Risk Assessment of Proposed ARFF Standards (2011)

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20 CHAPTER 3 COMPARISON OF FAA, ICAO, AND NFPA STANDARDS This Chapter discusses the authority of the Federal Aviation Administration (FAA), the International Civil Aviation Organization (ICAO), and the National Fire Protection Association (NFPA) to issue standards for aircraft rescue and fire fighting (ARFF). The differences between the ARFF standards issued by these organizations are identified and where information was available the basis for the standards is provided. AUTHORITY OF FAA, ICAO, AND NFPA TO ISSUE ARFF STANDARDS Federal Aviation Administration (FAA) Under Title 49 of the United States Code, § 44706, the FAA is authorized to certificate airports receiving scheduled air carrier service with aircraft having more than nine passenger seats and unscheduled air carrier service with aircraft having more than 30 passenger seats. Section 44706 is implemented by 14 CFR Part 139, the FAA regulation that sets forth the requirements for airport certification. Part 139 contains specific requirements for operators of airports with air carrier passenger service, including requirements for ARFF. Part 139 is not applicable to heliports or to airports that: a. are served by large all-cargo aircraft only, b. are in Alaska and are served by air carrier aircraft with less than 31 passenger seats, or c. do not have air carrier service that uses aircraft with more than nine passenger seats. The FAA adopted Title 14 CFR Part 139, Airport Certification, in 1972. Since then, the regulation has been amended on several occasions and substantially revised in 1988 and 2004. Part 139 requirements concerning aircraft rescue and fire fighting are found in Sections 139.315, 139.317 and 139.319. The requirements in 14 CFR Part 139 are established by the Federal rulemaking process and codified in Federal regulations. Prior to beginning the rulemaking process the FAA can seek input from interested parties. This can be done informally through public contact, participation on an industry committee or open forum, or formally through the Aviation Rulemaking Advisory Committee. Once the rulemaking process begins, e.g., by issuance of an Advance Notice of Proposed Rulemaking (ANPRM) or Notice of Proposed Rulemaking (NPRM), agency rules on ex parte communications apply. The regulatory process generally starts with the development of a regulation that is published as an NPRM. The NPRM is published in the Federal Register and public comment is sought for a set comment period, typically 45 or 60 days. Once the public comment period closes, the FAA will evaluate all the comments and decide whether to withdraw the proposed rule, adopt it as a final rule, or adopt a revised rule to reflect the comments received. A final rule may impose less burdensome requirements than the proposed rule, but cannot impose more stringent requirements than proposed in the NPRM without a supplemental notice and additional opportunity for public comment. All rules are required to undergo a benefit/cost analysis. The proposed rule will generally not be adopted unless the benefits of the rule outweigh its costs. If the final version of the rule has a benefit-cost ration greater than one, the agency may decide to issue the rule. The various requirements contained in the final rule then become required for entities and

21 persons within the applicability of the rule. For Part 139, this includes certificated airport operators and their employees. The FAA also develops and publishes standards in both advisory circulars and engineering briefs. These standards show an acceptable means of complying with the requirements of the rule, but can have regulatory effect only if incorporated by reference in an agency regulation. The standards may also be required as a condition of FAA grant agreements. If an airport operator is using Federal funds for airport development, the operator is required as a condition of the grant to comply with the standards set forth in the Advisory Circulars and engineering briefs that apply to the project. Consequently, these standards are used by airport operators, consultants and contractors in designing airport projects, putting together specifications for the procurement of airport equipment, and in meeting the requirements of the airport certification program (Part 139). Individuals, airport operators, manufacturers, or trade associations may request that a new standard be developed or an existing one be changed. For airport Advisory Circulars, that request is made to the Airports line of business in the FAA. In some cases, the FAA may