Armstrong – Spallumcheen Fire Services Review

132 Pages·2014·5.18 MB·English

Armstrong – Spallumcheen
Fire Services Review

Dave Mitchell & Associates Ltd.
February 2014
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Table of Contents 
Executive Summary ...................................................................................................................... 4 
Legal Structure .......................................................................................................................... 6 
Administration .......................................................................................................................... 18 
Occupational Health and Safety .............................................................................................. 18 
Mutual Aid Agreements ........................................................................................................... 24 
Standards of Service ................................................................................................................... 28 
NFPA 1221 .............................................................................................................................. 28 
NFPA 1720 .............................................................................................................................. 31 
Operational Review ..................................................................................................................... 32 
Review with Staff ..................................................................................................................... 32 
Apparatus ................................................................................................................................ 36 
Training ....................................................................................................................................... 41 
Overview of Training and Training Standards ......................................................................... 41 
Records Keeping ........................................................................................................................ 52 
Fire Prevention ........................................................................................................................ 55 
Emergency Response Analysis .................................................................................................. 56 
Total Events by Year ............................................................................................................... 57 
Total Events by Month ............................................................................................................. 58 
Responses by Day of the Week .............................................................................................. 59 
Responses by Hour ................................................................................................................. 60 
Responses by Fire Hall Area ................................................................................................... 61 
Response by Event Type ........................................................................................................ 63 
Fire Hall ....................................................................................................................................... 68 
Fire Hall Location ........................................................................................................................ 79 
Fire Underwriters Survey ............................................................................................................ 84 
Budgets and Finances ................................................................................................................ 94 
Summary of Recommendations .................................................................................................. 99 
Priorities .................................................................................................................................... 105 
Risk/Benefit Analysis with Timeline .......................................................................................... 106 
Appendix 1: List of Acronyms and Referenced NFPA Standards ............................................. 115 
Appendix 2: Firefighter Training ................................................................................................ 117 
BC Basic Fire Fighting Program ............................................................................................ 119 
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Live Fire Training ................................................................................................................... 119 
Live Fire Level I ..................................................................................................................... 121 
Live Fire Level II .................................................................................................................... 123 
Live Fire Level III ................................................................................................................... 123 
Appendix 3: Fire Department Health and Safety Program ........................................................ 125 
Appendix 4: Consultants’ Resumes .......................................................................................... 128 

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Executive Summary

The Armstrong—Spallumcheen Volunteer Fire Department (the “Department” or “ASVFD”) is
somewhat unique in that it is a shared service between the City of Armstrong (the “City” or
“Armstrong”) and the Township of Spallumcheen (the “Township” or “Spallumcheen”). The
Department operates from a single fire hall located in Armstrong and provides service to
approximately 10,000 residents across the two municipalities. The services provided include fire
suppression, inspections and response to motor vehicle accidents; the Department does not
provide a general first medical responder (“FMR”) program.

The underlying bylaw structure enabling the Department to operate requires updating to
address a lack of clarity regarding its operational authority, organization and reporting structure.
The Department’s operating budget is currently in the range of $400,000 per year, which is not
uncommon for fire departments of this size and composition. Its capital budget, however, can
dramatically affect the annual costs, as either new apparatus or fire hall renovations impact
expenditures. The Department should consider building capital reserves for such expenditures
to better manage the inter-annual variability in its budget. Further agreement on capital and
operating costs will be necessary as an expansion or renovation of the current fire hall proceeds
and consideration is given to a second, satellite fire hall in Spallumcheen. This second fire hall
is necessary to provide appropriate coverage in areas outside of the acceptable travel distance
as determined by the Fire Underwriters.

