ARFF and the control and rescue gap: why risk assessment is not risk aversion
Published: 19 March, 2012
Aviation rescue and fire fighting (ARFF) is characterised by a different timescale and set of priorities to normal civilian fire fighting. Time is of the essence. It is essential to minimise the delay between controlling the fire and carrying out any rescue of passengers and crew. The overall operational window is short by other fire fighting standards, writes Roger Klein.
The accepted standard response time for viable rescues is up to two minutes and certainly no longer than three minutes. The aim of controlling the fire is to facilitate rescue – not to save the aircraft. This means creating and maintaining survivable conditions for passengers and crew.
What is the overarching requirement for ARFF and indeed any fire and rescue activity? A viable and comprehensive standard operating procedure (SOP) culture is required rather than one over-ridden by considerations of potential legal liability or a management desire to save money thus trumping the public service imperative1. Is this currently an issue? Yes, it is. And there are coroner’s inquests which have identified this issue as unacceptable. Comments arising from the coroner’s inquests2 into the London bombings of 5 July 2005 were relatively restrained “…Risk assessments and decisions may have to be revisited as protocols are overtaken by events…”
Sheriff Desmond Leslie’s less so at the enquiry into the death of Allison Hume who fell down a disused mineshaft near Kilmarnock and died because of delays by the fire service in initiating a rescue. The full text3 of Sheriff Leslie’s official determination makes exceedingly uncomfortable reading for any serving fire officer. Rather than paraphrase the findings, extracts from his excoriating attack on a risk-averse management culture driven by legal and financial considerations together with a concern for the safety of their own personnel over and above that of members of the public, as well as a slavish adherence to brigade policy, are best quoted verbatim with the organisation and individual’s names removed.
Sheriff Leslie wrote, ‘…I was not directed to any legislation, or protocol, which allows me to accept the views expressed by Group Commander X, or Assistant Chief Fire Officer Y, that the type of rescue they would have required to undertake with Mrs Hume, was not within the parameters of their engagement… I found the evidence of Group Commander X, and Group Commander Z, to be focussed on self-justification for the action or non-action taken… I found their evidence to be bullish, if not arrogant, in their determination to justify the subservience of the need to carry out a rescue to the need to fulfil to the letter [their] Fire and Rescue Service "Brigade" policy… Mr X, in particular, considered that the rescue operation was "a success". In his view he had adhered to the policies and procedures set out by [their] Fire and Rescue Service… There had been no casualties other than the one to whom the Service was called upon to rescue...
Unfortunately this was not a successful operation: a woman died who had not only sustained survivable though life threatening injuries… I consider that the views expressed by Mr X and Mr Z were of a fundamentalist adherence to [their] Fire and Rescue Service policy. They rigidly stood by their operational guidelines… Assistant Chief Fire Officer Y conceded that the powers given to [their] Fire and Rescue Service under s13 and s14 of The Fire (Scotland) Act 2005 allowed a measure of flexibility to perform a rescue but only in suitable and reasonable circumstances… That statutory licence would have provided the mandate to the fire fighters who were anxious to deploy and adapt the equipment available to them to attempt a rescue…”. Devastating, hard-hitting and an embarrassment to any professional service!
Unfortunately there have also been other less extreme examples of failure to act by the emergency services in recent years driven by the management mantra of self-protection of their personnel. Partly in response to this climate the Health & Safety Executive has felt the need to define acts of heroism4 within the fire service and to endorse the recommendation that individual firefighters should not be at risk of investigation or prosecution, under health and safety law, if they have put themselves at risk as a result of heroic act. There are still practical problems with this definition. A firefighter would have to act entirely of their own volition, without putting anyone else at risk. The HSE also considers these actions have to be carried out ‘in the absence of instructions from senior officers’; this would have posed serious problems in the Hume mineshaft incident as senior officers ordered the withdrawal of rescue personnel!
What are the specific requirements for controlling fire in ARFF? First and foremost a rapid response time by rescue vehicles with sufficient fire power (foam power!). Response times and total number of airside crash tenders at any point on an aerodrome are governed by international regulations and depend on the assignment of an International Civil Aviation Organisation (ICAO) Category for the airport.
ICAO has identified three priorities for ARFF operations: (i) to save lives; (ii) to create and maintain survivable conditions, and; (iii) to initiate the rescue of those occupants, crew or passengers, unable to make their escape without direct aid. Apart from ICAO requirements it should not be forgotten that fire and rescue Services in the UK have obligations place on them for dealing with incidents involving aircraft under the Fire and Rescue Services Act 2004, the Fire and Rescue Services (Emergencies) Order 2007, and the Civil Contingencies Act 2004 for Category 1 and 2 Responders. The UK Department for Communities and Local Government (DCLG) recently issued the Chief Fire & Rescue Adviser’s comprehensive guidance on fire and rescue service involvement in ARFF incidents5.
There are two critical characteristic times for any incident; the time taken to reach the site of the incident and the time interval between reaching the site and initiating operations, in the case of ARFF, search and rescue activities. Clearly the attendance time is determined by fire station placement on the aerodrome and ARFF vehicle capabilities. The really critical and sometimes unacceptable gap is between controlling the fire and initiating search and rescue or identification operations. This gap is determined in the main by pre-planned systems of work or standard operating procedures (SOPs) which must be flexible and fit-for-purpose, focussed on a potentially dynamic incident and on the primary purpose of ARFF, that is the saving of life, not on a restrictive risk-averse set of management policies aimed primarily at saving money or protecting their own personnel. The key to managing this critical gap is for the incident commander to carry out a full and comprehensive assessment of risk based on their training and experience as well as on the conditions on the incident ground.