contract with an organization or consultant to investigate a particular problem and propose viable solutions. In other cases, the FAA may initiate a research and development project at the Technical Center. The agency generally reviews existing Advisory Circulars on a 5-year schedule to consider the need for revision. The FAA may decide to change an existing advisory circular or issue a new one, as appropriate. It may do this in-house or it may call a meeting with industry to consider a change to the existing standards. Once there is agreement to add or change (or, in some cases, to delete) a standard, the FAA will produce a draft change to the appropriate advisory circular. If the standard is very specialized or intended only as an interim standard, the FAA may issue it in the form of an engineering brief. The draft change is posted on the FAA’s website for comment. Anyone may comment on the draft. Typically comments are received from various aviation industry organizations, such as the Airline Pilot Association, the American Association of Airport Executives, the Airports Council International – North America, the Airports Consultants Council, and the Air Transport Association. The FAA will consider all comments received during the comment period and prepare a disposition of the comments. Based upon the comments received, the draft change may be withdrawn, modified to address the comments received, or issued as originally proposed. The final advisory circular change is approved by the appropriate Office Director (for engineering standards, the Director of Airport Safety and Standards) and reviewed for legal sufficiency by the Office of Chief Counsel. After approval by the Office of the Chief Counsel, the Director issues the revised Advisory Circular and posts it on the FAA Airports website. International Civil Aviation Organization (ICAO) The ICAO is a special agency of the United Nations linked to the Economic and Social Council. The constitution of ICAO is the Convention on International Civil Aviation, drawn up by a conference in Chicago in November and December 1944, and to which each ICAO Contracting State is a party. ICAO works in close co-operation with other organizations of the United Nations, such as the World Meteorological Organization, the International Telecommunication Union, the Universal Postal Union, the World Health Organization and the International Maritime Organization. Non-governmental organizations that participate in ICAO’s work include the International Air Transport

22 Association, the Airports Council International, the International Federation of Air Line Pilots’ Association and the International Council of Aircraft Owner and Pilot Associations. ICAO’s mandate is to ensure the safe, efficient and orderly evolution of international civil aviation. This is done through the issue of Standards and Recommended Practices (SARPs), which are adopted and incorporated as Annexes to the Convention on International Civil Aviation. The principal body concerned with the development of technical standards and other provisions is the Air Navigation Commission. Its primary role is to advise the ICAO council on air navigation issues. It is composed of fifteen experts with appropriate qualifications and experience in various fields of aviation. Its members are nominated by Contracting States and are appointed by the Council. They are expected to function as independent experts and not as representatives of their States. ICAO Annex 14, paragraph 1.2.2 states: “the specifications, unless otherwise indicated in a particular context, shall apply to all aerodromes open to public use in accordance with the requirements of Article 15 of the (Chicago) Convention.” However, Annex 14 standards apply to states (countries) and are only applicable to airport operators if their country adopts the Annex 14 standard. In addition to standards, ICAO also provides “Recommendations.” Countries may adopt or not adopt ICAO standards and recommendations. The ARFF standards and recommended practices adopted by ICAO are found in Annex 14, Chapter 9, Section 9.2 (24). The development of Standards and Recommended Practices to ICAO Annex 14 is a lengthy process that starts with a member country or an observer (such as Airports Council International or International Federation of Airlines Pilot Association) requesting the Working Group Chair to allow the topic be added to a meeting agenda. Along with the request is the submittal of a discussion paper to the Working Group and a presentation of supportive evidence. Although it is not an ICAO requirement, the submitter may include a benefit/cost analysis as part of its