The Department’s training records are generally quite good, however some of the challenges
which were identified include a lack of comprehensive individual training records for each
member (to record all aspects of training, including weekly practice nights), a lack of back-ups to
these training records, and the challenge the Department faces in utilizing a computerized
records management system (“RMS”). Thorough and complete record keeping is a requirement
of WorkSafe BC and a necessary measure to ensure that the Department, fire officers,
firefighters and local government are not unduly exposed to risk or liability. There are several
recommendations in the Records section dealing with various records-related issues.
Equally important, there is a set of recommendations relating to firefighter and fire officer
training issues. In general, the Department has done a very good job of training its members.
Its focus on ensuring that the volunteer firefighters receive regular live fire training is an
approach that is to be commended. The training recommendations principally relate to the
development of proficiency standards for all firefighting roles and skills. Certain of the
recommendations on records keeping and the operational guidelines, however, also impact (or
are affected by) the training recommendations.
The Deputy Fire Chief is the primary member responsible for training, although other qualified
members are assigned training duties according to their experience and qualifications. Deputy
Chief Crick suggested that, on average, it requires approximately one month to complete the 40
hour North Okanagan Regional District Basic Program (“NORD Basic Program”), which includes
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live fire training, after which members are at a level where they would be qualified to conduct
interior fire operations as a team member.
According to the Fire Chief and Deputy Chief, the Department will conduct offensive interior
operations (fire attacks and primary searches) depending on the nature of the incident and the
number and skill level of the members in attendance. The general criteria used to determine
which members are capable of performing interior operations are that they must have
completed the NORD Basic Program and their attendance at weekly practice sessions along
with their actual levels of experience. That determination, however, generally is not made
formally. Rather, it is left to the Incident Commander’s discretion as to whether a member is
sufficiently trained for an interior attack.
At present, approximately 19 of 38 Department members are deemed sufficiently trained for
interior operations. The operational guidelines (“OG”s) provided by the Department, however,
do not cover all of the necessary aspects of conducting interior operations (an issue addressed
in detail in this report). Absent such guidelines and individual training records to indicate the
areas of training successfully completed by each member, the Department relies on the Incident
Commander’s judgment for determining whether or not to enter a fire-involved structure and
which members are capable and qualified to do so.
This approach has drawbacks and presents some potential risks. Appropriate written
operational guidelines covering these types of operations are a WorkSafe BC requirement. In
addition, there are concerns as to whether the Department’s training records could easily and
readily identify all of an individual’s training history, in the context of a formal or contested
review, to establish the current training level (skills and proficiency) of a particular member.1
As discussed in greater detail in the report, these shortcomings should be addressed through
improved comprehensive records keeping and more formal assessment of members’
qualifications for interior attacks, as well as improved operational guidelines. Aggressive interior
operations such as fire attacks and primary searches require firefighters to enter a hazardous
environment, dramatically increasing exposure to potential adverse fire events such as
flashover, smoke, explosion or backdraft, along with a variety of other hazards. Such
operations pose the most significant risk to firefighters in fire ground operations.
The issue of appropriate training levels is considered along with the obligation to ensure that
workers are properly trained for their duties and supervised while performing them. The goal,
therefore, should always be to maximize training for all firefighters, and to limit their fire ground
operations to those tasks for which they have been properly trained. To accomplish this, the
Department should ensure that all firefighter activities are always supervised by a suitably
trained fire officer. As with firefighters, fire officers must adhere to the limits of their actual
training.

1 The records may, indeed, be available, though the method of storage and paper-based system in use
would make that difficult to ascertain easily.
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The report also analyzes the Department’s existing minimum training program in the context of
the requirements established under the Fire Services Act (B.C.), and against NFPA2 1001
Firefighter I and II criteria and the BC Basic Fire Fighting Program. It also examines Live Fire
Level I, II and III training requirements, which are critical training components for any
department which conducts offensive interior operations.

Legal Structure

Armstrong – Spallumcheen Fire Service Bylaw Review

The City and Township have agreed jointly to provide a number of services to their respective
residents. One of the services that is shared is the fire department.3 This shared structure
creates some conceptual challenges when considering the fire service establishment and
operational bylaws. Rather than a single bylaw creating the Department, there actually are two
– in essence, the Department has been established twice, though the description of it varies
somewhat between the two sets of bylaws.

The relevant Township bylaw is Bylaw No. 11174; the closest equivalent bylaw for the City is
Bylaw No. 929.5 Each will be considered in turn along with any relevant amendments. The
primary focus will be on the issues related to the establishment and operation of the
Department, and the authorities granted to it. Issues related to the adoption of the National
Building Code, the National Fire Code, open air burning restrictions and similar matters will not
be examined in detail. In conducting this review, we are not, and should not be construed as,
providing legal advice. Any issues noted should be reviewed by the Township and the City with
their respective legal counsel.