Risk assessment is often misunderstood. It is not about preventing one from carrying out some necessary procedure. It is also not about generating a perceived zero-risk situation. It is about carrying out the indicated procedure in the safest possible manner thus minimising the risk given the requirements of achieving an operationally successful conclusion, ie the public service imperative of saving and protecting human life. The elements of risk assessment are well described in the UK Health & Safety Executive’s guidance HSG65 6. In its simplest form it involves (i) identifying hazards with the potential to cause harm, (ii) identifying the risks posed by these hazards, ie the likelihood and consequences of harm actually being caused, and (iii) instituting measures to eliminate, reduce or control the risks.
Incident ground SOPs should concentrate on eliminating, reducing or controlling risks. Tactical procedures together with personal protective equipment (PPE) are the standard fire service methods of achieving this. Unfortunately many management policy-driven SOPs also factor in legal and financial risk at the expense of the public service imperative.
Given the dynamic nature of decision making on the incident ground – mistakes cannot usually be corrected but have to be lived with – full monitoring and auditing procedures which would normally be considered part of a comprehensive risk management strategy are not practical. Balancing the risks to be undertaken effecting a rescue is basically no different to other fire fighting activities. If human life is to be saved relatively high risk to emergency service personnel is acceptable. Otherwise it is not. Experienced and informed cost-benefit analysis of the risk scenario on the ground will lead to a more effective outcome in terms of the tactical priorities. Risk assessment is also needed to maintain the correct levels of manning so as to ensure an escape path is maintained at each aircraft exit.
A system of incident command should normally form an integral part of a standard SOP. A minimum of equivalent to Silver and Bronze levels of command is required; Bronze command at the incident ground level to deal with tactical issues, with Silver being responsible for overall management of the incident at strategic level, especially the provision of resources and any inter-agency liaison. In the case of a larger incident or the incident escalating – for example, an aircraft crash off-site in a residential or industrial area, or involvement of an airport terminal or ground services building – Gold command would be necessary. ARFF operations on helidecks, especially those associated with the oil and gas industry or heliports attached to hospitals, would require at least Silver and Bronze levels of incident command because of the real possibility of the incident escalating and involving other high risk systems or large numbers of people.
Technical requirements for crash tenders and other equipment are covered by ICAO regulations. In principle though these must, of course, be fit-for-purpose. Enough fire fighting foam and water must be carried, and the monitors used must have sufficient throw. The higher pump pressures required for extended throw may need special precautions and training. Regular maintenance and testing of the crash tenders and their foam delivery systems is essential, preferably with real finished foam as substitutes such as water or training foam will not mimic accurately operational behaviour.
The foam extinguishing agent used must have been approved to ICAO Level B. Compared to fire fighting foams used in the petrochemical and chemical process industries, foam for ARFF use has certain specific requirements, including fast extinction (knock-down) times for Class B hydrocarbon fuels and good (ie slow) drainage characteristics. This last is important in ensuring that foam will remain coating the fuselage and wings for as long as possible. In addition slow drainage times mean that the foam will not bleed off runway or taxi areas too rapidly into the surrounding ground, causing concerns for the environmental protection of groundwater. Extreme long-term stable blanketing for vapour suppression is not as important in the aviation industry since incident timescales are a great deal shorter than in the chemical process industries.
Increasing sensitivity amongst national and international regulators as well as governments to improve the environmental footprint of aviation operations is driving end-users – airport authorities and heliport/helideck operators – to consider the impact of potential ARFF incidents on and off-site. Physically restricting the run-off of extinguishing agent into the subsoil or ocean during operations and training is one solution. Other technological solutions include using fluorine-free foams in order to avoid discharging fluorochemicals to the environment or using compressed-air-foam systems (CAFS).
Finally a comprehensive program of exercising the techniques needed for ARFF under as realistic conditions as possible ensures a robust and resilient system of work embodying tried and tested SOPs, underpinned by operational risk assessment and adaptability to circumstance since no situation can be engineered to be completely risk-free for emergency service personnel.
1. HSE Occasional Paper Series OP8: §18 This situation has given rise to the concept of “the public service imperative”. When considering what is reasonably practicable, inspectors should take account of this imperative, which embodies the role and functions of the fire fighters, along with the societal expectation of what they will do. Reasonable practicability will therefore include not only consideration of the costs of a particular activity and the benefits to be gained from that activity, but also the nature of the work of the fire service and what society expects from them. Parallels can be found within the activities of the MoD and the defence imperative (see OC 335/1 paragraph 4); and the police service (see OC 334/4, paragraph 3).
5. http://www.communities.gov.uk/publications/fire/ aircraftincidents – Department of Communities and Local Government, Chief Fire & Rescue Service Adviser: Fire and Rescue Service Operational Guidance – Aircraft Incidents, 2012.
6. http://books.hse.gov.uk/hse/public/saleproduct.jsf?catalogue Code=9780717612765