proposal. If the majority of the Working Group feels the Discussion Paper [proposal] has merit, then the Working Group will either accept the presented arguments or may ask for more supportive evidence to determine a new or revised Standard or Recommended Practice. Once the Working Group has considered the change and agreed to it, the chair will submit the proposal to the Aerodrome Panel, which directs the various Working Groups. If the Aerodrome Panel accepts it, then the item will go up the chain of command within ICAO for further discussion and approval or disapproval. Once the ICAO approves the change, the item is sent to all the various member countries who will then be asked to vote on the measure. If a majority of countries vote to adopt the Standard or Recommended Practice or change to the SARP, then the change is made and given an effective date. This process can take up to 2 or 3 years. In setting standards and recommendations that apply to airports throughout the world, ICAO recognizes that all countries or all airports within a country may not be able to comply with those standards and recommendations. The reasons for non-compliance vary but often are related to the economic feasibility of the standard including the cost to implement and the expected benefit to be received. For this reason, countries may adopt or not adopt ICAO standards and recommendations. If a country does not adopt a

23 standard, it is required to file a “difference” with ICAO explaining what part of the Annex 14 standards that it does not comply with. The United States is a signatory country and an active member of the ICAO. Many of the SARPS published by the ICAO are reflected in the Advisory Circulars. Where the SARPS have not been adopted, the U. S. has filed the appropriate “difference." National Fire Protection Administration (NFPA) The mission of the international, nonprofit NFPA, established in 1896, is to reduce the worldwide burden of fire and other hazards on the quality of life by providing and advocating consensus codes and standards, research, training, and education. The NFPA develops, publishes and disseminates more than 300 consensus codes and standards intended to minimize the possibility and effects of fire and other risks. These codes are developed by technical committees and are adopted and enforced throughout the world. NFPA standards are written for airports of all sizes and types of operations, e.g., air carrier passenger service, air cargo, and general aviation operations. NFPA standards apply to airport operators if the state where the airport is located or the airport operator has adopted those standards. NFPA 403, Standard for Aircraft Rescue and Fire-Fighting Services at Airports (2009 Edition), is the principal standard governing ARFF, although there are a number of other NFPA standards that affect airports and airport operations (25). The following information with more detail can be found in the NFPA Brochure entitled “Codes and Standards, An introduction to the NFPA Codes and Standards Development Process.” The process for introducing or changing the NFPA codes and standards starts with a Call for Proposals. This Call for Proposals is a public notice asking for any interested party to submit specific written proposals on an existing document or a committee-approved new draft document. The responsible Technical Committee or Panel holds a meeting to consider and act on all the submitted Proposals. The committee or panel may also develop its own Proposals. A document known as the Report on Proposals (ROP), is prepared containing all the Public Proposals. Once the ROP becomes available, there is a 60-day comment period during which anyone may submit a Public Comment on the proposed changes documented in the ROP. The committee or panel reconvenes at the end of the comment period and acts on all public Comments. Approval obtained via written ballot in accordance with NFPA’s Regulations is required on all committee and panel actions. All of this information is compiled into a second Report, called the Report on Comments (ROC), which, like the ROP, is published and made available for public review for a seven-week period. Following the completion of the Proposal and Comment periods, there is yet a further opportunity for debate and discussion through the Association Technical Meeting that takes place at the NFPA Conference & Expo each June. The Association Technical Meeting provides an opportunity for the NFPA membership to amend the Technical Committee Reports (i.e., the ROP and ROC) on each proposed new or revised document. The NFPA Standards Council, as the overseer of the NFPA codes and standards development process, acts as the official issuer of all NFPA codes and standards. The

