Review of Standard Operating Procedures for Fire Fighting ... · z The key SOP “Water Supplies”...

Cardno Lane Piper Pty Ltdtrading as Cardno Lane PiperABN 35 120 109 935

Building 2154 Highbury RoadBurwood VIC 3125Australia

Phone: +61 3 9888 0100Fax: +61 3 9808 3511www.cardno.com

www.lanepiper.com.au

Our Ref: 212163.4Report04.3

19 April 2013

AshurstLevel 26,180 William StMelbourne, VIC 3000

Attention: Rob Jamieson

Dear Rob,

Privileged and Confidential

Review of Standard Operating Procedures for Fire Fighting TrainingCFA Fiskville and Regional Training Grounds, Victoria

1 INTRODUCTION

Cardno Lane Piper Pty Ltd was engaged by Ashurst (“the Client”) on behalf of the Country Fire Authority (CFA), to undertake a review of the occupational health and safety procedures applied to the current fire-fighting training operations at the CFA Fiskville Training College and the Regional Training Grounds.

This work was in response to the Report of the Independent Fiskville Investigation (IFI Report) authored by Prof Rob Joy in June 2012 and additional CFA initiatives. The work program was designed specifically to respond to Recommendation 6 of the IFI Report which stated:

That procedures be put in place to protect the health of personnel potentially exposed to waters and sediments in Dams 1 and 2 of the firewater treatment system and, in particular, to manage the risks to individuals who have the potential to come in contact with sediments in the dams during routine maintenance.

This work has been performed with the assistance of our specialist Occupational Health and Safety (OHS) advisor Brian Eva of Eva & Associates. Brian is a Certified Occupational Hygienist.

Preliminary advice in relation to the adequacy of Standard Operating Procedures (SOPs) relevant to hot fire training with water was provided to CFA in December 2012.

1.1 Objectives

While the purpose of this report is to respond to the IFI Report and other CFA initiatives for improvement to facilities and practices at Fiskville, the specific objectives of the current work were to:

Identify the potential risks to worker (trainees, supervisors, operators, maintenance workers and monitoring workers at dams) health and safety from occupational exposure during current training practices using supplied water, and the risks of exposure to sediment in dams;

Australia Belgium Canada Ecuador Germany Indonesia Italy Kenya New Zealand Papua New Guinea Peru Tanzania United Arab Emirates United Kingdom United States Operations in 85 countries

Privileged and Confidential Review of Standard Operating Procedures for Fire Fighting Training

CFA Fiskville and Regional Training Grounds, VictoriaAshurst

Assess the adequacy of OHS SOPs to protect workers from excessive exposure to water used in training at CFA training grounds; andProvide specific and detailed comments to improve current SOPs or introduce new SOPsconsidered necessary.

2 SCOPE & METHOD OF WORK

Information on potential exposures and OHS management of personnel engaged in hot fire training drills was gathered in August 2012 by observation at the Fiskville Training College Practice Areas for Drills (PAD). This was for the dual purpose of advising CFA on the adequacy of OHS procedures and providing input to the assessment of Human Health Risk. The former was undertaken by Brain Eva (occupational hygienist) and a Risk Assessor from Cardno Lane Piper. These two specialists collaborated to observe the drills on the same day.

The scope of works completed in relation to the study objectives was as follows:A site visit to observe the exposures of CFA training personnel to water during a hot fire training drill session conducted on 2 August 2012. Review of documents provided by CFA including:

The IFI report by Professor Rob Joy (2012)The Fiskville Training College SOPs dated 11 October 2010 The key SOP “Water Supplies” for fire training drills and related operations on the PAD with potential to expose workers to water and sedimentThe CFA Safety First Field Training Management Manual Edition 2 December 2007

Discussions with relevant CFA stakeholders to assist in the identification of the exposures to be assessed and the locations where the exposures occur.Attendance at meetings between CFA and Work Safe in relation to management of OHS issues at the Fiskville site.Preparation of this report, including an appendix with example procedures for key SOPs.

While this report relies on information from the Fiskville Training College, some of the documentation reviewed applies to all CFA training facilities. The observations of fire fighting training at Fiskville have been assumed to be relevant to all other training grounds despite the differences in training practices evident across the regional facilities. Essentially, Fiskville represents the most intensive training operation and uses foam on liquid fuels. It is, therefore, considered representative of the training scenarios across all RTGs.

3 WATER SOURCES AT FISKVILLE

The water storages and other features of the CFA Fiskville site are shown in Figure 4-1.

Prior to 26 June 2012, the CFA used town water supplemented by water recirculated from Dam 2 (and indirectly from Dam 1) in their training drills. Since that date, only town water has been used due to concerns about water quality in the dams.

In the past, water was drawn from multiple sources to meet the demand for fire-fighting training. The water potentially contained both chemical and microbial contaminants. The basic elements of the water supply and treatment system operating at Fiskville just prior to 26 June 2012 were:

212163.4Report04.3 Page 2



Water used by trainees on the Flammable Liquids (FL) PAD was supplied from a pumphouse located beside the FL PAD.The pump drew water from a pump sump known as the Water Supply (WS) Pit located beside the pumphouse.The WS Pit was fed by town water supplied by Central Highland Water, supplemented with water pumped from Dam 2.Effluent from the FL PAD, often containing residues of liquid petroleum hydrocarbons, discharged to the Surge Basin then into the Oil-Water Separator or Triple Interceptor Trap (TIT).From the TIT, the effluent flowed to another pump sump which lifted the water into Dam 1.Dam 1 flows by gravity into Dam 2 via a 300mm underground pipe linking the dams.Excess water not recirculated to the WS Pit from Dam 2 discharged to a drainage channel on the east side of Dam 2 then into Dam 3, then into Dam 4 and finally to Lake Fiskville.When the level of Lake Fiskville exceeds the level of the spillway, it discharges to the Beremboke Creek downstream.The only treatment provided to PAD water at present is oil separation in the TIT and aeration in Dams 1 and 2 as well as the retention time in all dams.

