Please be aware that the Georgia Firefighters Standards & Training Council (GFSTC) is considering the adoption of changes to the Rules that apply to firefighters and fire departments. Any such changes will have the affect of Law and will be binding on all fire departments and firefighters in Georgia.

Of particular concern is the impact the proposed changes will have on volunteer firefighters and departments. If your jurisdiction relies upon volunteers for the delivery of fire protection services, it may be helpful for you to look into the proposed changes and communicate with the volunteers to evaluate the impact the proposed changes may have. From what I have learned, many of the volunteer departments are completely unaware of the pending vote on the proposed changes to the rules.

The proposed changes will:

increase the initial training required to become a basic (volunteer) firefighter

set deadlines for volunteers to obtain either support firefighter accreditation or basic firefighter accreditation (one-year from date of joining)

require volunteers to pass a physical agility test

require basic (volunteer) firefighters to successfully perform 21 life-safety skills

require certain ongoing specific training requirements each year in order to maintain the ability to volunteer

require additional minimum equipment beyond the current requirements

There are some administrative changes as well to include:

the requirement that volunteer fire departments must notify GFSTC within ten days of someone joining their department

departments must obtain and maintain proof of age on volunteers

departments must get background checks on volunteers

departments must have a baseline medical form completed by a certified medical person on volunteers

departments must complete a registration form and submit the form with the criminal history check to GFSTC within one-year of a new member joining

departments must report an arrests of any member (not conviction) to GFSTC within ten days of the arrests

The above changes are not all-inclusive, but capture most of the possible impact on volunteer departments. It is very difficult to recruit and maintain volunteers, and volunteers have an extremely long list of responsibilities in providing fire services as it is, so everyone will need to consider the pros and cons of placing additional burdens on the volunteer spirit. It is very possible that jurisdictions that rely upon volunteers could be faced with having to increase funding to offset the loss of volunteers that could result from the application of the proposed rules. In a case where there are not enough volunteers due to the increased burdens being placed upon them, it is possible that communities will either become unprotected (property insurance rates will soar), or local governments will be forced to utilize tax dollars to provide service through paid firefighters.

GFSTC has historically worked well with fire departments that are deficient in compliance with the rules, but it has been made clear that deficient departments will lose their compliance certification and be unable to legally operate.

If you would like additional information on the proposed changes, or would like to discuss this matter, please contact me by e-mail at blombard@greenecountyga.gov, or by phone at 706-817-6600.

Many thanks,

Byron Lombard

County Manager

Greene County

Mr. Pardue,

My wife tells me that I am still H.F.Stewart.

I appreciate your quick response and do believe that the Rules Committee has good intentions. The practical side, however, is that implementation of the proposed rules as written will cause many volunteer fire departments to become non-compliant.

As a former EMA director, I know how difficult it is to get volunteers to give up their time to attend training and do all the other things required by the volunteer fire departments while trying to make a living.

Specifically, the additional reporting requirements and administrative burdens being placed on the leadership of these volunteer departments will serve as a deterrent to individuals desiring to volunteer their time for the fire service. Experienced leaders will likely find the extra burden too much and either quit altogether, or take on a lesser role leaving the leadership role to someone with much less experience. The additional reporting requirements and administrative burden include, but are not limited to:

· Notification of GFSTC within 10 days of someone joining a volunteer department

· The requirement to get criminal history checks

· The requirement to obtain certain documents for proof of age

· The requirement to have medical forms completed by certified individuals

· The requirement to report arrest within ten days

Further, the additional training that is proposed under the new rules will push available volunteers out of compliance, and thus no longer available. We need every volunteer we can get, not limit our volunteer pool by inserting “hoops” for them to jump through, training requirements that are not practical for volunteers, and deadlines that are arbitrary an unreasonable. Specifically, the proposed rules require the following that will hurt the volunteer fire service:

· Increasing the initial training to become a basic firefighter

· Setting a deadline of one-year from date of joining to obtain certain training certification

· Requiring volunteers to pass a physical agility test

· Requiring volunteers to successfully perform 21 life-safety skills

· Requiring additional ongoing training every year, especially the core competencies

If the above specific requirements are not satisfied, departments will lose their certification. These requirements are in addition to numerous requirements already being shouldered by a select few in volunteer departments.