24 Council, if appropriate, issues the Document as an official NFPA code or standard. Subject only to limited review by the NFPA Board of Directors, the Decision of the Standards Council is final, and the new NFPA code or standard becomes effective twenty days after Standards Council issuance. NFPA does not have a requirement that a benefit/cost analysis be performed for any of its standards. The performance of such an analysis is left to the discretion of the jurisdiction or authority that decides to adopt the NFPA standard. For a more complete explanation of the roles of these organizations, please refer to the ACRP Web-Only Document 7: How Proposed ARFF Standards Would Impact Airports, submitted June 2009. CLASSIFICATION OF AIRPORTS FAA Currently, there are four classifications of air carrier airports under 14 CFR Part 139. Table 1 shows how these apply to passenger service in terms of aircraft seating capacity for scheduled and non-scheduled operations and the number of airports in each class. Effectively, a Class I airport can serve all sizes of aircraft (e.g., a Beech 1900 to a Boeing 747) while a Class III airport can have scheduled and unscheduled passenger services with aircraft of 30 seats or less. Table 1. Part 139 Airport Classification by Seating Capacity and Service Type Airport Class Scheduled Passenger Operations Non-Scheduled Passenger Operations Number of Airports* I 10 or more 31 or more 381 II 10 or more but less than 31 31 or more 50 III 10 or more but less than 31 30 or less 35 IV N/A 31 or more 89 *As of 9/02/2010 Due to the various sizes of aircraft serving Class I airports, they are further divided into five categories (each category is labeled as an index) for purposes of ARFF. The length of the longest scheduled aircraft serving the airport with more than five scheduled departures a day determines the Index: 1. Index A airports serve air carrier aircraft less than 90 feet in length 2. Index B airports serve air carrier aircraft at least 90 feet in length but less than 126 feet 3. Index C airports serve air carrier aircraft at least 126 feet in length but less than 159 feet 4. Index D airports serve air carrier aircraft at least 159 feet in length but less than 200 feet 5. Index E airports serve air carrier aircraft at least 200 feet in length Class II, III, and IV airports must meet the Index A requirements, at a minimum. However, Class III airports may substitute an alternate procedure using a fire fighting

25 response from the local community. This procedure is outlined in 139.315(e). In contrast to ICAO and NFPA, the FAA requirements for determining the ARFF Index do not take into account the width of the aircraft serving the airport. ICAO and NFPA The ICAO and the NFPA airport classifications are somewhat different than the FAA classifications. ICAO and NFPA use a classification based from Category 1 through Category 10. The first 3 categories describe smaller airports that do not have air carrier commercial service based on the FAA equivalent. The FAA Index A is equivalent to the ICAO and the NFPA Category 4 airport. The ICAO and NFPA standards consider both aircraft length and width to determine the airport’s category (equivalent to an FAA Index). Table 2 compares the manner in which all three standards categorize airports using differences in aircraft size. Table 2. FAA ARFF Index Comparison to ICAO and NFPA FAA Airport Index Aircraft Length (ft.) ICAO Airport Cat. Aircraft Length (ft.) up to but not including Width up to but not including NFPA Airport Cat. Aircraft Length up to but not including Width up to but not including Sample Aircraft A <90’ 4 78’ 24m 13.1’ 4m 4 78’ 13.0’ EMB120 A <90’ 5 91’ 28m 13.1’ 4m 5 90’ 13.0’ CRJ-200; Saab 340 B 90’ <126’ 6 127’ 39m 16.4’ 5m 6 126’ 16.4’ DC-9, A320 C 126’ <159’ 7 160’ 61m 16.4’ 5m 7 160’ 16.4’ B757-200: B767- 200ER D 159’ <200’ 8 200’ 61m 22.9’ 7m 8 200’ 23.0’ A300; B757-300 E >200’ 9 249’ 76m 22.9’ 7m 9 250’ 23.0’ A340-600; B777 E >200’ 10 295’ 90m 26.2’ 8m 10 295’ 25.0’ AN-225, A380 NUMBER OF VEHICLES FAA, ICAO, and NFPA Section 139.317 addresses, among other things, the number of vehicles required by each airport index/category. FAA allows some flexibility in the number of vehicles for Index B and C airports as can be seen in Table 3. While FAA and ICAO call for three vehicles for Index E airports (NFPA/ICAO categories 9 and 10), NFPA’s standard requires four vehicles. However, the actual number of vehicles may be affected by the response time standards, since meeting response times can require more than one ARFF station.

