction hazards of new structures should be documented and information collected for training classes to increase the safety of all members.

One of the glaring weaknesses in regards to training is the lack of a department mission statement. The mission statement should spell out exactly what the department expects to be able to do, and be specific enough that the stated mission is definable and has goals that can be achieved. The resources must be purchased and the membership trained to the correct level to be able to safely and competently carry out the stated objectives.

Training records for the period 2004 through 2008 were reviewed.

A review showed that the majority of training classes consisted of typical weekly drills, New Jersey Division of Fire Safety CEU classes, and classes attended at conferences.

Several classes seem to be the same course, yet the hours are considerably different. Several class records fail to list the length of the drill. One training record indicates that a single member attended a 12 hour-long flashover simulator class, which seems questionable.

Some classes need to better described or explained. “Radiological” is listed for two different dates, once as a one hour class and once as a four hour class. This timing difference begs the question of what was covered and for what length? Examining the training record one if left to wonder what the two classes were about? One of the classes listed as taken by a member was “IS-1900.” To our knowledge there is no such class in the incident management series. The terrorist threat explosives class, the training officer seminar, and the pump operations class shown for 2007 all list zero attendance. If so, why are there training records for classes that were not taken or completed?

Some clarification on the records is needed. For example, the records show that on January 7, 2004, blood borne pathogens took place for one hour, radiological training took place for one hour, and right-to-know took place for one hour. Were these three individual classes at one hour apiece or three subjects that were part of one three hour class? The Trench Awareness class seems low at two hours, so a clarification is necessary to determine if this was an in-house refresher or an actual academy based class. An online check of the Monmouth and Ocean County Fire Academies web sites do not show “trench-awareness” as a listed class.

Some class dates show up more than once (i.e. CBRNE Awareness at eight hours and Blood Borne Pathogens training are both dated 1/26/09). Were these part of the same class, or two classes held on the same day at different times?

Training topics such “Drill,” “Drill-Monthly,” and “R.E.R.P” need to be explained.

The records submitted would also seem to indicate that there is a lack of a department-wide standard operating procedure for the training and certification of new apparatus operators. Additionally, there is also no standard operating procedure for the recertification of apparatus drivers. The implementation of a written operational procedure for training and certifying new apparatus operators, as well as a written procedure for the recertification of existing drivers, is warranted. Such standard operating procedures should include the driving, setting up of, and operation of all of the vehicles that each driver is expected to be able to operate. Such a procedure must include the driver being exposed to the manufacturer’s information on the vehicle, the appropriate New Jersey motor vehicle laws, as well as any other information specific to the roadway conditions for the District, and all department issued guidelines or orders pertaining to the operation of department vehicles.

During interviews with department members, it was stated that the members feel they are responsible to respond to and operate at what may be considered technical rescue type calls. This idea seems to have been reinforced with the purchase of at least some rope rescue equipment and confined space equipment. However, there seems to be a lack of fully trained members to safely carry out this type of call. And without having enough members to competently operate at such a response, it would seem there would not be enough members to drill with in order to maintain the knowledge, skills, and abilities required for a technical type of rescue.

The current structural stability of the training tower must be questioned. This building cannot be used for live fire training. Due to holes in the flooring, wood rot, and possible rodent issues, the tower seems to be used sparingly, if at all. This has led to an under-use of the training area adjacent to the firehouse.

While surveys and oral interviews have indicated that training is a priority, interviews with volunteer members of the department have indicated that a new, in-district, training location is not warranted. This “split decision” would seem to indicate that an overwhelming majority vote to support such a proposal would not be forthcoming.

Because there is no current mission statement, there is an opportunity to create one. This will allow the department to define what its role will be in addition to firefighting. Open-ended statements such as being an all-hazards department, or that the department will operate at all

man-made and natural disasters may not able to be supported due budgeting and manpower limitations. The creation of a mission statement that is goal oriented, definable, and logically manageable, will allow for the department to set operational benchmarks and justify funding for equipment and training.

The department also has the ability to collect additional funding for training and equipment through the collection of dedicated penalties under the enforcement of the New Jersey Uniform Fire Code. While the intent of the code is for violators to comply with the fire prevention regulations, this will not always occur. State laws allows for the collection of such penalties. As such, the department should not overlook those provisions, and should begin to have the Fire Official establish the process needed to collect those monetary penalties.

The fact that the department has a large parcel of land available for the possible future development of a new firehouse, should allow for increased training opportunities. The building of a new firehouse should include sufficient training classrooms. Additionally, any new firehouse should include an adjacent training ground and training building that will allow for hands-on, practical, training scenarios. The possibility of including a live fire training facility should be investigated.

Current training opportunities already exist at County level fire academies. Because of Jackson’s location, both the Ocean County and Monmouth County Fire Academies are relatively close by. Both facilities should be used as training resources, although some consideration may have to be given to the fact that there may be out of county fees that would have to be paid.

Because the District has already purchased confined space equipment, along with a trailer, and expects to answer such calls, the District should look to properly train and field a technical rescue team. However, such a team should be regional in scope, with staffing and funding being shared with the surrounding mutual aid departments. The opportunity exists to create a consolidated, funded, and staffed, regional technical rescue team.

With the property adjacent to the Larsen Road firehouse being able to be used as a training site, additional current training opportunities exist. This property can continue to be used until the development of a training ground at the new firehouse building site. While it is limited in size and the training tower should be removed, the property is already owned and is fenced in. Additional training props for technical rescue, roof operations, vehicle extrications, etc., should be developed and used. There would be a need to maintain the area and follow established safety and training regulations, as well as looking into any concerns about DEP regulations and the protection of surrounding properties. However, if the training refrains from causing water runoff and smoke conditions, the impact of such environmental regulations may be minimal.

It is apparent that there is a difference of opinion between the career staff and the volunteer members of the department. This problem has carried over into the training aspects of the department as well, in that the volunteers and career staff do not train together. A lack of training time with each other, and the fact that the members do not even train the same way to meet standard department issued fire-ground operational procedures, is a considerable problem. For fireground operations to run smoothly, with a minimum of confusion, and a competent attitude shared between career and volunteer members, it is imperative for all the members to train the same way, even if they can’t train together.

Another problem is with the keeping of training records. As previously stated, the submitted training reports are at least four years old, and the training hours seem to indicate different hourly totals for what seem to be the same classes. If a fire occurs, causing major damages or fatalities, the department must expect that it may have to defend itself in a lawsuit and have its training records reviewed by both investigators and attorneys. Having incomplete training records will make this process more problematic than it needs to be, and the District may have to face additional liabilities.

A final threat is available funding. If the budget does not support training initiatives, training may remain at a minimum accepted level, with advanced or technical training not occurring at all. With the recent re-evaluation and the statements that certain parts of the public do not support budget proposals, the department must redouble its efforts to get the budget passed, and include sufficient funding to support the department’s training needs.

