To the: ENVIRONMENT AND NATURAL RESOURCES COMMITTEE

SUBMISSION ON THE INQUIRY INTO THE

CFA TRAINING COLLEGE AT FISKVILLE

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1. My name is Philip John Taylor and I have been employed by the MFB since 1979. I currently hold the classification of Commander Work, Health and Safety.

2. I have also had extensive involvement in the development and evolution of firefighters' protective fire fighting equipment.

3. In facilitating the above I hold the following qualifications:

a. Diploma of Occupational Health and Safety

b. Diploma of Project Management

c. Advanced Diploma of Public Safety (Fire-Fighting Management)

d. Associate Diploma of Applied Science (Fire Technology)

e. Graduate Certificate in Business Management

4. As part of my duties as UFU OHS Coordinator (UFU Branch) I was a member of Australian Standards Committee SF-049 that oversees the development of fire-fighters protective clothing and equipment from 1999 until 2010.

5. I am providing this statement in my personal capacity.

FIREFIGHTING - HAZARDOUS WORKPLACE

6. Firefighting is an extremely hostile environment where unlike other workplaces the working environment is uncontrolled and the hazards cannot be eliminated.

7. For example, a normal structure fire involving a single premises, firefighters can be exposed to temperatures up to 1000 degrees Celsius in performing their duties of rescue and suppression.

8. The toxic environments created during structural fires due to generation of by products of combustion are well documented. Research has consistently proven that a normal structure fire generates large volumes of smoke and other by products including a multitude of toxic chemicals such as benzene, formaldehyde and PAH's.

9. Although contemporary firefighter's Personal Protective Clothing (PPC) provides much improved protection for firefighters, PPC and equipment is the least preferred risk control method . In addition, all of the Standards referenced for PPC specify that the level of protection provided by clothing and equipment is limited. In other words, there is a limit to the level of protection that can be provided to firefighters by PPC due to the inherent nature of work they perform.

10. Many of the chemicals firefighters are exposed to are known or suspected carcinogens as classified by the International Agency on Cancer.

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11 .1n 2011 the Australian Parliament enacted presumptive legislation to recognise specific occupational cancers for firefighters. Prior to doing so the Australian Senate undertook a robust inquiry into exposures of firefighters and the link between firefighting and occupational cancer. This included the limitations of protective clothing and the absorption of toxins and chemicals.

12.1 provided a submission to the Senate Committee which I attach as Appendix 1. I respectfully urge this committee to read that submission as it details the nature of firefighting, the hierarchy of controls to mitigate workplace hazards, and provides specifics about the limitations of personal protective clothing and equipment.

13.1 also appeared at a hearing before the Senate Committee and I attach as Appendix 2 a copy of the transcript dated 9 August 2011 . My evidence is recorded from page 22 of that transcript.

14. I attach a copy of the Final Senate Report and there is reference to my evidence from page 14-19.

15.As a result of that Inquiry, and relying on the Senate Report and recommendations the Federal Parliament unanimously passed legislation that recognises the link between firefighting and the absorption of toxins and carcinogens and presumes specific listed cancers are occupational cancers.

ABSORPTION OF TOXINS/CHEMICALS

16. For the purposes of this Inquiry into Fiskville the risk of absorption of toxins, carcinogens including contaminated water are highly relevant.

17. There are five routes of entry through which chemicals can potentially enter the human body. They are:

o Inhalation o Absorption o Ingestion o Injection o Through the eyes

18. Breathing of contaminated air is the most common way that workplace chemicals enter the body (inhalation). Some chemicals, when contacted , can pass through the skin into the bloodstream (absorption). Less commonly, workplace chemicals may be ingested accidentally if contaminated hands come into contact with food etc. For this reason any workers should not drink, eat, or smoke in areas where they may be exposed to toxic chemicals. This is not exclusive to the firefighting workplace but workplaces in general such as factories.

Inhalation

19. Oxygen in the inhaled breath crosses the alveolar walls to enter the blood within the capillaries. Once oxygen has become attached to the blood inside the veins, it is then distributed throughout the body. Chemical vapours, gases

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and mists which reach the alveoli in the lungs can also pass into the blood and be distributed around the body.

Skin Absorption

20. Chemicals which pass through the skin are nearly always in liquid form. Solid chemicals and gases or vapours do not generally pass through the skin unless they are first dissolved in moisture on the skin's surface. This is particularly relevant for firefighters as they generate excessive amounts of perspiration in the highly physical tasks of firefighting whilst dressed in personal protective clothing.

Ingestion

21 . Chemicals can enter the stomach either by swallowing contaminated mucus which has been expelled from the lungs, or by eating and drinking contaminated food . Food and drink are most frequently contaminated by contact with unwashed hands, gloves or clothing, or by being left exposed in the workplace. Nail-biting and smoking also contribute.