Other sources of water occasionally transferred into the WS Pit and/or Dam 2 have included water pumped from Lake Fiskville during the last drought and, on rare occasions, Class A1

reclaimed water was imported to the site.

Since 26 June 2012 the only water being used for training drills is town water. As of mid-October 2012, all of this town water is piped directly to two new temporary above ground, fully enclosed tanks connected to the WS Pit at the FL PAD.

1 Class A reclaimed water is treated sewage effluent water supplied by an approved water authority. The hazards associated with exposure to Class A recycled water are not discussed in this report because a) Chemicals in class A recycled water are not envisaged to be a human health risk, b) Class A recycled water is only a minor contributor to the total water used in the past at Fiskville, therefore exposure is low, and c) Other risk assessments have found that Class A recycled water is suitable for use in fire-fighting operational duties (GHD 2006)


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Confidential & Privileged Review of Standard Operating Procedures for Fire Fighting Training


4 POTENTIAL EXPOSURES TO FIRE TRAINING WATER

This section presents a summary of the potential modes of exposure of personnel engaged in fire training involving water. This assessment is elaborated upon in a separate report on potential health risks associated with water use at Fiskville which was in preparation at the time of writing.

This assessment is necessary for consideration of SOPs as it is expected that these procedures, in addition to training and use of Personal Protective Equipment (PPE), should provide protection against health effects from exposure to water and sediment. The current review evaluates the SOPs for effectiveness in this regard.

4.1 Persons Exposed

There are two broad areas where people may be exposed to water during training at Fiskville and RTGs:

Practice Areas for Drills (PAD) where fire-fighting training takes placeDams which may be accessed by CFA personnel or private contractors

Cardno Lane Piper has assessed exposure of these workers to water used during current training practices and also any access to dams where they may come into contact with sediment. The descriptions provided below are based on observations by representatives of Cardno Lane Piper, discussions with CFA personnel, including the PAD supervisor at Fiskville during site visits, and subsequent phone conversations. The roles and levels of exposure are interpreted to be:

PAD Instructor: The PAD Instructor is employed full-time to instruct recruits and fire-fighters during training at Fiskville (assumed to be 48 weeks’ exposure per year for 20 years).Leading fire-fighter: Instructs in recruit training once in a twelve month period and undertakes or assists in the delivery of eight modules at other times during the year (16 weeks’ exposure per year for 10 years).Recruit: Undertakes recruit training only in his/her first year of employment (this may amount to periodic exposures over 8 weeks of the 16 week course).Fire-fighter: Assumed to undertake or assist in the delivery of five training modules during the year (5 weeks’ exposure per year for 5 years).

For other on-site workers, including maintenance workers and people who casually visit the site, the following notes the roles and levels of exposure:

Maintenance Worker and Monitoring Workers at Dams: A person who works on the dams at Fiskville on an intermittent basis (once per month) or someone who casually visits the dam with limited contact, for example a contractor taking water samples..Other Organisations: People from other organisations who train at the Fiskville Training College and may be exposed to water during training drills. The duration, frequency and type of exposure is outside this assessment.




4.2 Relevant Exposure Routes

Based on the observations made on 2 August 2012, an assessment has been made of the exposure of CFA personnel to water during training drills (foam was not being used during the drill observed):

Low exposure to fire fighting water and airborne contaminants was observed for CFA Training Personnel involved in hot fire drills due to method of attack (upwind), and wearing waterproof turn-out gear, including gloves, boots and faceshields or full face respirators;The attack and water fogging procedures (as observed in techniques such as the two-line fog attack2) was performed from an upwind direction to minimise prolonged contact with emissions or water spray, however wind conditions would not always allow this, which could lead to increased exposure at times;Recruits wearing full face respiratory protection (or compressed air breathing apparatus, CABA) were afforded additional protection. It should be noted that recruits without full face respiratory protection are instructed to “seek refuge” behind other recruits (first in line in the fire attack position) that are wearing full face respiratory protection. On occasions the recruits wearing breathing apparatus were in the rear.PAD Instructors were wearing protective equipment including helmet with face shields but they were not positioned in the fire attack position and tended to be in a standoff position up to 1m away;PAD Operators used small quantities of unleaded petrol to initiate prop burning (additional ignition source for gas), and for tyres placed in car wreck. Petrol is dispensed from a safety can;Inconsistent use of PPE such as faceshields or breathing apparatus, were used for different roles during a training drill using fire training water.

The exposures to the maintenance worker or the monitoring workers at the dams were not observed during the site inspection. However, the nature of this work indicates a lower likelihood of exposure to spray from the PAD but an increased potential for dermal contact with water and sediment if appropriate OHS procedures and PPE are not employed.

The relevant routes of exposure for each scenario are presented in Table 4-1. Incidental ingestion of water is considered for all persons exposed. Inhalation of wind-blown sediment dusts is only considered relevant to workers who work in close proximity to the dam, whereas inhalation of aerosols is relevant to CFA training personnel.

2 The two line fog attack is a procedure used by fire-fighters to protect themselves when advancing in close proximity (<15m) and retreating from a scene involving fire. The two-line fog attack results in a fine spray mist of water (or a fog) to which recruits are potentially exposed




Table 4-1: Relevant Exposure Routes

Person Exposed

Relevant routes of Exposure

Incidental ingestion of water

Dermal contact

with water

Inhalation of dusts

Inhalation of

aerosols

Incidental ingestion of

Sediment

Dermal Contact

with Sediment

Fire-fighter Yes Yes No Yes No No

Recruit Yes Yes No Yes No No

Leading fire-fighter Yes Yes No Yes No No

PAD Instructor Yes Yes No Yes No No

Dam Maintenance / Monitoring Worker

Yes Yes No No Yes Yes

4.3 Management of Exposures

Following reviews of OHS exposures of CFA personnel to water and sediment in the dams at Fiskville, and after consultation with WorkSafe during August 2012, a number of initiatives have been taken to improve management of these exposures:

Since 26 June 2012 CFA has ceased taking water from Dam 2 and indirectly from Dam 1 for use in fire training, and has switched to the use of town mains water only for fire fighting training.Dams 1 and 2 have been fenced.Signs have been placed at Dams 1 and 2 warning people not to enter the dams or drink the water.Induction processes have been updated and new procedures for accessing dams have been developed and implemented.Procedures have been changed to cease drawing water from Dams during recruit training.