I would now ask you to provide something in return…please provide me with definitive proof that the fire service across the State is ineffective and broken, and in need of change. Also, provide me with the evaluative data that indicates that the problems that will ensue after establishing these proposed rules is less detrimental than whatever perceived problems exists today.

It would seem that local jurisdictions should be enabled to determine the success of their fire service. In those jurisdictions desiring change, let them make the change and bear the costs. In those that support their volunteers and believe in their dedicated efforts to serve their fellow citizens, let them continue to successfully perform without unnecessary policing.

T. Mayers Original Point:

• The fact that the rules have not been changed in thirty five years could either mean that there are problems with the present rules or that the rules have stood the test of time and have been quite effective. I am not aware of significant problems with the rules as they pertain to volunteer fire departments nor did I learn anything last Thursday to indicate that there are significant problems with the present rules. “If it isn’t broke don’t fix it”.

Pardue’s Response:

• As far as I can determine, the rules of Georgia Firefighter Standards and Training Council have never been updated since written in 1974 and becoming effective in 1975. There have been multiple law changes affecting this agency since that time and there are significant changes which need to be made.

T. Mayers Follow-up Response:

There have certainly been changes to the requirements imposed on volunteers over the years, such as the live-fire requirement that became effective around 2005. Any such changes should be incorporated into the Rules as opposed to promulgating Policy changes adopted independently by Council. It is important to note that the requirements for volunteers under the Rules of 1974 are not the same as the requirements for volunteers under Council’s requirements today.

Please identify those proposed changes that are a product of Legislative changes enacted by the General Assembly with reference to the Code Section that necessitates such change

T. Mayers Original Point:

• I do not like the removal of the word “Volunteer” we are volunteers! We are not “basic” firefighters.

Pardue’s Response:

• This was discussed in detail during the Rules Committee meetings. Generally throughout this state, individuals are labeled “volunteers” even if they receive a fixed reimbursement on a per call basis which would technically make the individual “paid-on-call”. Other options in use are paying the “volunteer” on an hourly basis and giving an annual bonus which is usually prior to Christmas. This is not all inclusive, but just used as an example. (Of my 24 years serving as a “volunteer”, 14 of those were actually paid-on-call). Please remember Mr. Mayers that these proposed Rules are a draft open for discussion and are subject to revision at the Council’s pleasure.

T. Mayers Follow-up Response:

We have volunteer firefighters around the State that are trained to higher levels than that of “Basic Firefighter.” Basic Firefighter should remain a level of training, “Volunteer Firefighter” should mean “a firefighter trained to at least the level of Basic Firefighter that is not employed for hourly compensation but appointed and regularly enrolled to serve as a firefighter for any municipal, county, state, or private incorporated fire department.”

T. Mayers Original Point:

• The mandated training and reporting requirements for a small rural department of 100% volunteers is onerous and excessive. While I believe in and support ongoing training, mandating them with the resulting reporting will, in my opinion, result in the loss of some membership and greatly adversely affect future recruitment. The training should be in the form of recommendations not mandates. Keep in mind most of the volunteer firefighters are employed in full time jobs in addition to their volunteer activities.

Pardue’s Response:

• Fighting fire is one of the most “hazardous occupations” there is. I included “occupation” because there is no difference in volunteers, paid-on-call, part-time, or career firefighters engaged in fighting fire at a two story farm house trying to save property or a life. This is the reason minimum training requirements were included by the Rules committee. It was to establish minimum training for all firefighters, not just those who choose to participate.

T. Mayers Follow-up Response:

There IS a difference between volunteers, paid on-call, part-time, and/or career firefighters engaged in fighting fire…paid firefighters GET PAID. These paid firefighters get paid to participate in training, both required and voluntary training. These paid firefighters are paid to perform to meet certain expectations and rely upon their job as a firefighter to provide for their household. Without risking their jobs, the paid firefighters have little choice when given an assignment except to perform to the level expected of them. Volunteers absolutely have the choice (and responsibility) to deny an assignment if it is beyond their comfort level or training.

Paid firefighters must respond to calls when dispatched on their shift, volunteers do not have to respond. Volunteer departments never know who is able to respond, what role they will need to fill, or what equipment will role to the call.

Bottom line, there is a difference in the expectations of paid firefighters versus volunteer firefighters. The reality is that this difference is commonly accepted due to the nature of volunteering to perform versus being paid, i.e. required, to perform.