Recommendations: Immediately discontinue all use of the District training facility. Remove the existing tower. Expand the use of the current training facility at the Larsen Road firehouse through the creation of new training props that more accurately reflect the service deliverables of the Fire District. Develop training requirements for all positions within the fire department, based on its scope of operations and mandated training requirements. Training that is required or mandated should be clearly understood and provided. This training should include driver/operator, rescue disciplines as appropriate, and officership. Where available, training should be supplemented and validated through personnel certification. All training completed by Fire District personnel should be fully and properly documented. Specifically the following should be done:

• Drill class records should list the location where the class was taken (i.e. in-house, a county academy, mutual-aid location, local seminar, national conference, or a NJ Division of Fire Safety class).

• The person(s) instructing the class should be included on the training record. • Records simply marked “drill” or “drill-monthly” should not be allowed. Length of

classes must be filled in. • Clarify aerial operations type drills as to what exactly was done (e.g. positioning for roof

access, water tower, etc.). • Clarify pump operations type drills as to what exactly was done (eg. pumped hand lines,

master stream set-up, drafting, etc.). • Clarify on drill records for SCBA training what was included, and whether it was hands-

on or classroom. • For specialized types of classes, such as radiological or elevators, explain exactly what

was drilled on. • Drill records should indicate who was driving, operating aerial devices, or operating the

pump in order to better track hours for driver training. • Training records should indicate starting times and ending times.

Training opportunities at regional training facilities should be fully investigated and utilized, as should the potential of constructing a new training facility within the Fire District, possibly in conjunction with the construction of a new fire station. Create and maintain a pre-plan and an all hazards database of properties in the district. Through the use of digital photos and even video, hazards of existing properties should be documented. Construction hazards of new structures should be documented and information collected for training classes to increase the safety of all members.

RECORDS RETENTION Findings: The Fire District was found to maintain good records in a limited number of areas, such as the external testing of apparatus and equipment, and the internal records maintained on SCBA. The deficiencies in training records mentioned previously are a significant issue that the Fire District must address. Inconsistencies exist in the recordkeeping for the career and volunteer staffs, with better records being maintained on the career personnel. A specific and detailed records retention policy is not being utilized, with the potential for significant monetary costs from a civil action or failure to comply with PEOSH requirements when asked to produce records indicating regulatory compliance. There are no individuals tasked with the responsibility of maintaining records for regulatory compliance. Additionally, there is no individual designated with the responsibility of regulatory compliance. While there are some members of the Fire District who had knowledge of certain regulatory or statutory requirements, few could articulate the requirements. The overall and prevailing response to inquiries regarding this area was a general lack of concern. Unfortunately, this has the potential for significant financial harm to the Fire District. This would include items such as the federal Fair Labor Standards Act, the New Jersey Public Employee Occupational Safety and Health regulations, New Jersey Uniform Fire Code requirements relative to fire code enforcement, incident management, and training; and federal OSHA regulations as enforced by the New Jersey Department of Labor including the General Duty clause Recommendations: Develop and implement a comprehensive recordkeeping and retention policy. Initial guidance for determining the length of time that records should be retained should be sought from the following: regulatory authorities having jurisdiction, auditors, NJ Division of Local Government Services (especially for financial records), NJ Civil Service Commission (for personnel related items), NJ Division of Fire Safety (for fire code enforcement related items, incident management related items, mutual aid agreements, and training facility related items), insurance carriers, and private organizations that have an interest including the Insurance Services Office (ISO) for insurance rating purposes. Improve information management through the use of computer technology in data collection and record maintenance. To the extent possible make the transition from paper to electronic records, with proper provisions for backup.

OPERATING PROCEDURES Findings: While the Fire District has a limited number of standard operating procedures or guidelines, it was found to lack the comprehensive set of SOPs necessary to provide the necessary guidance to ensure operational effectiveness, efficiency, and safety. The lack of a comprehensive set of SOPs as well as a failure to train on existing SOPs has resulted in significant inconsistencies in operations based on the time of the emergency incident and the personnel responding to that call. On a positive note, steps are currently underway to establish operating policies and guidelines in certain areas such as response protocols. Recommendations: Develop a comprehensive set of SOPs based on the department’s scope of operations. Utilize available resources in the development of personnel, including the participation of Fire District personnel in the interest of establishing ownership, thus contributing to successful implementation. Incorporate best practices in the development of policies and procedures. Provide and document the training of all appropriate personnel in these policies and procedures.

ORGANIZATIONAL STRUCTURE Findings: The existing organizational structure that incorporates two chief fire officers, one for the career staff and one for the volunteers, is problematic in that it violates the established management principle of unity of command. As discussed in the commentary included in this report on role-related issues, the current situation has resulted in the role-related issues of both role ambiguity and role conflict. The qualifications required for the various officer positions also lack clarify and should be defined. The Fire District Board of Fire Commissioners has a responsibility to the electorate of the Fire District to fully understand, embrace, and enact the responsibilities of their office. Addressing this organizational structure issue is integral to the successful provision of fire protection services within the Fire District. The roles and responsibilities currently being performed by the career lieutenants seem to be more aligned with those associated with those of a captain. Consideration should be given to changing the title of these career officers from lieutenant to captain to better reflect the responsibilities they have. Additionally, a change in title would allow for the career officers to be assigned some additional duties, particularly in the areas of training and pre-planning, The project team also believes that the volunteer officer staff should be modified. Currently there is one captain and four lieutenants. There are also positions for safety officer and engineer. There is a need to have a responsible individual to serving as the training officer for the volunteer staff as well as the career staff. The project team believes that this should be a person at the rank of captain. We also believe that the captains should also be responsible for additional administrative duties including implementation of health, wellness and safety programs. We believe the volunteers should have at least two captains along with the four lieutenants. This would also create a larger officer pool for the duty crews currently used for certain types of incidents and responses. Recommendations: Restructure the organization so as to have a single fire chief with subordinate officers reporting to this position. Complete job descriptions and job specifications should be developed for each position within the fire department, including its officers. These job descriptions should cover all positions, whether staffed by volunteers or career personnel. The individual selected to serve as fire chief should meet all articulated qualifications for this instrumental leadership position and be prepared to fully execute all of the accompanying “inside” and “outside” roles of this position.