5 REVIEW OF STANDARD OPERATING PROCEDURES

The key documents reviewed were:

Fiskville Training College Standard Operating Procedures dated 11 October 2010Safety First Field Training Management Manual Edition 2 December 2007

The Fiskville Training College Standard Operating Procedures comprises a set of operating procedures, some of which are in draft and others which are ‘approved’. Table 5-1 presents a summary of the review comments on each SOP with some relevance to use of water. It also includes advice on improvements that should be made to the procedure to make it more effective in protecting worker health and safety. In addition, a set of example procedures that could be used as the basis for improvement or replacement of the deficient SOPs, subject to revision in keeping with the CFA documentation and OHS management systems, is presented in Appendix A.


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Tabl

e 5-

1: C

omm

ents

on

Trai

ning

Col

lege

SO

Ps –

PAD

Ope

ratio

n

SOP

num

ber

Title

Gen

eral

Com

men

ts a

nd Is

sues

Iden

tifie

dPr

opos

ed A

dvic

e or

sug

gest

ed e

dits

4.09

W

ater

Sup

plie

sN

o in

form

atio

n re

latin

g to

loca

tion

or d

escr

iptio

n of

th

e on

-site

dam

s an

d ot

herw

ater

sto

rage

sth

at a

re

pres

ent o

n th

e si

te.

No

desc

riptio

n of

the

colo

ur c

odin

g sy

stem

for t

he

fire

fight

ing

wat

er s

uppl

y (r

ed a

nd b

eige

pip

es).

The

colo

ur c

odin

g sy

stem

is la

belle

d on

site

but

is n

ot

docu

men

ted

in th

is S

OP.

Th

ere

is a

refe

renc

eto

hot

fire

trai

ning

and

re-

circ

ulat

ed w

ater

”fro

m th

e sy

stem

”,ho

wev

er th

ere

is

no m

entio

n of

the

use

of w

ater

for o

ther

act

iviti

esor

sc

enar

ios

that

are

list

ed in

sec

tion

4,su

chas

the

recr

uits

’ “C

halle

nge”

or “

Dra

ught

ing”

from

dam

sN

o he

alth

and

saf

ety

info

rmat

ion

prov

ided

rega

rdin

g po

tent

ial h

azar

ds a

ssoc

iate

d w

ith th

e so

urce

wat

er

used

.

A si

mpl

e m

ap o

r dia

gram

of F

iskv

ille a

nd th

e w

ater

sup

ply

syst

ems

shou

ld b

e in

clud

ed.

Def

initi

ons

of th

e w

ater

sup

ply

syst

em, i

nclu

ding

the

colo

ur c

odin

g sy

stem

of p

ipes

, sho

uld

be in

clud

ed w

ithin

the

text

and

pre

sent

ed

as a

dia

gram

.Al

l act

iviti

esan

d sc

enar

ios

liste

d in

sec

tion

4, a

nd a

ny o

ther

s lis

ted

by C

FA w

here

wat

er is

use

d fo

r tra

inin

g,sh

ould

be

incl

uded

as

wel

l as

a d

efin

ition

of t

hese

act

iviti

es.

Incl

ude

heal

th a

nd s

afet

y m

easu

res

and

furth

er in

form

atio

n on

the

sour

ce o

f wat

er s

uppl

y us

ed (o

r pro

hibi

ted

from

use

) for

fire

trai

ning

.

4.01

PAD

Saf

ety

Brie

fing

and

Indu

ctio

n to

the

site

The

PAD

saf

ety

brie

fing

(PAD

Les

son

Brie

f) do

es

not i

nclu

de h

ow w

ater

is u

sed

on s

ite.

Safe

ty B

riefin

g sh

ould

be

pres

ente

d as

a p

repa

red

stat

emen

t, w

hich

in

clud

es th

e us

e of

wat

er o

n th

e si

te a

nd th

e m

anag

emen

t m

easu

res

curr

ently

in p

lace

rega

rdin

g th

e us

e of

wat

er. T

he

brie

fings

sho

uld

be to

all

staf

fso

that

no

pers

on m

isse

ses

sent

ial

wat

er u

se in

form

atio

n.Th

e sa

fety

brie

fings

shou

ld d

iscu

ss th

e po

tent

ial h

azar

ds o

f the

w

ater

sup

plie

s, c

olou

r cod

ing

of s

uppl

y sy

stem

s, fo

am a

nd a

ny

othe

r che

mic

al s

ubst

ance

s. R

efer

to S

OP

4.09

PPE

requ

irem

ents

to p

rote

ct s

taff

and

train

ees

durin

g ac

tiviti

es

invo

lvin

g w

ater

use

sho

uld

be m

ore

spec

ific

for t

he ta

sk o

r tra

inin

g dr

ill o

r sce

nario

to ta

ke p

lace

. Th

is m

ust i

nclu

de a

pla

n fo

r de

cont

amin

atio

nas

requ

ired.

The

“Gen

eral

and

Saf

ety

Brie

fing”

sho

uld

be s

ubje

ct to

con

tinua

l re

view

and

upd

ated

to re

flect

any

add

ition

al h

azar

ds id

entif

ied

with

si

te o

pera

tions

and

/or c

hang

es in

legi

slat

ion.

An

annu

alre

view

of

the

brie

fing

docu

men

t is

appr

opria

te.

