Prohibition of Self-Contained Breathing Apparatus (SCBA) Program
April 12, 2017
In Reply Refer To:
9210 (CA943)P
EMS TRANSMISSION: 04/13/2017
Instruction Memorandum No. CA-2017-009
Expires: 12/31/18
To: District Managers, Field Managers, and District Fire Management Officers
From: State Director
Subject: Prohibition of Self-Contained Breathing Apparatus (SCBA) Program
Program Area: Fire Management
Purpose: This Instruction Memorandum (IM) is to advise BLM California leadership that the SCBA program is indefinitely suspended.
Policy/Action: BLM California Fire Management employees are no longer authorized to use SCBA for the suppression of non-wildland fires. SCBA and related components shall be removed from BLM California fire apparatus and placed in an appropriate storage facility awaiting future disposition.
Timeframe: Effective immediately
Budget Impact: None
Background: Current policy regarding Respiratory Protection is described in Chapter 7 of the Interagency Standards for Fire and Aviation Operations (Red Book). This policy states "Respiratory protection should only be implemented once engineering and administrative controls are exhausted. The need for respiratory protection during wildland fire operations must be determined by each agency."
BLM California developed policy stating "all employees engaged in initial attack activities where smoke containing (or potentially containing) hazardous/toxic materials from dump fires, vehicle fires, structure fires, or other respiratory hazards not routinely associated with wildland fire suppression will be equipped with, and trained in the use of Self Contained Breathing Apparatus (SCBA)."
After extensive review, it was determined that the SCBA program is not in compliance with requirements found in OSHA’s Respiratory Protection Standard 29 CFR 11910.134, NFPA 1851 standards for the care and maintenance of firefighting protective clothing, and Respiratory Protection requirements found in Red Book Chapter 7.
Mitigations: Red Book policy further states that "Managers and supervisors will not knowingly place wildland firefighters in positions where exposure to toxic gases or chemicals that cannot be mitigated and would require the use of self-contained breathing apparatus." BLM California policy also states that "Employees without the appropriate personal protective equipment or training will not enter into hazardous or potentially hazardous atmospheres."
Until such time that the BLM California SCBA program is re-instituted, utilize the "Safety Precautions" listed in the 2016 North American Emergency Response Guidebook if dispatched to incidents that produce or have the potential to produce toxic vapor, fumes smoke, and spills.
If you have any questions contact Van Arroyo, Deputy State Fire Management Officer for Operations, at 916-978-4442.
Signed by:
Martha L. Maciel
Acting State Director
Authenticated by:
Kathleen Christian
GIS/Applications Mgmt Branch, CA-946