DEMOGRAPHICS Findings: This study has examined the current development trends and potential development in the future within Jackson Township, along with its correlation to the impact it may have on Fire District # 3. Like all New Jersey municipalities, Jackson Township must be cautious in its land development in order to prevent overdevelopment and strain of vital services, as it pertains to this study most specifically, fire service protection. Even though Jackson Township Fire District # 3 has a primary response area within its designated boundaries, this study has analyzed the land use of the entire Township given that Fire District # 3 responds throughout Jackson Township and is therefore impacted by land use changes and decisions Township-wide. According to Jackson Township’s Master Plan dated July 22, 2009, there has been significant residential development over the last 10 years within the community. The Master Plan notes 2000 Census data showing a population of 42,816 residents and a current estimated population of 55,000 residents, yielding an estimated population increase of 12,184. This population increase is a result of the construction of 4,775 housing units, of which 3,000 are age-restricted housing. An interesting side note is that the Fire in New Jersey report issued by the New Jersey Division of Fire Safety reflects an equal population distribution throughout the township for all four fire districts. In reality, Fire District 3 has the largest population of the four fire districts. Confined to the boundaries of Fire District # 3, Jackson Township has seen some of this projected development in the past two years. Furthermore, a “Build Out Analysis” included in the Master Plan confirms further potential development in the form of an additional 7,565 housing units, 4.9 million square feet of commercial space, and 9.7 million square feet of industrial development. This projected development is based on current zoning regulations and will have an impact on Fire District # 3 in terms of pre-planning, fire prevention services, training and real emergency responses. Beyond the potential development allowed by current zoning regulations, Jackson Fire District # 3 must remain aware of further development that can come from obligations prescribed through the State of New Jersey’s Council on Affordable Housing. Currently, under Rounds One and Two of the Council on Affordable Housing’s requirements, Jackson Township is obligated to provide a certain quantity of housing units. Round Three of its obligation remains undetermined and is currently in the proceedings of the Court. Obligated affordable housing units can be assumed to be calculated into the potential 7,565 units previously projected. However, this cannot be a realistic assumption due to the historic granting of variances and density bonuses to develop such housing. Developers in New Jersey have used variances, density bonuses, and the “Builder Remedy” lawsuit as tools to create larger scale developments in order to offset their own costs associated with building affordable housing units. Certification of an Affordable Housing Plan by the Council on Affordable Housing is said to insulate municipalities from such tools. The future of Jackson Township’s obligation remains unknown until final decisions on Round Three are provided by the Court.

While there is great potential for the development to occur, the likelihood of such is currently reduced due to the current national economic climate. However, Jackson Township Fire District #3 should not ignore the possibilities of large scale projects, but instead use this time of economic decline as an advantage to establish long-term strategic plans to pre-plan and respond to new developments. One additional development that should benefit the level of fire protection in new housing is the anticipated adoption of new construction code regulations that will require one- and two-family homes to be equipped with automatic sprinkler protection. The project team found that the current level of site plan review was limited in scope. In large part, comments are limited to the location of fire hydrants and the establishment of fire service access roads. The Fire District should participate more fully to assure that critical fire service concerns are addressed at the site plan, planning board and zoning board levels. Often times, these concerns can be codified in the adopting resolutions when projects are approved. The project team also examined the public water supply due to the inherent need for water to fight fires. The Jackson Township MUA Master Plan Final report dated April 2009 by O’Brien & Gere states “The total supply available to support the Authority system is approximately 5,255 gpm (7.6 MGD). This quantity is sufficient to meet the current annual average day demand of 3.4 mgd, and the peak day demand of 6.4 mgd.” One of the critical points taken from this statement is that the local MUA has a total available supply of approximately 5,255 gpm. This flow is for the entire township. This means that pre-fire planning needs to take into account the volume of water that might be needed for a high challenge type fire and plan accordingly. This is also an area of concern and consideration when evaluating new developments, particularly those that have significant fire challenges. That same report states “with respect to water supplies, Critical Supply Management Areas continue to exist throughout Jackson Township. These areas were defined and established due to the increase of salt water infiltration into the New Jersey Coastal Plain.” The sensitive nature of the public water supply has a significant impact on how the fire service addresses certain types of incidents that are responded to and the actions or mitigation activities that are implemented. Where the potential for groundwater pollution to the aquifers may occur as the result of a fire or hazardous materials release, the fire service in Jackson Township Fire District # 3 should have in place operational protocols that are designed and intended to limit the impact that those types of incidents. As an overall part of managing the water supply for fire protection purposes, the fire service has an equally important role in working with the municipal utilities authority to protect the water supply. The Fire District should work with the MUA to develop, establish and implement operational protocols on incident management that protects and preserves the water supply. The MUA does have an aggressive plan in place for maintenance, repair and upgrades to its infrastructure. This includes annual flushing of fire hydrants. This information should be documented for future Insurance Service Office surveys.

Recommendations: Fire District # 3 should establish a stronger relationship with the Township’s Zoning and Planning Board, allowing for more detailed reviews of applications and an open dialogue of how applications will affect the fire service. This can be accomplished through staff involvement and reviews, and assignment of personnel to appear and provide comment to the applicable Board. The Fire District should seek to become represented on the planning, zoning, and site plan advisory boards. The fire district should work with the MUA to develop, establish and implement operational protocols on incident management that protects and preserves the water supply.

RECRUITMENT AND RETENTION Findings: The Fire District lacks a proactive and continuing program in volunteer recruitment and retention. When asked what the recruitment program consisted of, three items were identified. They were a Length of Service Award Program (LOSAP), use of the classified section in the local newspaper, and posting of signs throughout the fire district. A number of the volunteers appear complacent and satisfied with the current volunteer cadre and thus do not see the need to actively seek to recruit and retain volunteer members. Several volunteers voiced the position that the fire district does not have the funds necessary to equip new volunteers with personal protective equipment so it would not pay to seek new volunteers. Frankly, this is a rather narrow view. The project team does not share the view point held by the members of the volunteer company relative to recruitment of new volunteers. With the increasing demands and requirements on volunteers, constant recruitment must be a priority of the Fire District. Few individuals could articulate the benefits available to a new volunteer. Nor could they articulate the benefits available in the event of a Line of Duty Death. To assist in this area, the project team has attached to this report in the appendices information relative to benefits afforded to volunteers and career firefighters under a variety of circumstances. It should be noted that this is not an all inclusive or exhaustive list of benefits. However, the information does serve as a good foundation for presenting currently available benefits. As existing members transition from the active rolls to a less active role, or exit the fire service entirely, their replacement by a new member while maintaining statistical neutrality does not translate into a one-for-one replacement. As an existing member leaves, that member leaves a certain experience vacuum that cannot be expected to be replaced by a new member. Thus, it is critical that the fire district recognize the need to constantly be recruiting and bringing in new members. Further, as service demands continue to grow on the fire service, it will be necessary to have a cadre of competently trained personnel to respond to and deal with a variety of fires and emergencies. One area where volunteer recruitment should be targeted would be weekday hours. While additionally volunteers would be desirable regardless of when they are available, the number of volunteers available during weekday hours is significantly lower than during other times of the day or week. While a great deal of attention has been paid to recruitment, it is just as vital to remember that retention of existing volunteer personnel should be a high priority for the Fire District. It is difficult at best to calculate the value that any individual possesses until the loss of institution knowledge is fully in force when a member leaves the organization. Suffice to say that the years of knowledge and experience possessed by any member cannot be replicated instantaneously in any new member. In reality it may take several years before a new recruit is capable of performing without constant oversight and direction. For these reasons, the Fire District should continue to work extensively to retain as many of their existing volunteer firefighters as possible.

Recommendations: Develop and implement a comprehensive and continuing volunteer recruitment and retention program. Consider new classes of membership as appropriate, such as junior members and members who volunteer for non-emergency duties such as maintaining the website, fundraising, or public education. Organizations such as the National Volunteer Fire Council and Fire Corps are important resources available to assist in these initiatives.