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SOP

num

ber

Title

Gen

eral

Com

men

ts a

nd Is

sues

Iden

tifie

dPr

opos

ed A

dvic

e or

sug

gest

ed e

dits

4.02

Pers

onal

Saf

ety

and

Wel

fare

incl

udin

g m

aint

enan

ce

wor

kers

,co

ntra

ctor

s an

d ot

her p

erso

nsac

cess

ing

dam

s

The

defin

ition

s of

som

e te

rms

used

in th

is S

OP

are

uncl

ear i

n re

latio

n to

exp

osur

e to

wat

er. F

or e

xam

ple

“dre

ss u

p or

dow

n”ne

eds

to c

onsi

der r

isk

of

expo

sure

to w

ater

and

oth

er p

oten

tial c

onta

min

ants

.

Con

side

r add

ing

Pers

onal

Saf

ety

& W

elfa

re to

SO

P 4.

16.

The

SOPs

sho

uld

have

the

sam

e te

rmin

olog

yan

d de

finiti

ons

asth

e R

TG m

anua

l, th

ereb

y av

oidi

ngam

bigu

ity.

Rol

es a

nd R

espo

nsib

ilitie

s fo

r hea

lth a

nd s

afet

y in

rela

tion

to w

ater

sh

ould

be

iden

tifie

d an

d sh

ould

mak

e re

fere

nce

to S

OP

4.04

if a

n in

cide

nt o

ccur

s.

If th

ere

is “p

ract

ical

and

hot

fire

trai

ning

”at o

ffsite

loca

tions

then

the

follo

win

g ite

ms

shou

ld b

e ad

dres

sed

by a

risk

ass

essm

ent

incl

udin

g:

Ref

eren

ce S

OP

4.03

for f

urth

er g

uida

nce.

Wha

t wat

er s

uppl

y is

use

dW

hat c

ontro

l mea

sure

s ar

e in

plac

eW

hoch

ecks

con

trol m

easu

res

prio

r to

train

ing

The

faci

litie

s, a

men

ities

and

“per

sona

l wel

fare

requ

isite

s”,

incl

udin

g cl

ean

wat

er a

vaila

ble

off s

iteIf

no o

n-si

te fa

cilit

ies

avai

labl

e, a

pro

cedu

re to

acc

ess

adeq

uacy

of o

ff-si

te fa

cilit

ies

durin

g tra

inin

gis

requ

ired.

4.04

PAD

Saf

ety

and

Inci

dent

Rep

ortin

gTh

is S

OP

refe

rs o

nly

to P

ract

ical

and

Hot

Fire

Tr

aini

ng. I

t has

no

refe

renc

e to

inci

dent

repo

rting

as

a re

sult

of w

ater

exp

osur

e in

gen

eral

.

Inci

dent

repo

rting

shou

ld b

e ap

plic

able

to a

ll ac

tiviti

es o

n th

e si

tean

d no

t res

trict

ed to

pra

ctic

al a

nd h

ot fi

re tr

aini

ng.

4.05

PAD

Ope

ratio

ns &

En

viro

nmen

tal

Con

side

ratio

ns

SOP

expa

nds

on e

nviro

nmen

tal i

nfor

mat

ion

in o

ther

SO

P’s

.N

o co

nsid

erat

ion

of p

oten

tial c

onta

ct b

y st

aff a

nd

train

ees

or c

ontra

ctor

s an

d ot

her p

erso

nsw

ith

cont

amin

ated

fire

wat

er.

Add

Hea

lth &

Saf

ety

to th

e tit

le a

nd in

clud

e co

ntac

t with

pot

entia

l co

ntam

inat

ed w

ater

run-

off a

nd d

econ

tam

inat

ion

of c

loth

ing

or

pers

ons

if si

gnifi

cant

con

tact

or e

xpos

ure

occu

rs.

4.06

Pers

onal

Pro

tect

ive

Equi

pmen

t&Pe

rson

al H

ygie

ne

No

dire

ctio

n fo

r man

agem

ent o

f PP

E or

enf

orce

men

t of

Ste

ps 1

to 6

of t

he S

OP.

N

o re

quire

men

t for

insp

ectio

n or

che

ck fo

r sui

tabi

lity

or d

amag

e, th

eref

ore

furth

er e

xpos

ure

to w

ater

may

oc

cur i

f fau

lty P

PE

used

.

The

PPE

requ

irem

ents

for s

peci

fic fi

re fi

ghtin

gac

tiviti

es u

sing

fire

train

ing

wat

er s

houl

d be

add

ed to

bot

h th

e Fi

skvi

lle S

OP’

s an

d th

e R

TG m

anua

l. A

proc

edur

e sh

ould

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Confidential & Privileged Review of Standard Operating Procedures for Fire Fighting Training


The CFA Safety First Field Training Management Manual Edition 2 includes OHS SOPs for a wide range of activities across CFA operations. Many of the activities covered in the guidelines, or which should be covered, are also relevant to fire training activities at CFA’s other training campuses across the state and are not commented upon here. The SOPs are quite general and need to be made more specific to the identification and management of hazards associated with training activities (amongst other activities). There are also a number of omissions for activities more directly relevant to fire training, and SOPs should be developed to cover these activities or hazards, namely:

The use of fire training water, foam, other chemicals (such as fuels); Personal hygiene following the use of training water; andPost Application exposure following the use of training water.

6 CONCLUSIONS

The review of SOPs relevant to potential exposures of CFA personnel to water and sediment derived from the dams has resulted in the following conclusions:

6.1 Potential Exposures to Water & SedimentExposure to fire fighting water is intermittent during the training courses; however there are water bodies present on site where people could be exposed if access was uncontrolled. Currently these areas are managed with appropriate signage and restrictive barriers. Use of recirculated dam water for training ceased at Fiskville and RTGs in June 2012.Exposure to fire fighting water occurs at various levels for the following people at Fiskville:

The recruits during the fieldwork component of the fire training courseThe PAD instructor during fieldwork components over the period they are based in these roles during the fire training course.Career fire fighters who return to Fiskville to undertake further advanced training. The maintenance worker/contractor who works on the dams and/or water supply system at Fiskville on an intermittent basis.The contractor who is engaged by CFA to take samples of Fiskville’s fire training water in order to provide regular water quality monitoring services.

