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Subcommittee presses commission staff to clarify live-fire prerequisites and SCBA fit-test documentation
Summary
Members urged clearer documentation and attestation for live-burn events, including evidence that students met NFPA 1403 topics and OSHA 1910.134 fit testing; staff said the current attestation form and event application can be adjusted to add required items.
Subcommittee discussion turned to live-fire training events and what documentation hosts must maintain. Members emphasized that before permitting a student to participate in live-burn evolutions, hosts must have evidence that the student has completed prerequisite topics identified in NFPA 1403 (referred to in the transcript as "14 o 3") and that SCBA fit testing has been completed in accordance with OSHA 1910.134.
Regional coordinators reported the commission's current application instructions reference NFPA 1403 and OSHA 1910.134, but the form departments mail in for live-burn approval did not list all required documentation. David (regional coordinator) and others suggested adding a checklist or an attestation item to the Live Burn Training Request form so the host chief certifies that required prerequisites (for example: safety, fire behavior, PPE, ladders, hose/nozzle operations, ventilation, forcible entry, building construction) have been covered and that fit testing documentation exists.
Members discussed enforcement: the rule requires that certain documentation be maintained on site but does not require all items to be submitted to the commission office. Multiple attendees urged keeping attestation and roster requirements as part of the event approval process, and suggested the commission ask hosts to maintain records and add a signature block attesting compliance; staff agreed to add line items to the application and attestation forms. The subcommittee also discussed whether the commission should approve specific individuals as fit-testing entities or simply rely on host documentation.
Staff will update the live-burn application and attestation forms to include explicit references to NFPA 1403 topics and OSHA 1910.134 fit-testing verification and will circulate the changes.