RESPONSE PROTOCOLS AND TIMES Findings: Currently the Fire District has no adopted protocol for acceptable response and deployment to fires and emergencies. When no such protocol is adopted, nationally recognized criteria is usually examined following an incident where response is called into question. Understandably, it is better to have a well thoughtout protocol than to leave something as important as response and deployment evaluation criteria to chance. For this reason, and to establish a widely accepted response and deployment criteria, the project team turned to the nationally recognized NFPA standard 1720-2004 edition, Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Volunteer Fire Departments. This document covers those fire departments that are substantially volunteer such as this Fire District. NFPA 1710 was not used since that document applies to substantially career fire departments, which this fire district is not. The 2004 edition of the standard was utilized since this standard was the current standard when the study project was initiated. The staffing and deployment criteria of NFPA 1720 establish staffing and response times based on demand zones (urban, suburban, rural and remote) and population demographics. For purposes of this study, Jackson Township Fire District # 3 is considered a suburban community having a population demographic of between 500 and 1000 people per square mile. This translates to a staffing and deployment model of 10 firefighters within 10 minutes for 80% of fires and emergency incidents. Because the majority of fires and emergency incidents responded to by the Fire District occur during the workday hours of the career staff, most incidents are responded to in less than 10 minutes time. During the year 2008, the Fire District responded to a total of 1,050 incidents. During 2007, the Fire District responded to 1,058 incidents. Of those responses, 523 in 2008 were emergency medical calls. In 2007, 502 were emergency medical calls (based on NFIRS data supplied to the New Jersey Division of Fire Safety). For each year, these figures represent almost half of the total responses for the year. The standard allows for a lower number of responders for emergency medical calls based on service needs established on a state by state basis. Calls responded to between the weekday hours 6:00 a.m. and 8:00 a.m. reflect a challenge in meeting the deployment criteria. During this period, only one crew of three career firefighters is on duty. Calls responded to by the career staff between 8:00 a.m. and 2:00 p.m. reflect a sufficient number of members responding in accordance with the performance criteria of the standard. Between 2:00 p.m. and to 4:00 p.m. the response is within 10 minutes but the number of firefighters attending is below performance criteria. Response by the volunteer members generally fails to meet the response criteria. This is not necessarily a negative situation. The standard contains a mechanism whereby a fire department may conduct a risk management analysis to determine the risk versus benefit on certain responses. Where there is a negligible potential for negative consequence and the loss of life or property are not likely, the fire impact management model suggests that rigid adherence to the

staffing and deployment criteria may be further scrutinized to determine if alternatives may better reduce or limit risk to occupants, the structure and fire department personnel. One example would be response to a report of a carbon monoxide alarm sounding. If all people have successfully exited the structure and there is no danger to the occupants, the risk to the responding fire department could be reduced by altering the response to one that eliminates the use of emergency lights and sirens effectively slowing the responding fire apparatus. Another example would be the use of duty crews, as is the current practice by the volunteers, to certain types of calls, such as outside brush fires or fluid spills at a motor vehicle collision. The staffing levels of the duty crew are below that established by the criteria in NFPA 1720, but may be totally acceptable given the particulars of the incident. All of this said, the standard anticipates that a risk management plan and use of the fire impact management model are done prior to responses and not merely ignored. Unfortunately, based on the data provided, it does not appear that any such risk management exercise is practiced relative to fire responses and as such, the Fire District is not meeting the benchmark criteria of NFPA 1720. A close examination of the fire incident data for the years 2007 and 2008 reveal that a significant number of incidents are classified as hazardous conditions, good intent calls or false alarms. For 2007 the figures are 112, 95 and 242 respectively out of a total of 1,058 (42.43%). For 2008 the figures are 108, 104 and 210 respectively out of a total of 1,050 (40.19%). The number of actual fire calls responded to for either year is approximately 8% of the total call volume (83 of 1,058 for 2007 and 84 of 1,050 for 2008) leading one to speculate as to the accuracy and quality of the data. Incidents can frequently be misclassified due to misunderstandings of the fire incident reporting system. As an example, a smoke detector that is set off by cooking smoke should be classified as a fire, not as a hazardous condition, good intent call or false alarm. The fact that no fire was visible or was out on arrival does not mean there was no fire. The higher than expected number of hazardous conditions, good intent calls and false alarms suggests that there may be a need for additional training classes on the fire incident reporting system to enhance data quality. Recommendations: The Fire District should be aware that it will be judged based on national recognized criteria. It should adopt NFPA 1720 and use it as a basis to establish response time targets. The Fire District should consider the use of the risk management plan and fire impact management model contained within NFPA 1720 as part of the community fire risk reduction plan. The Fire District should consider conducting additional training sessions on the fire incident reporting system to assure that the data collected and used for planning purposes is accurate and of a high quality.

FIRE PREVENTION/CODE ENFORCEMENT Findings: The fire official has created a master plan and a mission statement for the Bureau of Fire Safety. These documents identify the duties and responsibilities of the fire official and the Bureau of Fire Safety for the Fire District. It should be noted that all properties are subject to the provisions of the New Jersey Uniform Fire Code with the exception of owner occupied one- and two-family dwellings. The Fire District has elected to establish a local agency known as the Bureau of Fire Safety to act as the local enforcing agency (LEA) for the fire district. This bureau is staffed by the fire official. One of the career firefighters assists the fire official with primary responsibility for public fire safety education. Additionally, there are at least five members of the career staff that possess state certifications as Fire Inspectors and are permitted to conduct inspections of life hazard uses. The project team notes that Fire District # 3 provides fire inspection and prevention services for both itself and Fire District # 1. As a result, Fire District # 3 has a total of 562 inspections to conduct. The breakout is as follows: District 3 Life Hazard Uses – 80 Non-life hazard uses – 325 Total – 405 District 1 Life Hazard Uses – 38 Non-life hazard uses – 119 Total – 119 These totals do not include re-inspections following the issuance of a Notice of Violation and Order to Correct to confirm abatement of fire code violations identified during the initial inspection. Life Hazard Uses (LHU) are properties and occupancies identified by the New Jersey Division of Fire Safety that require registration with the State of New Jersey, payment of an annual registration fee to the State, and mandated inspections according to a schedule stipulated in the State fire code. Local enforcing agencies (LEA) typically act as the enforcing agency for conducting the inspections of these Life Hazard Uses with the State rebating 65% of the registration fee to the LEA to offset the expense of conducting these inspections.

District # 3 Life Hazard Uses Rebate from State 2004 60 $10,214.42

2005 67 $9,061.32

2006 76 $10,372.60

2007 75 $11,670.14

2008 80 $13,311.99

District # 1 Life Hazard Uses Rebate from State 2004 No data available No data available 2005 24 $4,436.81

2006 27 $4,410.50

2007 28 $4,250.34

2008 38 No data available

Non-life Hazard Uses are those properties subject to inspection under the Uniform Fire Code that are not required to be registered with the State. The local enforcing agency may establish a fee for each property to offset the cost of conducting inspections and fire code enforcement.

District # 3 Non-life Hazard Uses Local fees collected 2004 302 $16,442.00

2005 307 $21,130.00

2006 290 $20,075.00

2007 300 $18,857.50

2008 325 $19,620.00

District # 1 Non-life Hazard Uses Local fees collected

2004 No data available No data available 2005 46 $2,516.60

2006 112 $7,140.00

2007 128 $6,805.00

2008 119 No data available

The Bureau issues permits required under the Uniform Fire Code (UFC). These permits generate revenue known as permit fees. The fee schedule is established in the fire code. The fee is to assist in offsetting the cost of inspections associated with the permit activity.