Exposure during training drills and following completion of drills could be via incidental ingestion of water/food, dermal contact with water, and inhalation of aerosols from ‘fogging’.

6.2 Adequacy of Standard Operating Procedures

The SOPs included in the key OHS documents Fiskville Training College Standard Operating Procedures (11 October 2010) and the CFA Safety First Field Training Management Manual Edition (2 December 2007) do not have adequate procedures for:

use of fire fighting water or contact with fire fighting water used in training; use of foam, other chemicals (such as fuels) potentially in recirculated water;managing post application exposure to water on PPE or other equipment used in fire training drills;maintenance workers performing duties around the dams and Lake Fiskville and/or on water supply systems;

212163.4Report04.3 Page 11



site induction with regard to the water supply, treatment systems, and hazards associated with the dams and Lake Fiskville.

Inconsistent use of PPE, such as faceshields or breathing apparatus used for different roles during a training drill using fire fighting water, were observed.

Advice has been provided regarding the recommended upgrades to SOPs, along with a set of minimum example SOPs for the critical activities and tasks.

7 RECOMMENDATIONS

The review of OHS procedures and exposures to water on the training grounds has identified the need for an upgrade to procedures.

A number of recommendations flow from the conclusions drawn:1. A “workshop” with PAD Instructors and OHS advisors be arranged to brainstorm the

hazards for each PAD Lesson Brief/Safety Briefing that involves the use of water. Relevant controls and PPE considerations to be incorporated in the documentation where water is utilised.

2. A formal review should be undertaken to align the RTG Manual and individual fire training ground site procedures to ensure consistency in OHS practices across all fire training sites.

3. The recommended changes to key SOPs presented in Table 5.1 and the example SOPs in Appendix A of this report should be implemented, subject to revisions in keeping with the CFA documentation and OHS management systems.

4. Inclusion of specific SOPs within the operations manual for activities undertaken at Fiskville and the RTGs. This should include the hazards identified as follows:

contact with fire water or fire water used for training and sediments;Personal hygiene following contact with fire fighting water and sediments and care of personal protective equipment; The types and sources of water used for training at the facility and any hazards associated with the water source. The potential effect(s) of contact with recirculated fire fighting water when in contact with the skin or used to treat wounds sustained in a fire;The potential health effects of accidental drinking of recirculated water or inhalation of droplets or aerosols.

Should you have any further questions or queries, please do not hesitate to contact myself or Anthony Lane directly.

Yours faithfullyCardno Lane Piper Approved:

Lauren Ryan Anthony P LaneProject Manager Senior Principal

212163.4Report04.3 Page 12



AppendicesAppendix A..................................................................................................... 14 Pages Example Procedures

212163.4Report04.3 Page 13



Appendix A14 Pages

Example Procedures

212163.4Report04.3 Appendix A

Example SOP – Mixing, Handling and Application of AFFF Page 1 of 2

EXAMPLE STANDARD OPERATING PROCEDURE

MIXING, HANDLING AND APPLICATION OF AQUEOUS FILM FORMING FOAM

1. PURPOSE The purpose of this standard operating procedure is to minimise the risk to health and safety of personnel who are required to handle Aqueous Film Forming Foams (AFFF) for fire fighting training purposes, including those who mix, handle and apply foam, including clean up and decontamination of containers.

2. SCOPE This SOP relates to training activities only when AFFF is being prepared and used.

3. REFERENCES

AFFF Aqueous Film Forming Foam

4. PROCEDURE 4.1. Indentify all fire fighting foams (Class A and B) held at the facility and ensure that only

approved types are used for training purposes. 4.2. Safety data sheets to be held for each foam identified and used at the RTFG. 4.3. Ensure trainees have completed the theoretical component of foam fire fighting training

prior to the mixing and application of foam during hot fire training. This training to include instruction on safe storage and handling, use of PPE to minimise exposure in use, and cleaning of protective clothing ensemble.

4.4. PPE to be worn by all personnel when mixing, applying and clean up following foam application. The minimum PPE required is to be determined from the supplier SDS. When correctly worn, the CFA hot fire ensemble will provide exposure protection from foam during training activities. (CFA Standard Operating Procedure 11.03 Schedule 1).

4.5. An emergency deluge shower and eye wash to be provided in close proximity to the foam training area(s).

4.6. STORAGE OF FOAM PRODUCTS i. AFFF products should be supplied and stored in sturdy sealed containers. Broken

seals on the container may reduce its shelf life. ii. All AFFF containers and extinguishers are to be stored appropriately in a bunded

and roofed store house to avoid rain ingress or weather damage. iii. The AFFF storage area should be away from incompatible hazardous substances or

hazardous environment, including electrical devices. iv. Decanting AFFF products must not be conducted in the storage area. v. Leaking containers must be replaced promptly or placed within a clean container

and sealed. Any spills or wastes that may be generated shall be soaked with an inert soaking material such as saw dust or vermiculite and disposed of in accordance with

Example SOP – Mixing, Handling and Application of AFFF Page 2 of 2

CFA guidelines. Empty containers should be disposed of by similar means. AFFF wastes must not be mixed with other wastes.

5. ROLES AND RESPONSIBILITIES Text to be provided

6. PERFORMANCE INDICATORS Text to be provided

7. RECORDS Text to be provided

8. ATTACHMENTS

To be advised.

Example SOP – Workplace Amenities Page 1 of 4


WORKPLACE AMENITIES

1. PURPOSE The purpose of this standard operating procedure is to provide guidance on the requirements to provide appropriate workplace amenities for CFA employees and other RFTG users.

2. SCOPE

This procedure covers the provision of workplace amenities and facilities at RTFG’s as documented with the Worksafe Victoria Compliance Code “Workplace amenities and Work environment”.