T. Mayers Original Point:

• The requirement for providing documentation to GFSTC when new Volunteer (basic) as well as support members are added only adds time and effort to already very busy volunteer officers of the small rural departments and, as far as I can determine, really does not serve a real useful purpose.

Pardue’s Response:

• I pray we never have another line of duty firefighter death. Under Georgia Law regarding the indemnification benefits for firefighters injured or killed in of duty, O.C.G.A. 45-9-81(B) states: “Firefighter” shall also mean any individual serving as an officially recognized or designated member of a legally organized volunteer fire department…” It is very important to notify GFSTC when new firefighters are employed/appointed to fire departments. I serve on the Indemnification Commission and I do not want to verify an individual was not an officially recognized or delegated member of a legally organized volunteer department and possibly jeopardize much needed assistance for the firefighter or his/her survivors.

T. Mayers Follow-up Response:

In my review of all information available to me under Title 45 and other sources relating to the Georgia Indemnification Commission and could not find any reference to a requirement that in order to qualify as a “Firefighter” for purposes of the Georgia Indemnification Fund that a volunteer firefighter must be registered with the GFSTC to be considered for benefits under the Fund.

Have you ever had to verify that a firefighter was not “officially recognized” by the GFSTC as a member of a legally organized volunteer fire department? If so, did such verification from you representing GFSTC prevent benefits from being paid under the Fund? It appears that while such registration with the GFSTC might simplify the verification process, not being registered with GFSTC does NOT prevent benefits from being paid under the Fund. Please correct me if I am wrong on this point.

T. Mayers Original Point:

• There is no distinction for the annual training and reporting for a firefighter that is trained and qualified to enter a burning structure, for an offensive attack and rescue, or a firefighter that is trained and qualified to handle a hose on a defensive attack. Additionally there is no distinction in the requirements for fighting a wild fire, vehicle fire or dumpster fire.

Pardue’s Response:

• Basic firefighter training is standardized using the National Fire Protection Association standard on Firefighter (NFPA 1001). As individuals are trained as a firefighter and responds to calls, he/she does not know what is ahead. Firefighter may and do find themselves in a situation they can’t get out of without assistance. Wouldn’t it be comforting to know there are trained individuals on site ready to assist should the need arise?

T. Mayers Follow-up Response:

I believe you missed my point. In volunteer fire departments, we are limited in manpower and never know for sure who is responding to the fire. There may be a case where those that are able to respond must be completely defensive in their attack, which could be due to the conditions present, or the manpower available. Volunteers should be able to fight fire defensively without having to meet the same standard as those making an interior offensive attack.

Likewise, a support firefighter may respond to a small area on the side of the road that is on fire, yet they would have to wait on a Volunteer Firefighter to actually put water on the fire. This delay could cause the fire to grow into a more hazardous event.

My belief is that there should be a distinction made for initial training requirements for Volunteer Firefighters entering into burning structures over that required of Support Firefighters. However, beyond entering a burning structure, Support Firefighters should be able to man a nozzle on a defensive attack, woods fire, or other fire using their training and experience gained through departmental training.

T. Mayers Original Point:

• The comment that “people die fighting wild fires” is not a valid argument. We all know that most firefighters die from heart attacks and secondly from vehicle accidents. More people die crossing the street than are killed fighting Georgia wild fires. The skill level and physical requirements for fighting an offensive attack on a structure certainly exceeds the others mentioned above.

Pardue’s Response:

• In 2008, according to the U.S. Fire Administration, there were 118 line of duty fire deaths, 66 of these were volunteers, and 26 were related to wildland firefighting

T. Mayers Follow-up Response:

A review of the 2008 U.S. Fire Administration report reveals that only two of those fire deaths occurred in Georgia. One of the deaths occurred during training being delivered at the Georgia Fire Academy, the other occurred while in route to a woods fire after the apparatus overturned. Neither of these deaths in Georgia were the result of volunteers fighting wild-land fires.

Further, you point out that “26 of these deaths were related to wildland firefighting,” yet a review of the specifics of these deaths does not indicate that additional requirements for those fighting wild-land fires is appropriate or necessary. None of the 26 deaths were volunteers or support firefighters that died due to lack of training or certification.

The majority of these 26 deaths were due to helicopter or plane crashes (14 to be exact), 5 were due to medical conditions rather than training level/certification, 2 due to a bridge collapse while in an apparatus rather than their training level/certification. Of the remaining five, one was hit by a vehicle on a roadway, one fell from a cliff, one fell off a parked forestry plow, one had a tree fall on him, and one had fire burn over his position…it is arguable as to whether their training level/certification had anything to do with the cause of their death, but of these last five, all had high levels of training.