26 Table 3. Minimum Number of ARFF Vehicles Required ICAO/NFPA Airport Category FAA Airport Index Vehicles Example Aircraft ICAO FAA NFPA 4 A 1 1 1 DHC-8-100 5 A 1 1 2 ATR-72 6 B 2 1 - 2 2 B-737-300; Emb-145 7 C 2 2 - 3 3 B-757 8 D 3 3 3 A300; B-767-300 9 E 3 3 4 B-747-200; A340-400 10 E 3 4 AN-225; A380 QUANTITY OF AGENT FAA/ICAO/NFPA ICAO first considered standards for the quantity of fire extinguishing agent in 1972. The standards include the concept of theoretical critical area (TCA) and practical critical area (PCA). (These are the physical areas in which fire fighting is expected to take place.) The PCA is two-thirds the size of the TCA. A discussion of the TCA and the PCA as well as the mathematical formulas for the TCA and the PCA can be found in NFPA 403, Annex B. The FAA Advisory Circular 150/5210-6D, Aircraft Fire and Rescue Facilities and Extinguishing Agents, in Chapter 1, also discusses the concepts of control time and extinguishment time. The amounts of extinguishing agents to control and to extinguish a fire are determined separately. The quantities are named and defined as follows. Quantity Q1—The quantity of water required to obtain a one-minute control time in the PCA. (Advisory Circular 150/5210-6, Aircraft Fire extinguishing Agents, defines the control time as the time required from the arrival of the first fire fighting vehicle and the beginning of agent discharge to reduce the initial intensity of the fire by 90 percent. The equipment and techniques to be used should be capable of controlling the fire in the PCA in 1 minute.) The formula for the water required for control (Q1) in the PCA can be found in NFPA 403, Annex B. Quantity Q2—The quantity of water required for continued control of the fire after the first minute or for complete extinguishment of the fire or both. The amount of water required for Q2 cannot be calculated exactly, as it depends on a number of variables, consisting of the following: 1) Aircraft Size—Aircraft size reflects the potential level of risk. This risk factor is a composite of the occupant load, the potential internal fire load, flammable liquid fuel capacity and fuselage length and width. Careful consideration of all these factors allows the identification of a meaningful operational objective, that is, the area to be rendered fire free (controlled or extinguished). 2) Relative Effectiveness of Agent Selected—This is accounted for by the specific application rate identified for the common generic foam concentrate types.

27 3) Time Required to Achieve PCA Fire Control—Information from reliable large-scale fire tests, empirical data from a wide variety of sources, and field experience worldwide indicates that 1 minute is both a reasonable and a necessary operational objective. 4) Time Required to Maintain the Controlled Area Fire-Free or to Extinguish the Fire—An operational objective that provides a safety factor for the initial fire attack on the PCA while waiting for the arrival of backup support or to complete extinguishment of remaining fires outside the PCA. Quantity Q3—The quantity of water required for fire-fighting operations in the aircraft interior. This quantity of water, called Q3, is based on the need for hand lines to be used for interior fire fighting. The actual amount of water comprising Q3 is found in Table B.5.3 of NFPA 403 for the various NFPA categories. The amount ranges from 600 gallons for Category 4 to 5,000 gallons for Category 10, and was adopted by NFPA but was not by the FAA or ICAO. NFPA adopted the Q3 water quantity in 1993 since it believed that there was an insufficient amount of water to launch interior attacks once the external fire had been contained. Table 4 shows the amount of water required by the FAA, ICAO and NFPA for airport index/category. It is the total amount of water required (or the sum of Q1, Q2 and Q3) to properly mix with the foam concentrate carried on the trucks. Table 4. Water/Quantity Comparison ICAO/NFPA Airport Category FAA Airport Category Water (U.S. Gallons), Q1+Q2 Example Aircraft FAA ICAO NFPA* 4 A 100 634 730 DHC-8-100 5 A 100 1,427 1,510 ATR-72 6 B 1,500 2,087 2,490 B737; Emb-145 7 C 3,000 3,197 3,630 B757 8 D 4,000 4,808 5,280 A300; B767-300 9 E 6,000 6,419 7,070 B747-200; A340-400 10 E 6,000 8,533 9,264 AN225, A380 *In addition to Q1 and Q2, NFPA requires an additional quantity of water, Q3, which ranges from 600 gallons for Category 4 to 5000 gallons for Category 10. AIRCRAFT RESCUE AND FIRE FIGHTING STAFFING FAA and ICAO FAA and ICAO standards do not require a specific minimum number of firefighters. Instead those standards require that a “sufficient number” of trained personnel be present to operate vehicles, meet response time standards, and meet the agent discharge rates specified in the standards.