3. REFERENCES

3.1 Compliance with the OHS Regulation 2004

Section 21 (1) of the Occupational Health and Safety Act 2004 (the OHS Act) requires employers to provide and maintain a working environment that is safe and without risk to employees’ health, so far as reasonably practicable. Section 21 (2)(d) requires that, in meeting their duty under section 21 (1), an employer must provide, so far as reasonably practicable, adequate facilities for the welfare of employees at any workplace under the employer’s management and control. Employers owe the same duty to independent contractors and their employees who are working at the workplace, but only for matters over which the employer has, or should have, control.

3.2 Subsidiary Documents To be advised. 3.3 Other References

OHS Regulations 2007 Worksafe Victoria Compliance Code- Workplace Amenities and Work Environment Building Code of Australia Air Conditioning Units Standard Operating Guidelines Australian Standard AS3666: Air Handling and Water Systems in Buildings- Microbial

Control AS1668.2: The Use of Mechanical Ventilation and Air Conditioning in Buildings AS1690: Interior Lighting AS3754: Emergency Control Organisation and procedures for buildings, structure and

workplaces. AS2293: Emergency Evacuation Lighting in Buildings


Australian Drinking Water Guidelines AS3565: Meters for Cold Potable Water AS 4276.7: Water Microbiology- thermotolerant coliforms and E. Coli – Membrane

filtration method Worksafe Victoria Guidance Note Sun Protection for construction and other outdoor

workers Worksafe Victoria Code of Practice Manual Handling Worksafe Victoria Guidance Note- Working in Heat

4. DEFINITIONS

5. PROCEDURE /ACTIONS 5.1. Work Areas, Bathroom, Toilet and Dining Facilities and Water Supply

5.1.1 The Provision of amenities a) General

Amenities shall be provided so as to accommodate the largest training group and be maintained in a clean and hygienic state.

b) Work Areas To be of adequate size, with adequate lighting and ventilation for persons to conduct their work safely and effectively.

c) Washing Facilities To be provided and maintained for persons to use as requires for cleaning and cleansing of turnout gear and individual ensemble elements.

d) Bathrooms, toilets and changing facilities To be of sufficient capacity for the requirements of persons and the largest training group and of adequate design and separation for male and female usage.

e) Dining and work break facilities To be provided with adequate lighting, ventilation and seating arrangements. Food heating and cooling storage facilities to be provided and maintained

f) Provision of Drinking water The workplace must have an adequate supply of portable drinking water.

5.1.2 Maintaining the hygienic condition of workplace amenities Regular cleaning must be undertaken to ensure that an adequate level of cleanliness and hygiene is maintained. Where a “hot mess” is operated, a more frequent and thorough cleaning regime is required to remove any potential contaminants. Bathrooms, toilets and lunchrooms must be maintained in a hygienic state. All receptacles containing food scraps must be emptied and disposed of daily.


5.1.3 Potable Drinking Water Potable drinking water must be available to all persons on site at all times.

5.1.4 Emergency Plan All persons involved in PAD Training are to have access and training in an emergency response plan, including the controlled movement of persons from the workplace.

5.1.5 Hand Washing Hand washing facilities must be:

Accessible at all times to the PAD training areas, dining rooms and the toilets.

Be separate from troughs or sinks used in connection with rinsing or washing of turnout clothing or other ensemble PPE.

Be protected from the weather

5.1.6 Personal Storage and Change Area Employees who are required to change in and out of PPE or other turnout gear must have access to private, convenient changing areas with secure storage for personal belongings.

5.1.7 Shower Facilities Employees who undertake training activities that require strenuous effort which leaves them dusty or smelly, or could expose them to infectious or other contaminants, need to have access to showers prior to leaving the PAD area(s).

5.2 Control of Air Conditioned Atmospheres Air conditioning units and filters shall be adequately cleaned and maintained so as to control the growth and spread of microbial organisms. Persons who are involved with the design, installation, operation and maintenance of any air handling and water system in the workplace shall conduct the work in compliance with relevant standards

Australian Standard AS3666: Air Handling and Water Systems in Buildings- Microbial Control

AS1668.2: The Use of Mechanical Ventilation and Air Conditioning in Buildings

So as to prevent accumulation of microbial bacteria in air conditioning units, the following precautions shall be taken:

Correct installation of condenser drainage systems Regular checks tonsure that the system is functioning correctly Regular inspections to ensure:

the condenser coil and evaporator drain is not blocked and that there is no accumulation of water


the filters are clean, and if the system is ducted, that there is no accumulation of moisture in the duct.

If there is a regular accumulation of moisture the system should be modified to prevent it occurring. Failing this, a sample should be taken of the accumulated water/moisture at least every 12 months, for laboratory analysis.

5.3 Surface Workplace Lighting The illumination levels of all amenities, dining facilities and work areas shall comply with the limits set out in the relevant Australian Standards, e.g. AS 1690: Interior Lighting. Illumination levels of all amenities, dining facilities and work areas to be accessed on a regular basis (3 years max). A system for the maintenance of lighting equipment and rectifying lighting defects to be implemented. Portable lighting shall be made available to increase illumination if work tasks are being performed in an area with insufficient lighting. Portable lighting shall not be used to increase lighting in work areas on a permanent basis but only for the purpose of increasing lighting until the task is completed or permanent lighting has been installed. Emergency lighting shall be provided in all areas of regular work. This emergency lighting system shall always be ready for use and tested in accordance with relevant Australian Standards.

6. ROLES AND RESPONSIBILITIES 6.1. Site Senior Manager

The person responsible for implementation and ongoing compliance with this Standard Operating Procedure. In particular, to ensure that all personnel and visitors on site are familiar with this standard operating procedure.

7. PERFORMANCE INDICATORS Results from testing of workplace conditions, drinking water and water generated from

air handling systems, comply with acceptable standards. No incidents of health problems related to amenity cleanliness, drinking water or from

air handling systems.