Dist. 3 Permits Dist. 3 Fees Dist. 1 Permits Dist. 1 Fees 2004 45 $1,226.00 No data No data

2005 42 $1,380.00 12 $336.00

2006 45 $1,464.00 9 $378.00

2007 54 $1,421.50 12 $378.00

2008 46 $1,798.00 No data No data

Fire code enforcement appears to have been extremely effective in preventing fires in occupancies subject to inspection under the Uniform Fire Code. New Jersey has a very stringent Uniform Fire Code that provides enforcement personnel with a variety of tools to achieve successful code compliance. These tools include empowering the fire official with the ability to assess financial penalties when compliance is not forthcoming or violations are repetitious. The fire code regulations require both a penalty account and a dedicated penalty account. It was found that the Fire District does not currently have, and appears to never have had, a dedicated penalty account. As can also be noted from the data listed below, the fire official issues few penalties in relation to the number of inspections conducted.

Penalties

Dist. 3 No. Issued

Dist. 3 Collected Dist. 1 No. Issued

Dist. 1 Collected

2004 2 $37.50 No data No data

2005 9 $2,400.00 0 $0.00

2006 6 $300.00 0 $0.00

2007 30 $1,100.00 7 $50.00

2008 33 $1,112.50 No data No data

The fire official articulated that he was not familiar with the dedicated penalty requirements of the Uniform Fire Code. That said, the code mandates that dedicated penalties be assessed when the initial penalty for a fire code violation is issued. These funds are required to be placed in a separate fund and they may only be used to supplement the regular Fire District budget for equipment and training. The lack of penalty assessment means that the taxpayer must continue to fund the majority of expenses related to the Fire District. The project team believes that this alternative revenue source should be more vigorously pursued and utilized.

The fire official has requested that the Fire District promote one firefighter to the position of Fire Prevention Specialist UFD and serve full time in the Bureau as a fire inspector. This individual would also serve as the back-up to the fire official and be permitted to act in that capacity in the event the fire official is not available. Concurrently, the fire official suggests that the in-service company inspection program be reduced to enable fire suppression personnel to perform other duties. The project team does not agree with the approach articulated by the fire official. One reason offered as support for the proposal was the workload of the Bureau. The fire official mentioned that approximately 50% of his time is taken up by clerical duties associated with the Bureau. The project team believes that a technology solution may be the better way to address the time constraints currently encountered by the fire official. Further, the project team believes that in-service inspections by fire suppression personnel are beneficial from the fire code enforcement point of view and also from a pre-fire intelligence and pre-fire planning point of view. Additionally, there is nothing that prevents the Fire District from designating individuals to serve as the back-up or stand in for the fire official provided the individual possesses the appropriate certification. The Fire District has articulated a commitment to public education and designated an individual with primary responsibility for this area. The program is, however, limited in scope as is participation of the fire department’s members in its public education programs. There is a desire on the part of the fire official as articulated in the Bureau of Fire Safety Master Plan to expand the public fire safety education effort. A number of proposals have been identified and include:

Participate in the Operation Save-A-Life smoke detector distribution program. The Master Plan suggests providing and installing free smoke detectors to seniors and occupants in need. The smoke detectors are provided free of charge from the New Jersey State Division of Fire Safety. We concur with this plan and suggest that it also include distribution when fire apparatus respond to the residence and find the smoke detector missing or inoperative. A supply should be kept on responding fire apparatus and in each command vehicle for distribution.

Implement a program to install smoke detector batteries in senior developments. While a laudable goal, this activity would be labor intensive and require extensive scheduling to complete. This is an activity where establishing a public education group using the Fire Corps concept may provide better results. These groups could be designated to interact with local community organizations rather than using existing fire suppression personnel from the career and volunteer staff.

Expand the juvenile firesetter program. There is no doubt that many fires are the result of juvenile activity. Early intervention has been an effective tool in reducing the rate of recidivism of juvenile firesetters. However, the more successful programs are those that are directly associated with providers capable of conducting intensive intake interviews that are trained at detecting root causes of this activity. The project team supports

expanding this program but only if the appropriate approach is taken utilizing trained intake professionals.

Finally, the public fire safety education effort of the Fire District should be more fully examined to assure that the design goals of each program component are directed towards addressing and reducing fire problems rather than reinforcing response behaviors after a fire has occurred. The residents of the fire district would be better served through the prevention of fires rather than teaching what to do after a fire has begun. Recommendations: Develop and implement a comprehensive public education program in response to a community risk analysis and train and equip more personnel to participate in this important initiative. Partner with stakeholder organizations in public education initiatives and activities. Encourage all career staff to achieve at least the “fire inspector” certification. Increasing the number of individuals qualified to perform inspections will ensure fire code enforcement and that the relatively positive fire loss experience will continue to be maintained. Establish a dedicated penalty account, thus reducing certain cost impacts on the taxpayers through the creation of an additional revenue stream for training and equipment.

RISK MANAGEMENT Findings: There have been limited injuries to response personnel over the past few years. In fact, for the years 2007 and 2008 there have been a total of three injuries reported in the fire incident reporting system. This is certainly a desirable position given the level of loss potential that exists based on the response level of the Fire District. However, this positive loss experience may not be deliberately attributable to an effective and coordinated risk management program. Rather, the realized loss experience may be the result of being rather fortunate. The Fire District lacks a comprehensive risk management program that addresses many issues that a provider of fire protection services is faced with. There are operating procedures in place for some items, but these procedures often fail to completely and adequate address loss potentials. One example is the qualification of new drivers and operators. Currently drivers and operators are qualified based on attendance at specified training courses. However, there are no established performance criteria being used to qualify an individual’s competency. Another example of the need for a comprehensive risk management program is incident response criteria. As discussed in the staffing and deployment section of this report, reducing response levels for certain types of incidents may be appropriate, such as a carbon monoxide call where it is established that all people have evacuated a building and are not exhibiting any indications of distress. Continuing to respond in emergency fashion unnecessarily exposes the responders and the public to additional risk and threat of loss where a reduced response will limit or eliminate certain aspects of the risk or loss potential. The primary cause of firefighter line of duty deaths is cardiac-related incidents. Firefighters in New Jersey have an outstanding opportunity to address this issue by participating in the Buscio medical examination program offered through the Deborah Heart and Lung Center. Firefighters and their spouses may obtain an annual cardiac and pulmonary examination at the center with no out of pocket expense whatsoever. As part of a coordinated health and wellness program the Fire District should encourage every firefighter to participate in this extremely worthwhile program. Currently, few members participate. The benefits of having heart-healthy firefighters should be apparent to anyone. The risk management plan should also be used to identify loss cost potentials and establish mechanisms to reduce, eliminate or avoid these loss cost potentials. Specifically, the Fire District needs provide clear support of the line officers regarding policies concerning the use of personal equipment in contravention of established operating procedures. This would include non-compliant personal protective equipment, personal portable radios or personal tools where officers and especially chief officers have established policies for what should and should notbe used. Allowing individuals to used non-compliant or personally owned equipment without permission may establish an expectation on the part of members that should the items be damaged the Fire District would pay for their replacement. Even more critical though, is the lack of control regarding maintenance and functionality of personally owned equipment.