28 NFPA NFPA, on the other hand, does publish a minimum staffing requirement based on the category of airport. Annex D to NFPA 403 contains an explanation of how NFPA developed its staffing figures. Basically, it is based on a Task and Resource Analysis Model that was used to determine the minimum number of qualified personnel required to deal with an aircraft accident or incident. Figure 1 shows the staffing required by the NPFA. Figure 1. NFPA 403 Minimum Number of Firefighters per Shift RESPONSE TIMES Response time standards are important in determining the numbers and locations of fire stations required at an airport and therefore the required numbers of ARFF vehicles and staffing. Although there are variations in response times and areas among the three organizations, all three organizations provide that the demonstration of compliance be done in optimum conditions, i.e., daylight, dry pavement, etc. FAA Section 139.319 (h) requires an airport operator to demonstrate that its aircraft rescue and fire fighting vehicles can respond to the midpoint of the farthest air carrier runway in three minutes for the first vehicle and four minutes for all other required vehicles. When Part 139 was originally adopted in 1972, the 3-minute response was considered a reasonable time due to the rollover potential. The ARFF vehicles of that era had a high center of gravity and slow acceleration speeds. 0 3 6 9 12 15 NFPA Airport  Category 4 5 6 7 8 9 10 N um be r of F ir ef ig ht er s

29 ICAO ICAO has a response time standard, which requires airports to demonstrate that the first ARFF vehicle can reach any point on a runway within three minutes. NFPA NFPA requires the first vehicle to reach any point on the operational runway in two minutes or less (NFPA 403, Paragraph 9.1.3 [2009 Edition]). Other ARFF vehicles shall arrive at intervals not exceeding 30 seconds. NFPA 402, Guide for Aircraft Rescue and Fire Fighting Operations (26), and NFPA 403, Standards for Aircraft Rescue and Fire Fighting Services at Airports, can trace the inclusion of a response time back to 1968. At that time, the NFPA documents included a response time of 3 minutes. This is probably the basis for the FAA’s adoption of the Part 139 response time. In 1975, the response time was changed in NFPA 403 to be a response time not exceeding 3 minutes but preferably 2 minutes. In 1988 NFPA changed the response time in its standards to 2 minutes or less to any point on the operational runway and 2 ½ minutes to any point remaining within the on-airport portion of the rapid response area (NFPA 403, Paragraph 9.1.3). The Rapid Response Area is defined in NFPA 403 as a rectangle that includes the runway and the surrounding area extending to but not beyond the airport property line. Its width extends 500 feet outward from each side of the runway centerline and its maximum length is 1650 feet beyond each runway end. The NFPA also includes another area, called the Critical Rescue and Fire Fighting Access Area (CRFFAA) that is a rectangular area surrounding any runway within which most aircraft accidents can be expected to occur on airports. Its width extends 500 feet from each side of the runway centerline and its length is 3300 feet beyond each runway end. In NFPA 403, Annex A, Explanatory Material, states that approximately 85 percent of the (aircraft) accidents as historically recorded in the CRFFAA occurred within the boundary of the Rapid Response Area. No other information supporting this statement is included in Annex A. TRAINING FAA Section 139.319 specifies the initial and recurrent training required for certificated airport fire fighting personnel. The requirements enumerated in paragraph 139.319(i) specify the training curriculum should include initial and recurrent training in the following areas: a. Airport familiarization b. Aircraft familiarization c. Rescue and fire fighting personnel safety d. Emergency communications systems e. Use of fire hoses, nozzles, turrets, and other appliances f. Application of the types of extinguishing agents g. Emergency aircraft evacuation assistance h. Fire fighting operations i. Adaption and use of structural rescue and fire fighting equipment for aircraft rescue and fire fighting j. Dangerous goods k. Familiarization with fire fighters’ duties under the airport emergency plan