8. RECORDS Test results for potable water, air conditioning hygiene, lighting surveys etc. cleaning schedule.

9. ATTACHMENTS To be advised.

Example SOP – Chemical Substances Page 1 of 2


CHEMICAL SUBSTANCES

1. PURPOSE The purpose of this standard operating procedure is to ensure that the risk of exposure to all personnel handling a hazardous substance/Dangerous Good, (chemical substances) is minimised at the RTFG.

2. SCOPE Applies to the storage and handling of chemical substances (in packages) at the RTFG. It does not apply to bulk storage or transfer systems.

3. REFERENCES

Dangerous Goods Act 1985 Dangerous Goods Regulations 2012 OHS Act 2004 OHS Regulations 2007

4. DEFINITIONS

SDS Safety data sheet.

5. PROCEDURE / REQUIREMENTS 5.1. All chemical substances to be identified and recorded into a chemical substance register. 5.2. Safety data sheets to be obtained from the supplier and to be less than 5 years old.

Australian Contact information to be included. 5.3. Ensure the SDS information is available to all staff. 5.4. Ensure all substances are stored in safe containers (if decanted) and labelled with:

the full name, and any safety and risk phrases

5.5. Ensure that all chemical substances are stored in approved cabinets or rooms. If the chemical substances are dangerous goods, then the specific storage and handling requirements obtained from the Regulations, Code of Practice and Australian Standard, must be implemented.

5.6. Identify and assess all risks in consultation with employees from chemical substances (and keep records for at least 5 years).

5.7. Review risk assessments every 5 years or when substances or work processes change or an incident occurs.

5.8. Eliminate or minimise the risk of injury/illness from exposure to substances 5.9. Train all employees in the safe handling, use and storage of chemicals, including how to

read an SDS.

Example SOP – Chemical Substances Page 2 of 2

5.10. Conduct atmospheric monitoring where indicated by a risk assessment and keep records for 30 years.

5.11. Provide information to employees on the results of atmospheric monitoring or health surveillance.

5.12. Ensure all contractors provide relevant SDS and their employees are trained in the use of chemical substances.

6. ROLES AND RESPONSIBILITIES All RFTG Staff, Contractors and visitors (if applicable) to site to comply with the SOP requirements.

7. PERFORMANCE INDICATORS All SDS information current All chemical substances labelled All chemical substances stored safely and no spill or exposure incidents

8. RECORDS

SDS sheets Workplace Inspection records

9. ATTACHMENTS

Chemical Substance Register.

Example SOP – PPE&C Use, Decontamination & Cleaning Page 1 of 6


PERSONAL PROTECTIVE EQUIPMENT AND CLOTHING – USE, DECONTAMINATION AND CLEANING

1. PURPOSE The purpose of this standard operating procedure is to ensure that all personnel involved in practical and hot fire training at RFTG’s wear appropriate Personal Protective Clothing (PPC) and understand correct cleaning and decontamination procedures.

2. SCOPE This procedure applies to all Practical and Hot Fire Training at RTFG’s and off site locations where PPC is to be worn. It also includes information for decontamination of the PPE following structural Fire Training. The PPE decontamination procedure is applicable for Fire Training ground purposes only. Decontamination may be required when fire training with potentially contaminated firewater and AFFF (foam).

3. REFERENCES

3.1 Related Documents Safety First System Procedures and Guidelines Chief Officer’s Standing Orders:

6.00: Training and Competence 11.00: Health and Safety

Chief Officer’s Standard Operating Procedures: Section 6: Training and Competence Section 11: Health and Safety

3.2 Other Links and References

CFA Act 1958 CFA Regulations 2004 Field Training Ground Management Manual, 2005. NFPA (National Fire Protection Association) Standard 1851 (2008)- Standard on

Selection, Care and Maintenance of Protective Ensemble for structural fire fighting and proximity fire fighting.

3.3 Delegations

All RFTG staff


4. DEFINITIONS

PPE personal protective equipment

PPC personal protective clothing

PPE&C personal protective equipment and clothing

AFFF aqueous film forming foam

5. PROCEDURE 5.1. PAD Supervisors/ Instructors must ensure that personal protective equipment (PPE) and

clothing is provided, maintained and worn where a hazard cannot be eliminated and its use will minimise risk at work.

5.2. PAD Supervisors/Instructors must identify any foreseeable risks associated with the practical and hot fire training and implement action to control the risk by the provision of suitable PPE or clothing.

5.3. All personnel must be trained and instructed in the use (including fit and adjustment) and

maintenance of the equipment or clothing.

5.4. Where the use of personal protective equipment could affect communication, steps must be taken to ensure this does not present a risk.

5.5. All CFA personnel involved in practical and hot fire training conducted at, or managed by

RFTG, shall wear current approved issued PPC in accordance with CFA Standard Operating Procedure 11.03 Schedule 1, unless included by exception in this SOP.

5.6. As well as those categories listed in CFA Standard Operating Procedure 11.03 Schedule 1,

Wildfire Protective Clothing Ensemble is the minimum level of PPC which is able to be worn by personnel participating in:

Defensive LPG and defensive Flammable Liquid training HAZMAT training where chemical clothing is not required; Pump training and training involving the use of hose-lines, small gear, and other

fire-fighting and ancillary equipment; Training drills involving flammable liquid spills.

5.7 Personal Protective Clothing requirements for non live fire training shall consist of CFA issued clothing approved for the task, EG Specialist Rescue or Fire Investigation, or as determined by the PAD Co-ordinator following a Risk Assessment being undertaken

5.8 Personnel from organisations other than CFA who are participating in practical and hot fire training are required to wear either:

PPC issued by their organisation where such protective clothing is designed to provide protection from the hazards associated with the training undertaken, or

PPC issued by the RTFG.


5.9 In accordance with PAD Brief, students participating in practical and hot fire training drills may wear differing levels of PPC. In such instances, the instructor shall ensure that the tasking of students is consistent with the level of PPC worn by the student.

