DOE FIRE SAFETY
WORKSHOP
Argonne National Laboratory
April 16-19, 2007
Eau de Code: The Essence
of National Fire Protection
Codes and Standards
Dennis Kubicki, P. E.
Office of the Senior Advisor for
Environment Safety & Health
NNSA Headquarters (NA 3.6)
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Introduction
Dennis Kubicki, Bill Boyce and Nicole
Kidman were stranded on a remote
desert island. After a couple of days
pondering their fate, Nicole turns to
the two men and says…
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DOE O 420.1B and 10 CFR Part 851
require compliance with NFPA
Paragraph 3.a.(3) of Chapter II of DOE O
420.1B requires that contractors “meet or
exceed …NFPA codes and standards…”
 Paragraph 2.(b) of Appendix A to 10 CFR
Part 851 requires that contractors have a
comprehensive fire safety program that
includes “meeting applicable building
codes and NFPA codes and standards”

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DOE Fire Safety and Emergency
Response Implementation Guides
The existing 1995 DOE Implementation
Guide affirms the need to meet or exceed
NFPA codes and standards.
 The (still pending) new DOE Fire Safety
and Emergency Response Implementation
Guide explicitly lists the governing NFPA
codes and standards, including those for
DOE Fire Departments and brigade.

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Yes. But…
There are 161 specific NFPA codes and
standards that are delineated in the Fire
Safety and Emergency Response
Implementation Guide as being applicable
or “likely to be applicable to contractors”
under the provisions of the Order and
Rule.
 These 161 represent thousands of
individual requirements.

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How should we assess
compliance with NFPA?
“Gap analyses” seem to have been the
expectation in some DOE issued guidance
on compliance with 10 CFR Part 851.
 “Line-by-line” code compliance reviews
are explicitly discouraged in the DOE fire
safety guide and in the answers to FAQs
on Part 851 related to fire safety and
emergency response.

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How DO we usually assess
compliance with NFPA?
By doing line-by-line reviews with the
codes and standards in hand…….NOT!
 By having a sense of the fundamental
principles and concepts in our
consciousness, with the occasional use of
the standards for clarification……LIKELY!
 But we all need routine reinforcement on
the essential principles and practices.

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What are the “essentials?”
Let’s consider a few NFPA standards…
Take NFPA 1, “Uniform Fire Code,”
chapters, 531 pages
73
Group exercise: What are some of the
fundamentals of this code?
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NFPA 1 Fundamentals
“Equivalency Concept” (I bet that wasn’t
on your list.) Alternatives are OK when
approved by the (DOE) AHJ.
 A comprehensive documented fire
prevention program with defined goals,
criteria, roles and responsibilities.
 Documented reviews of changes (new
construction, occupancy) by a qualified
individual (FPE, FD officer, FM).

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NFPA 1 (continued)…
Multiple safeguards (defense-in-depth) to
protect people, processes, facilities.
 (Documented) Identification and
evaluation of hazards.
 Delineation of safeguards (active, passive,
procedures, training) to mitigate the risk
from these hazards.*

*Sub-tier essentials
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NFPA 1 (Sub-tier Essentials)








Procedures to control combustibles
Procedures to control ignition sources
Fire-resistant construction
Compartmentation (storage requirements, etc.)
Fire (detection) and alarms
Fire fighting equipment
(Fire suppression systems)
Training of workers, etc.
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NFPA 1 (continued)…
IT&M of the safeguards
 Self assessments
 Interim safeguards (when problems occur)
 Abatement plans / corrective action plans
 Tracking system for violations

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NFPA 1 (continued)
If a contractor’s approach satisfies all of
these essentials, the degree of safety
concern should diminish to “secondary”
issues. (e.g. A contractor has flammable
liquid storage containers and cabinets, but
they are not all in good working condition.)
 Such secondary issues can be handled
less rigorously, such as by a “punch list.”

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Let’s focus on an emergency
services-related NFPA Standard.
Consider NFPA 1500, “Fire Department
Occupational Safety and Health Program”
What are its essential requirements?
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NFPA 1500
“Equivalency Principle” in Paragraph 1.4.1
 Written policies, program and procedures
including a “Risk Management Plan.”
 A (written) training, education, and
professional development program.
Training should address the hazards from
the full spectrum of responsibilities (Note
Part 851 “pilot inspection” at ORNL.)

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NFPA 1500 (continued)
An (safety-focused) inspection program for
PPE, apparatus, equipment, including an
inspection for hazards in FD structures.
 Code-complying PPE.
 Safety-conscious emergency operations.
Incident management system
Adequate communication
Personnel accountability
RIT

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NFPA 1500 (continued)

Medical and Physical Performance
FD Physician
Medical exams (See NFPA 1582)
Annual physical qualifications /fitness for
duty
Health and fitness program
Member assistance and stress
programs
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Consider the Life Safety Code
About 275 pages of explicit criteria
Thousands of individual requirements
How would you characterize the
essentials?
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NFPA 101
“E…. P…” (Paragraph 1.4.3)
 Two, remote, traversable means of egress
 Protected travel path
 Adequate illumination
 Exit signage
 Stuff addressed by other codes and
standards (alarms, HVAC, etc.)

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The Feared 1710 Standard
DOE has issued a one-and-one-half page
“Implementation Plan.” So, the answer to
the following question should be easy.
What are the essential requirements of
NFPA 1710, “Organization and
Deployment of Fire Suppression
Operations and Special Operations to the
Public by Career Fire Departments?”
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NFPA 1710
Equivalency (Paragraph 1.3) DOE has
stated that equivalency can be
demonstrated in a reasonably
comprehensive Baseline Needs
Assessment or comparable document.
 Delivery objectives (including response
times) for every service component.
Arguably, this should be a DOE task.

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NFPA 1710 (continued)
An annual self-assessment with a
quadrennial report to DOE. (A selfassessment is also a requirement of 10
CFR Part 851.)
 A delineation of services. (A BNA will
address this.) Note EMS treatment levels.
 Staffing to fulfill the responsibilities. (There
will never be consensus on this issue.)

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NFPA 1710 (continued)
Medical oversight / review (of EMS)
 Training that addresses the responsibilities
 Implementation of the Incident Command
System
 An occupational safety and health
program
 A dialogue leading to a “treaty” between
the DOE and the fire department.

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Summary / Conclusions
10 CFR Part 851 and DOE O 420.1B
require compliance with NFPA codes and
standards.
 The spectrum of applicable requirements
is too vast to expect literal, line-by-line
conformance evaluations.
 Contractors and DOE should focus
compliance efforts on the core concepts
from each code or standard.

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Recommendation
The DOE Fire Safety Committee and Fire
Chiefs Committee should consider
identifying the core principles and
practices from the applicable NFPA codes
and standards. (This effort, if managed
efficaciously, should require only a few
weeks of effort.)
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Questions?
Dennis Kubicki, P.E.
301-903-4794
dennis.kubicki@nnsa.doe.gov
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Whiteboard Input to Dennis Kubicki
At 2007 DOE/Contractor Fire Protection Workshop
During the presentation by Dennis Kubicki, “Eua de Code,” The following items were
submitted by attendees in response to being asked what they thought of the NFPA
Standard indicated:
NFPA 1
Fire Prevention
Maintenance
Identification and Control of Hazards
Water Supply
Housekeeping
NFPA 1500
Medical Standards
Personal Protective Equipment
Fire Apparatus and Equipment
Station Condition
NFPA 101
Equivalency
Egress
Travel Distance
Lighting
Occupancy
NFPA 1710
Response Times
Staffing
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