In short, the Fire District would benefit from the implementation of a comprehensive risk management program. Recommendations: Develop and implement a comprehensive risk management program for the Fire District. The absence of such a program of risk management and loss prevention could contribute to the incurrence of significant losses in a relatively short period of time. Establish a regulatory compliance program and designate one individual to coordinate all documentation necessary to demonstrate regulatory compliance.

SERVICE DELIVERY Findings: The mission of the Fire District has evolved over time. At a point in time many years ago, the fire department was called when there was a fire and the fire had to be extinguished. As the population of the township grew, service demands on the Fire District also grew. There is now an expectation on the part of some within the community that the fire department will respond to any and all emergencies (however that term is defined) and resolve the situation. As such, the Fire District now responds to utility emergencies for gas, electric and water; motor vehicle collisions with entrapment or fluid spills and releases; hazardous material incidents involving leaks, spills, and releases; an assortment of natural disaster incidents involving weather related problems including wind, rain, flooding, subsidence, earth movement and lightning strikes; collapses, entrapments and medical related incidents. The service capabilities of the Fire District are extensive, but not all encompassing. The reality is that in some cases the need far out exceeds the available resources. Additionally, there are some calls that are best identified as high impact/low frequency type of incidents that might be better dealt with on a regional basis or by another service provider. There is no doubt in anyone’s mind that the Fire District needs to respond to fires for purposes of control and extinguishment. In the event that a fire is of a magnitude that the local resources of the Fire District are not capable of controlling the fire, mutual aid can be summoned to assist. The local resources currently available for technical rescue and hazardous material response are extremely limited. In addition to having limited equipment for these types of incidents, the number of trained personnel is also limited. The project team believes that the best approach for these types of highly skilled, high impact and low frequency incidents would be for the Fire District to work with the other districts within Jackson Township and surrounding municipalities to create a regional response capability where the cost for personnel, training and equipment is shared. There is a benefit to the community of the career staff responding to assist on medical calls during the day. Response to assist on all medical calls, however, may not be justifiable. Currently, career firefighters respond with the contract EMS provider to render medical aid on all calls when the career staff is working. The project team observed significant lag time in dispatching for both the EMS provider and the assigned Fire District responders. The project team believes that the Fire District should continue to have career personnel respond on medical calls where any life threatening situation exists and immediate medical intervention is indicated. A medical professional should be consulted to establish the appropriate level of care necessary to dictate response by the Fire District. The project team also believes that the Fire District should discontinue the practice of using the aerial ladder truck for EMS calls. Some members of the public indicated a desire that the Fire District provide resources for incidents such as power outages, flooded basements, and property salvage when retail providers are not available or open for business. Others felt this was not the responsibility of the Fire

District and that homeowners should plan on their own for such emergencies. If the Fire District decides to embark on a program of providing for such needs, the project team believes that strict criteria needs to be established to assure that program goals are met. An example may be that the Fire District may elect to provide an emergency generator during power outages to a residence that requires electric power for a life assist device such as an oxygen generator or a dialysis machine. The Fire District may further define that they will offer this service once and then provide notice to the resident that they are expected to provide for themselves in the future and to make appropriate preparations. Conversely, the Fire District may decide that these are services that the Fire District should not provide and communicate this to the public. The Fire District currently has certain communication inefficiencies in terms of communicating to fire department members and other stakeholders within the Fire District. This lack of effective communication to external stakeholders can lead to misunderstanding and a lack of clarity regarding the services provided by the Fire District to the community. An uninformed or misinformed electorate may not be as responsive to supporting the Fire District as is desired or necessary. In effect, the Fire District needs to examine its communications program. The advent of new technology provides the Fire District with unique opportunities to deliver critical and important information to its stakeholders. The project team believes that the Fire District needs to go beyond the existing web-site to more inclusive and direct communications methodologies. To this end, we believe that the Fire District should seek a person from the community to become its technology champion who could design, develop and implement a coordinated communications program that encompasses current and future technologies. This could also be a means for expanding the public fire safety education program. Recommendations: Adopt a proactive approach to communicating with members and external stakeholders. Strive to build a high level of stakeholder relations and resulting support. Develop a mission statement and strategic plan based on stakeholder input that provides the necessary strategic direction for the Fire District and its personnel, whether volunteer or career. Work with the other fire districts within Jackson Township and surrounding municipalities to establish regional response capabilities for high impact low frequency type incidents such as hazardous material calls and technical rescue calls. Continue to have career personnel respond on medical calls where any life threatening situation exists and immediate medical intervention is indicated. Consult a medical professional to establish the appropriate level of care necessary to dictate response by the Fire District. Discontinue the practice of using the aerial ladder truck for EMS calls. Consider the merit of assuming an enhanced role in providing EMS services as the contract for these services is renegotiated.

Consider establishing a fee for services, including cost recovery from insurance companies, in the interest of reducing the tax burden on residents of the Fire District. Pursue discussions with other fire districts within Jackson Township to ensure that they are sharing and contributing to operating costs proportionately to the services and benefits that they are receiving. Utilize technology, including township-wide e-mails and a websites, to effectively and efficiently communicate with members and to other stakeholders of the Fire District in an accurate and timely manner.

Appendix A

Standards for Firefighters in the State of New Jersey

New Jersey Administrative Code 12:100 et. seq.

SUBCHAPTER 10. STANDARDS FOR FIREFIGHTERS

12:100-10.1 Scope; standards information

(a) This subchapter shall apply to all public employment as provided below:

1. This subchapter contains requirements for the organization, training, and personal protective equipment of fire service organizations whenever an employer establishes them.

2. The requirements of this subchapter shall apply to all fire service members in the public sector performing structural fire fighting.

(b) This subchapter shall not be applicable to:

1. Construction, agriculture and maritime employment; 2. Airport crash rescue; or 3. Forest firefighting operations.

(c) The CGA and NFPA standards incorporated in this subchapter by reference may be obtained by contracting the issuing entities at the addresses listed in N.J.A.C. 12:100-17.3. 12:100-10.2 Definitions (a) The following words and terms, when used in this subchapter, shall have the following meaning unless the context clearly indicates otherwise. "Approved" means the term as defined at N.J.A.C. 12:100-2.1. "CGA" means Compressed Gas Association. "Confined space" means the term as defined at 29 CFR 1910.146(b). "Damaged equipment" means equipment which has been affected by external forces such as, but not limited to, mechanical, thermal, chemical or hydraulic, to an extent whereby the equipment no longer performs its original function to the extent required for the users' safety. "Education" means the process of imparting knowledge or skill through systematic instruction. "Employee" means the term as defined at N.J.A.C. 12:100-2.1. "Employer" means the term as defined at N.J.A.C. 12:100-2.1. "Enclosed structure" means a structure with a roof or ceiling and at least two walls which may present hazards to employees, such as accumulations of smoke, toxic gases and heat, similar to those found in buildings.