5.10 For non-training activities, the following clothing shall be worn as a minimum:

Safety footwear Safety Vest Safety goggles Industrial Helmet Gloves

5.11 The Instructor may allow students to dress down and remove Turnout Coats and/or Helmets where the removal of such equipment does not compromise safety and is conducive to the activity being undertaken: for example, when making up equipment. Turnout trousers/overalls and gloves shall not be removed in these instances

5.12 In this instance, a simple risk assessment should be conducted supporting the “Dress Down”” to be completed and filed with Course Training Records.

5.13 DECONTAMINATION OF PPE 5.13.1 Facilities for the cleaning and decontamination of fire fighting ensemble and

ensemble elements, to be provided. 5.13.2 Ensembles and ensemble elements shall be evaluated by the wearer for

application of appropriate cleaning level after each use. Advice to be provided by PAD Supervisor/ Instructor if trainee is unsure of cleaning levels required.

5.13.3 Soiled or contaminated elements must not be brought into the home, washed in home laundries, or washed in public laundries unless the public laundry has a dedicated business to handle protective ensembles and ensemble elements.

5.14 ROUTINE CLEANING 5.14.1 The user (wearer) of the PPE is responsible for the routine cleaning, maintenance

and inspection of their issued ensemble and ensemble elements. 5.14.2 The CFA will examine the manufacturer’s label and user information for instruction

on cleaning and drying specifically for the ensemble or ensemble element. This will be incorporated into the CFA Operations Manual.

5.14.3 In the absence of manufacturer’s instructions or manufacturer’s approval of alternative procedures for the ensemble or ensemble element, the routine cleaning and drying procedures provided in this section shall be used.

5.15 ROUTINE CLEANING PROCESS

Prior to leaving PAD Training area:

Any dry debris to be brushed off Other debris gently rinsed off with water (water spray) Heavy scrubbing or spraying with high-velocity water jets such as a power

washer is not to occur at any time. Where necessary, a soft bristle brush shall be used to gently scrub, and the

ensemble or element shall be rinsed off again.


5.16 A utility sink for routine cleaning of ensemble or ensemble elements to be provided in

close proximity to the Training Area. The sink is to be used for cleaning purposes only using the following procedure:

1. Heavily soiled or spotted areas to be pre treated. Chlorine bleach, chlorinated solvents, active-ingredient cleaning agents, or solvents are not to be used without the ensemble or element manufacturer’s approval.

2. Water temperature shall not exceed 40 C. 3. Mild detergents with a pH range of not less than 6.0 pH and not greater than 10.5 pH as

indicated on the product SDS or original product container to be used. 4. Protective gloves and eye/face splash protection to be worn. 5. Element(s) shall be gently scrubbed using a soft bristle brush 6. Element(s) shall be thoroughly rinsed 7. Element(s) shall be inspected and, where necessary, shall be rewashed or submitted for

advanced cleaning procedures. The manufacturer shall be consulted if stronger cleaning agents are required.

8. Elements shall be dried in accordance with the section 5.22. 9. Following the routine cleaning procedure, the utility sink shall be rinsed.

5.17 Additional Requirements for Routine Cleaning of Ensemble Elements

5.17.1 Routine cleaning procedures for cleaning garment elements to be used only for

spot cleaning of the element and must be performed in a designated utility sink. 5.17.2 To avoid cross contamination, ensemble element layers to be isolated whenever

possible

5.18 Additional Requirements for Routine Cleaning of Helmet Elements 5.18.1 If it is necessary to totally immerse the helmet, the impact cap is to be separated

from the helmet shell. Each element component shall be washed and dried separately before reassembling.

5.18.2 Solvents are not to be used to clean or decontaminate helmets or helmet components. The manufacturer is to be consulted if stronger cleaning agents are required.

5.18.3 Helmets are not to be machine dried using equipment that produces mechanical action from tumbling or agitation.

5.19 Additional Requirements for Routine Cleaning of Glove Elements 5.19.1 Glove elements are not to be machine dried using equipment that produces

mechanical action from tumbling or agitation.

5.20 Additional Requirements for Routine Cleaning of Footwear Elements 5.20.1 Footwear elements are not to be machine dried using equipment that produces

mechanical action from tumbling or agitation.


5.21 Additional Requirements for Routine Cleaning of Proximity Fire Fighting Ensembles and Ensemble Elements

5.21.1 Outer shell and other radiant reflective components of proximity fire fighting protective ensembles and ensemble elements are not to be cleaned with any abrasive cleaning devices.

5.21.2 Where routine cleaning fails to render the ensemble of ensemble element(s) sufficiently clean for service, the ensemble or ensemble element(s) shall receive advanced cleaning in accordance with CFA operational procedures.

5.22 Drying Procedures The manufacturer’s label and user information to be reworded for instructions on drying procedures of the ensemble or ensemble element. Where information is not provided or available, the following procedure is to be implemented for air drying:

Place elements in an area with good ventilation. Do not dry in direct sunlight

For machine drying:

The recommended capacity of the machine is not exceeded All closures, including pocket closures, hooks, loops, snaps, zippers, and hooks and

dees to be fastened A “no heat”or “air dry” option to be used, if available. In the absence of a “no heat” or “air dry” option, the basket temperature shall not

exceed 40 C The use of a heat cycle to be discontinued prior to the removal of all moisture from

the ensemble or ensemble elements The remainder of the drying process to be accomplished by a “no heat”machine

setting or removal of the ensemble or ensemble elements from the machine dryer to air dry.

6. ROLES AND RESPONSIBILITIES 6.1. PAD Instructors/ Supervisors Identify any foreseeable risks associated with the practical and hot fire training and implement action for risk control through provision of PPE and PPC. Ensure all PPE and PPC is cleaned at the completion of hot fire training. 6.2. All Trainees/ Other Site Staff

Ensure requirements of the SOP are implemented at all times.

7. PERFORMANCE INDICATORS No incidents of health problems related to exposure to contaminated turnout clothes or

other PPE. No exposure to hot fire contaminants from training activities.


8. RECORDS PPE training records PPE cleaning records PPE Inspector/Serviceability Record

ATTACHMENTS

Nil.

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