Fire of any type including wild-land fire is unpredictable and despite the highest levels of training, one can still die due to fire. However, WE NEED volunteers to fight fire of all types including wild-land fires. Implementing requirements that can not be justified that restrict those allowed to fight fire will easily cause wild-land fires to grow in intensity causing greater property loss and possibly loss of life if the fire spreads to nearby occupied dwellings and consumes the occupants.

Appropriate initial training should be encouraged, but volunteer fire departments across the State should not be hamstrung by Rules that make fighting fire more difficult when such rules can not be defended with statistical data and sound rationale. Hundreds, of wild-land fires throughout Georgia each year are successfully managed by volunteer and support firefighters.

T. Mayers Original Point:

• Any “review committee” that is established for the review of a Volunteer Fire Department should only include (the fire department portion of the committee) members of Volunteer Fire Departments. Just as I do not think a paid department should be reviewed by members of a volunteer department. Peer review is much more effective and relevant.

Pardue’s Response:

• I agree that any committee dealing with volunteers should have volunteer representation.

Follow-up Response:

Based on your own description of the Rules Committee, it appears that there were virtually no purely volunteer departments involved in the re-write process. Accordingly, based on your concurrence expressed above, the GFSTC should solicit purely volunteer departments to serve on a committee to develop revisions to the Rules for volunteer departments not merely “volunteer representation”.

T. Mayers Original Point:

• In section 205-2-2-04 the reporting of arrests of members should be removed. Whatever happened to the “innocent until proved guilty in a court of law”? These arrest reports can sit in a person’s records for years, possibly after the person was found to be “not guilty”, and still be available with an open records request by someone on a “witch hunt” to slander another’s reputation.

Pardue’s Response:

• The committee using Peace Officer Standards and Training Council Rules as a guide felt this should be included in Rules.

T. Mayers Follow-up Response:

POST Council Rules apply to law enforcement officers, which are involved in enforcing the Law and should be held to a much higher standard under the Law. There is a direct association between those that enforce the Law and their own willingness to obey the Law.

You were asked what the GFSTC would do with such a record when reported, and you indicated “nothing.” So why place this burden on any department, especially volunteer departments?

T. Mayers Original Point:

• 205-3-1.01-h should be changed from Purchase and maintain to Provide and maintain. Our insurance is provided to all Greene County Fire Departments by the County.

Pardue’s Response:

• The above mentioned section (205-3-1.-01(h) is a direct quote of Georgia Law with the exception of this addition, “…that is in accordance with applicable Georgia insurance laws.” I feel certain the current insurance provided to all Greene Co FDs is more than adequate.

Follow-up Response:

To be correct it should be changed to provide.

T. Mayers Original Point:

I hope these comments and suggestions will be given serious review and consideration before we have rules and regulations promulgated on us that will make our lives much more difficult. Please keep in mind that we are all 100% volunteers and many of our members work full time in addition to volunteering with the fire department as well as other volunteer activities.

Pardue’s Response:

It is my experience that the majority of full-time firefighters also have “full-time” jobs while off duty. It has not been nor has ever been the intent to place undue burdens on our volunteers, simply establish fair, equitable, minimum standards for all of our fire service professionals.

T. Mayers Follow-up Response:

I fail to see why you point out that “the majority of full-time firefighters also have ‘full-time’ jobs while off duty.” The full-time firefighters get paid while on-duty to participate in required training. Their secondary jobs are to supplement their primary profession and income. Not only do they get paid for their service as a firefighter, they get paid for their secondary employment. Volunteers must find time around their paying profession to attend training and provide service.

Volunteers should be supported in their efforts to provide service to their fellow citizens, nor regulated and policed out of existence. Any additional burdens will make it more difficult on volunteers, PERIOD.

T. Mayers Original Point

If it isn’t broke don’t fix it. I do not believe, nor does the evidence indicate, that the existing rules and regulations for rural volunteer fire departments are broken.

Pardue’s Response:

Updates and changes actually are needed.

Follow-up Response:

A very subjective response! It should be fairly obvious that many do not agree with your position. Any changes should be based on clear and overwhelming justification and limited in scope to the maximum extent possible when being inflicted against volunteers.