"Fire brigade" means an organized group of firefighters who are public employees who have an obligation to fight fires but who may be assigned to other duties. "Fire department" means an organized group of employees organized by a public employer who are knowledgeable, trained and skilled in basic firefighting operations. "Firefighter" means a member of the fire service who engages in the physical activity of rescue, fire suppression or both, in buildings, enclosed structures, vehicles, vessels or like properties that are involved in a fire or emergency situation. "Fire service" means a fire department or fire brigade. "Helmet" means a head protective device consisting essentially of a shell, an energy absorbing system, a retention system, fluorescent retro-reflective markings, ear covers and faceshield. "Interior structural firefighting" means the physical activity of fire suppression, rescue or both, inside of buildings or enclosed structures which are involved in a fire situation beyond the incipient stage. "NFPA" means the National Fire Protection Association. "Overhaul" means the final control of a fire with suppression of the main body of the fire and other pockets of fire, searching for victims and performing salvage operations. "Positive-pressure apparatus" means an open or closed-circuit apparatus in which the pressure inside the face piece in relation to the immediate environment is positive during both inhalation and exhalation. "Quick disconnect valve" means a hand-operated device which provides a means for connecting and disconnecting the air cylinder to the self-contained breathing apparatus. "Remanufactured" means the complete dismantling and reassembly of the fire apparatus body with or without removal from the chassis during the process. "Respiratory protective device" means a breathing device designed to protect the wearer from an oxygen-deficient or hazardous atmosphere. "SCBA" means self-contained breathing apparatus. "Self-contained breathing apparatus" means an atmosphere-supplying respirator for which the breathing air source is designed to be carried by the user. "Service life" means the period of time that a respirator has been rated to provide protection to the wearer. "Unserviceable" means past useful life of garment or protective gear, or those that have been

declared unsafe. "Vapor-barrier" means that material used to substantially prevent or inhibit the transfer of water, corrosive liquid, steam or other hot vapors from the outside of a garment to the wearer's body. 12:100-10.3 Organization, training and education (a) The employer shall prepare and maintain a statement or written policy which contains the following:

1. The basic organizational structure of the fire service; 2. The expected number of members in the fire service; and 3. The functions that the fire service is to perform.

(b) The organizational statement shall be available for inspection by the Commissioner of Labor and by the employees or their designated representative. (c) Training and education requirements are as follows:

1. The employer shall provide training and education for all fire service members commensurate with those duties and functions that fire service members are expected to perform. Such training and education shall be provided to fire service members before they perform fire service emergency activities. Fire service leaders and training instructors shall be provided with training and education, which is more comprehensive than that provided to the general membership of the fire service.

2. The employer shall assure that training and education is conducted frequently enough to assure that each member of the fire service is able to perform the member's assigned duties and functions satisfactorily and in a safe manner so as not to endanger fire service members or others. All fire service members shall be provided with training at least annually. In addition, fire service members who are expected to perform interior structural fire fighting shall be provided with an education session or training at least quarterly.

3. The quality of the training and education program for fire service members shall be similar to those conducted by such fire training schools as the Maryland Fire and Rescue Institute; Iowa Fire Service Extension; West Virginia Fire Service Extension; Georgia Fire Academy; New York State Department, Fire Prevention and Control; Louisiana State University Firemen Training Program, or Washington State's Fire Service Training Commission for Vocational Education. (For example, for the oil refinery industry with its unique hazards, the training and education program for those fire service members shall be similar to those conducted by Texas A & M University, Reno Fire School, or the Delaware State Fire School.)

4. The employer shall inform fire service members about special hazards such as storage and use of flammable liquids and gases, toxic chemicals, radioactive sources and water reactive substances to which they may be exposed during fire and other emergencies. The fire service members shall also be advised of any changes that occur in relation to the special hazards. The employer shall develop and make available for inspection by fire

service members written procedures that describe the actions to be taken in situations involving the special hazards and shall include these in the training and education program.

5. The employer shall provide each member of the fire service training in HAZMAT Operations Level I, Bloodborne Pathogens, Incident Management System Training Orientation (I-100), and where applicable, Confined Space Entry Rescue Operations, Trench Rescue Operations and High Angle and Technical Rescue Techniques. All training shall be consistent with the applicable PEOSH Standard.

6. The employer shall comply with the Hazard Communications Standard, N.J.A.C. 12:100-7, and relevant parts of the New Jersey Worker and Community Right to Know Act.

12:100-10.4 Personnel; limitations on ability to perform (a) The employer shall assure that employees who are expected to do interior structural firefighting are physically capable of performing duties, which may be assigned to them during emergencies.

1. Prior to appointment as a structural firefighter, all individuals shall have successfully passed a medical evaluation, which meets the Medical Evaluation Protocol required under the Respiratory Protection Program Standard, 29 CFR 1910.134. Failure to pass said examination shall exclude the individual from serving as a structural firefighter.

(b) The employer shall assure that compliance with (a) above shall be accomplished in conformity with the provisions of the Americans with Disabilities Act of 1990. 12:100-10.5 Protective clothing (a) The employer shall provide, at no cost to the employee, and assure the use of, protective clothing which complies with this subchapter. (b) Firefighters performing interior structural firefighting and overhaul shall be provided with, and required to wear, the equipment covered in this subchapter. (c) The employer shall assure that:

1. Protective clothing protects the head, body and extremities, and consists of at least the following components: body protection, eye, face and head protection;

2. Protective clothing ordered or purchased after the effective date of this subchapter shall comply with this subchapter; and

3. Firefighters wear foot, leg and body protective clothing complying with this subchapter.

12:100-10.6 Protective clothing; foot and leg protection (a) Foot and leg protection shall comply with this section for all firefighters.

1. Protective footwear shall comply with NFPA 1974-1987, Protective Footwear for Structural Firefighting.

12:100-10.7 Protective clothing; body protection (a) Body protection shall comply with this section for all firefighters. (b) Body protection shall be achieved by the wearing of a fire resistive coat and bunker pants, both of which shall be at least equivalent to NFPA 1971-1986, Protective Clothing for Structural Firefighting, incorporated herein by reference. For career firefighters, body protection must be worn in combination with a station/work uniform or apparel complying with (c) below. If the employer issues or requires the wearing of uniforms for volunteer firefighters, the uniform must comply with (c) below. (c) Station/work apparel shall be provided to the career firefighter as follows:

1. The performance, construction and testing of station/work uniforms shall be at least equivalent to NFPA 1975-1985, Station/Work Uniforms for Firefighters, incorporated herein by reference; or

2. Apparel issued to the firefighter must be of a non-meltable material, such as cotton.

12:100-10.8 Protective clothing; hand protection (a) Hand protection shall consist of protective gloves or a glove system which will provide protection against cuts, punctures and heat penetration. (b) The performance, construction, and testing of gloves for structural firefighters shall be at least equivalent to NFPA 1973-1988, Gloves for Structural Fire Fighting incorporated herein by reference. 12:100-10.9 Protective clothing; head, eye and face protection (a) Head protection shall consist of a protective head device with ear flaps and chin strap which meet the performance, construction and testing requirements of 29 CFR Part 1910.156(e)(5) or NFPA 1972-1987, Helmets for Structural Fire Fighting. (b) Full facepieces, helmets, goggles or hoods of breathing apparatus which comply with 29 CFR 1910.134 and N.J.A.C. 12:100-10.10 shall be deemed to comply with (a) above. (c) A full protective hood shall be provided for the firefighter that meets the performance, construction, and testing requirements of NFPA 1971-1991, Protective Clothing for Structural Fire Fighting.