22. Once inside the mouth, workplace chemicals pass down the oesophagus and then into the stomach. Food in the stomach is digested with a strong acid produced by the stomach. Most chemicals move from the stomach into a long, twisting tube known as the small intestine. The inside of the small intestine has many hundreds of tiny finger-like projections called villi. The villi have very thin walls and are filled with tiny blood vessels. This allows the digested food and chemicals to pass from the small intestine across the walls of the villi and enter the veins.

Injection

23.1njection is the fourth way chemicals may enter the body. Whi le uncommon in most workplaces, it can occur when a sharp object (e.g., needle) punctures the skin and injects a chemical (or virus) directly into the bloodstream. Firefighters have an elevated risk of needle-stick injuries when attending Emergency Medical Response calls and in particular when dealing with intravenous drug users.

Eyes

24. The eyes may also be a route of entry. Usually, however, only very small quantities of chemicals in the workplace enter through the mouth or the eyes. There is a risk to the eyes coming into contact with water when training as not all drills are conducted wearing breathing apparatus.

25. Regardless of the way the chemical gets into the body, once it is in the body it is distributed throughout the body via the blood stream. In this way, the chemicals can attack and harm organs which are far away from the original point of entry as well as where they entered the body.1

1 1 Source -The Canadian Centre for Occupational Health and Safety

Fact Sheet- How Workplace Chemicals Enter the Body

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FIGHTER PPC

26. The structural protective clothing currently worn by both MFB and CFA fire­fighters was introduced into the MFB in mid 2008 and the CFA in 2009.

27. The process of manufacturing and distribution of 3 sets of garments to every MFB fire-fighter took approximately 12 months to complete. The process of distribution to all CFA fire-fighters was not completed until some time later.

28. The structural fire-fighting garments worn prior to this period were comprised of a woollen jacket and a single layer Nomex over-trouser and did not incorporate a moisture barrier.

29. The lack of a moisture barrier in the garments used up until 2008 allowed water, foam and any contaminants or chemicals in those liquids to penetrate directly through the garment and come in contact with the skin of the fire­fighter.

30. Fire-fighters generate high levels of moisture on the skin when undertaking fire suppression and the protective clothing used up until 2008 would expose fire­fighters to the risk of absorption of chemicals into the body via very moist skin .

31 . The protective clothing now supplied to MFB and CFA fire-fighters including protective gloves incorporates a breathable moisture barrier which reduces the entry of water, liquids and a range of chemicals such as fire-fighting foam whilst allowing metabolic heat and water vapour generated by the body to exit the garment.

32. Since the about the mid 2000's, the Australian Standard for structural fire­fighting footwear has required protective footwear to be constructed of either rubber or of leather incorporating a moisture barrier to prevent liquid exposure to the fire-fighters feet. Prior to the introduction of this Australian Standard there was no requirement for fire-fighter footwear to prevent the entry of liquids.

33. Together currently the garments, gloves, flash hoods and footwear provide a high level of protection to the skin of the fire-fighter against exposure to liquids and contaminants including some liquid chemicals thereby reducing the potential for absorption of chemicals into the body via this route of entry.

34. Whilst these garments providing excellent protection against liquids there is still the potential for some entry of liquids at the interface areas at the neck, wrists, waist and trouser cuffs.

35. Fire-fighters can be at risk of exposure to injection of pathogens into the body when engaged in search and rescue inside burning structures. Limited protection against this route of entry is achieved through the placement of tough, penetration resistant materials such as Kevlar on the knees of the garments to provide some protection against sharps and syringes.

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36. The moisture barrier in structural PPC is not designed to prevent the entry of gaseous chemicals and chemical vapours. Protection for fire-fighters against chemicals in this form is achieved through the use of gas tight protective su its commonly referred to in the industry as FENCAPS or Fully ENCApsulated Protective Suits.

37. These protective suits are made of materials that are not suitable for fire­fighting and are purely designed for protection against liquid and gaseous chemicals at HAZMAT incidents.

38. Protection for fire-fighters against the inhalation, ingestion and eyes routes of entry is achieved through the use of compressed air SCBA or Self Contained Breathing Apparatus. The facemasks of modern breathing apparatus sets have a full face visor that covers and protects the respiratory system, the digestive system and the eyes.

39.AII breathing apparatus sets currently used by MFB are also positive pressure sets which means the pressure inside the facemask is higher than the outside environment to protect against inadvertent leaks of smoke, gases and vapours into the mask. In the past breathing apparatus were not positive pressure sets and therefore the risk of leakage and therefore exposure was significantly higher.

40. There are limitations to the use Breathing Apparatus and in particular when undertaking drills in training for hours at a time it is not physically possible to wear BA continually.

41 .1 respectfully suggest it would be highly beneficial for the Committee to undertake an inspection of the Victorian Emergency Management Training Centre located in Craigieburn to see first hand the nature of firefighting/firefighting training including the personal protective clothing and equipment and witness the limitations of such protections in a controlled environment.

42.1 would welcome an opportunity to appear before the Committee to expand on this submission.

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