30 ICAO ICAO Annex 14, Paragraph 9.2.34 specifies that all rescue and fire fighting personnel shall be properly trained to perform their duties in an efficient manner and shall participate in live fire drills commensurate with the types of aircraft and type of rescue and fire fighting equipment in use at the aerodrome. In the ICAO Airport Services Manual, Part I, Rescue and Fire Fighting, ICAO devotes a chapter (Chapter 14) to training (27). Chapter 14 specifies a training curriculum that is the same as for Part 139 above. NFPA The training required by NFPA can be found in NFPA 1003, Standards for Airport Fire Fighters Professional Qualifications, and in NFPA 405, Standard for the Recurring Proficiency of Airport Fire Fighters. Both of these documents parallel the FAA requirements except they are in greater detail. ARFF MISSION AND RESPONSE STRATEGIES FAA The FAA’s concept has been based on the need for controlling and extinguishing any fire that may be endangering the lives of the passengers and crew by securing an escape path(s) from the aircraft. Since the airport owner is usually the jurisdiction in which the airport is located, there is a responsibility for the downtown fire departments to respond to the airport as they would whenever there was a fire or accident anywhere within that jurisdiction. At those airports not within the same jurisdiction, then the airport operator normally enters into mutual aid agreements with the jurisdiction(s) in which the airport is physically located. In theory, by the time the fire is brought under control, the additional fire assistance will have arrived and would be implementing the airport’s emergency plan. At some airports, response from outside agencies is dependent upon a call from the airport operator. At other airports, the response is automatic and initiated when the Air Traffic Controller notifies the ARFF department. This is normally the case when the airport fire department is associated with the downtown fire department. ICAO ICAO states in its Airport Services Manual, Part I, Rescue and Fire Fighting, that the principal objective of a rescue and fire fighting service is to save lives in the event of an aircraft accident or incident (Paragraph 1.1.1). The Manual goes on to say that the provisions of adequate and special means of dealing promptly with an aircraft accident or incident occurring at, or in the immediate vicinity of, an airport assumes primary importance because it is within this area that there are the greatest opportunities of saving lives. NFPA NFPA 403 states in 1.2 Purpose, paragraph 1.2.2, “that the principal objective of a rescue and fire-fighting service is to save lives. For this reason, the preparation for dealing with an aircraft accident or incident occurring at, or in the immediate vicinity of, an airport is of primary importance because it is within this location that the greatest opportunity to save lives exists. The possibility of, and need for, extinguishing a fire that

31 can occur either immediately following an aircraft accident or incident, or at any time during rescue operations, must be assumed at all times.” NFPA response strategy is designed to have a sufficient number of aircraft rescue and fire fighting personnel on duty that would respond to the fire and could commence not only fire suppression but also aid in rescue operations. Based on an OSHA regulation, there is a requirement known as the “2-in/2-out” rule. This rule says that for a fire in a confined space a team of 2 fire fighters may enter the confined space but must have a safety team on the outside in case of an emergency involving the 2-man entry team. Based on interpretation from OSHA, an aircraft is considered to be a confined space and therefore the rule would be applicable. In the preamble to the 14 CFR Part 139 final rule that was published in the Federal Register on February 19, 2004 (FR Vol. 69, No.27, Feb. 10, 2004, page 6403), there was a discussion on OSHA’s “2-in/2-out”rule. In a legal memorandum developed jointly by the FAA and OSHA (dated July 7, 1999) it was determined that the respiratory standard is applicable only to personnel fighting a fire within a structure and not an outside aircraft fire. As the primary purpose of ARFF personnel is to suppress the external aircraft fire and to establish an escape route for the aircraft crew and passengers, the “2-in/2-out” rule does not apply to ARFF.