1. Firefighters shall be provided with a full protective hood provided that if the wearing of the hood interferes with the proper fit of the helmet, a full protective hood need not be provided until the helmet becomes unserviceable and is replaced.

12:100-10.10 Respiratory protection devices (a) The employer shall ensure that respirators are provided to, and used by firefighters, and that the respirators meet the requirements of 29 CFR 1910.134 and this section. (b) Approved self-contained breathing apparatus with a full-facepiece, or with approved helmet or hood configuration, shall be provided to, and worn by, firefighters as follows:

1. While engaged in interior structural firefighting; 2. While working in confined spaces where toxic products of combustion or an oxygen

deficiency may be present; 3. During emergency situations involving toxic substances; and 4. During all phases of firefighting and overhaul.

(c) The employer shall assure that:

1. Respirators ordered or purchased after January 4, 1993 shall be at least equivalent to NFPA 1981-1987, Open-Circuit Self-Contained Breathing Apparatus for Fire Fighters, incorporated herein by reference; and

2. All firefighters shall wear respirators complying with this subchapter except that existing respirators meeting the previous OSHA standards that are superseded by this subchapter may continue to be worn until such time as the respirator becomes unserviceable.

(d) The employer shall establish and maintain a respiratory protection program, which includes the requirements of 29 CFR 1910.134, Respiratory Protection, with amendments published in the Federal Registry through April 23, 1998 and any subsequent amendments thereto, are incorporated and adopted herein by reference as standards applicable to firefighters for respiratory protection. (e) Existing respirators meeting the previous OSHA standards that are superseded by this subchapter:

1. May be used with approved cylinders from other approved self-contained breathing apparatus provided that such cylinders are of the same capacity and pressure rating. All compressed air cylinders used with self-contained breathing apparatus shall meet the United States Department of Transportation (49 CFR Parts 100 through 199) and National Institute for Occupational Safety and Health (42 CFR Part 84) criteria.

2. Can be switched from a demand to a positive pressure mode. However, such apparatus shall be in the positive pressure mode when firefighters are performing interior structural firefighting operations or overhaul.

12:100-10.11 Life-safety rope, harnesses and hardware (a) This section is intended to apply to fire departments that train and perform rope rescue services. All employees that are required by the fire department to participate in such rescue services shall be provided with the proper equipment meeting the requirements of this section.

(b) The employer shall provide, at no cost to the employee, and assure the use of, life-safety rope, harnesses, and hardware which comply with this section. (c) The employer shall assure that the life-safety rope, harnesses and hardware complying with this section are used to support fire service personnel during rescue, firefighting, and other emergency operations, or during training exercises. (d) The performance, construction and testing of ropes, harnesses, and hardware for firefighters shall be at least equivalent to NFPA 1983-1985, Fire Service Life-Safety Rope, Harnesses and Hardware, incorporated herein by reference. (e) Life-safety rope, harnesses and hardware need only be provided in those departments that perform rope rescue services and to employees who perform such services. 12:100-10.12 Personal alert safety system (a) The employer shall provide, at no cost to the employee, and assure the use of, a personal alert safety system which complies with this section. (b) The employer shall assure that all firefighters wear personal alert safety systems that comply with this section by January 4, 1994, except that personal alert safety systems complying with NFPA 1982-1983, Personal Alert Safety Systems (PASS) for Fire Fighters, may continue to be used until they become unserviceable. (c) The performance, construction and testing of a personal alert safety system for a firefighter shall be at least equivalent to NFPA 1982-1988, Personal Alert Safety Systems (PASS) for Fire Fighters, incorporated herein by reference. (d) Approved personal alert safety systems shall be provided and worn by the firefighter as follows:

1. While engaged in interior structural firefighting; 2. While working in confined spaces; 3. During all phases of overhaul; and 4. The PASS device shall be attached to the exterior of the firefighter's turnout gear.

12:100-10.13 Hearing protection (a) This section is intended to provide hearing protection to the firefighter in non-emergency situations. An example of a non-emergency situation requiring hearing protection to the employee would be during the testing of equipment creating a noise level exceeding 90 decibels (dBa). The hearing conservation program described should be in writing and may be incorporated into standard operating procedures (SOP). (b) The fire department shall provide hearing protection for all members when they are exposed

to noise in excess of 90 dBa from power tools or equipment, except for situations where the use of hearing protection devices would create an additional hazard to the user. (c) The fire department shall engage in a hearing conservation program to identify and reduce or eliminate potentially harmful sources of noise in the work environment. (d) The provisions of 29 CFR 1910.95, Occupational Noise Exposure, incorporated at N.J.A.C. 12:100-4 are applicable to this subchapter. 12:100-10.14 Filling air cylinders (a) Air cylinders for respiratory equipment shall be filled only by trained personnel. (b) The charging station shall be equipped with proper facilities to ensure the safety of the charging station operator and nearby personnel. 12:100-10.15 Fire apparatus operations (a) Whenever a fire apparatus leaves the fire station in response to a fire alarm, all firefighters, except the driver of the fire apparatus, shall have donned their protective clothing before the apparatus is in motion. The term "fire apparatus" does not include an automobile. (b) The employer shall provide restraining devices for all firefighters aboard a fire apparatus. Restraining devices may include protective seating, seatbelts, or vehicle harnesses for all firefighters aboard. (c) All fire apparatus purchased and/or remanufactured after January 4, 1993 shall provide enclosed seating with seatbelts for all personnel riding on the apparatus, complying with the following standards, incorporated herein by reference:

1. NFPA 1901-1991 Pumper Fire Apparatus; 2. NFPA 1902-1991 Initial Attack Fire Apparatus; 3. NFPA 1903-1991 Mobile Water Supply Fire Apparatus; and 4. NFPA 1904-1991 Aerial Ladder and Elevating Platform Fire Apparatus.

12:100-10.16 Maintenance of firefighter equipment (a) Firefighting equipment required under this subchapter shall be maintained and inspected by the employer at least annually to ensure the safe operational condition of the equipment. Damaged equipment or equipment found to be in unserviceable condition shall be removed from service and replaced. (b) All fire department aerial apparatus is to be subject to visual inspection, operational tests and load tests at least annually in accordance with NFPA 1914-1991, Testing Fire Department Aerial Devices. Complete inspections and tests including, the non-destructive testing defined in NFPA 1914-1991, Testing Fire Department Aerial Devices, shall be conducted whenever visual

inspection or load testing indicates a potential problem or at least every five years. Any device that fails a test shall be immediately removed from service and shall not be returned to service until properly repaired and retested. In addition, pumper fire apparatus shall be inspected at least annually in accordance with criteria of NFPA 1911-1997; initial attack fire apparatus shall be inspected at least annually in accordance with criteria of NFPA 1911-1997; and mobile water supply fire apparatus shall be inspected at least annually in accordance with criteria of NFPA 1911-1997. Each inspection shall include road-worthiness and safety equipment.