It is important for the bylaw structure under which the Department operates to be designed to
give it the necessary operational authority and powers to respond to and manage emergency
incidents. Fire departments and their members do not have any inherent or generally
recognized powers.6 Rather, they derive their authority from their establishment and operational

2 National Fire Protection Association.
3 Based on the 1984 cost sharing agreement, other shared services include the operation of the
cemetery, the sanitary landfill, civic buildings and parks and recreation commission. Memorandum of
Agreement between The City of Armstrong and the Township of Spallumcheen, [undated – 1984], s. 1.
4 Township of Spallumcheen Fire Department and Fire Prevention By-law No. 1117, 1991, adopted 18
November 1991 (as amended).
5 City of Armstrong Fire Prevention By-Law Number 929, 1986, adopted 24 February 1986 (as amended).
6 Fire chiefs of municipal departments have certain statutory powers arising from their designation as
“Local Assistants to the Fire Commissioner” under the Fire Services Act (B.C.), but these powers are not
of themselves sufficient to cover a department’s operations.
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criteria bylaws. If they are based in a municipality, the municipal government has the authority
to establish and operate a fire service under the Community Charter (B.C.) (the “Charter). If the
local fire department is in an unorganized area, it will have been established as a local service
by the relevant regional district, under the terms of the Local Government Act (B.C.) (the “LGA”),
in response to requests by (or with the agreement of) taxpayers in the fire service area.7
Powers which may be granted to a fire department by its local authority include those contained
in the Fire Services Act (B.C.) (and, in particular, in section 25 of that act), as well as powers
enumerated in the Charter and the LGA.

In each case, the powers and authorities granted to the fire chiefs, officers and firefighters are
limited to the jurisdictional authority of the entity creating the department. In the case of a
municipal department, this typically means the boundaries of the municipality.8 In situations
where a department operates outside of its usual jurisdiction, consideration should be given to
where its authority comes from and any limitations that may exist.

It is critical therefore, that the bylaw structure clearly empowers the Department to carry out its
responses to emergency incidents and to control the scene at such incidents. It is also
important periodically to update the bylaw structure, as statutory references grow stale with time
as the underlying regulatory framework is amended or updated (as has occurred for municipal
and regional district governments, with the advent of the Charter and LGA).

In the case of the Township and the City, we recommend that the existing bylaw structure be
revised and materially updated. At the same time, the two municipalities should more
thoroughly address the shared nature of the service, preferably by creating a “joint municipal
service” as contemplated by section 14 of the Charter. Our detailed comments on the existing
bylaws are set out below.

Township Bylaw No. 1117 and amendments

Under Bylaw No. 1117 (as amended), the Township authorized the establishment of the
Department and granted it various operational authorities and responsibilities.

7 This is a generalization, as the Local Government Act (B.C.) has changed over time and the “local
service” terminology derives from amendments made in the 1990s. The general concept is still applicable
however: Regional District fire departments are only created where local taxpayers have requested or
consented to the establishment of such service. Only those taxpayers enjoying the service pay taxes to
support it. The same general concept applies to those services which are still operated by local
Improvement Districts.
8 A municipality can define the fire service area to a region that is less than the entire municipality – to
exclude, for example, Crown lands that may exist within municipal borders, or other undeveloped lands –
if it so chooses.
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One of the issues with this bylaw is its failure properly to define terms, and then consistently use
them in the various provisions. Thus, the definition of the term “Department” is as follows:

“Department” means the Township of Spallumcheen Fire Department”.

The term “Fire Chief”, however, then fails to use the defined term:

“Fire Chief” means the person duly appointed to serve as the head of the fire
department, or his lawful deputy or any person duly appointed to act in his absence.
[emphasis added]

The issue is further compounded in sections 1 – 3 of Part 2 of Bylaw No. 1117, where the
Department itself is established, its constitutional “framework” indicated and its members
granted indemnification protection (in each case, emphasis added):

1. The Municipal Fire Department is hereby established and will be known as the
Armstrong/Spallumcheen Fire Department.
2. The Township of Spallumcheen Fire Department shall be guided in all matters by
their [sic] constitution. Such constitution may be amended from time to time and shall
require the approval of Council.
3. The fire chief and all members of the fire department shall be included in the Township
of Spallumcheen’s general indemnification bylaw.9
The bylaw, therefore, uses four different terms to refer to the Department: “Department”, “fire
department”, “Municipal Fire Department” and “Township of Spallumcheen Fire Department”.
Ironically, the original form of this bylaw passed in 1991 did not use the current name of the
Department – the Armstrong/Spallumcheen Volunteer Fire Department.10 This lack of
consistency is both confusing and unnecessary. It should be reviewed and revised and a single
defined term applied to the “Department” throughout the bylaw.

We also would recommend that the Township review the establishment language. The
Department is being jointly operated by the Township and the City: the bylaw should expressly
recognize that situation and clarify that the two municipal authorities together will determine how
the Department is to be operated, regulated and empowered. In that regard, the two
municipalities can structure the arrangement as an intermunicipal service under section 14 of

9 Based on the approach taken, which is to capitalize defined terms set out in Part 1, section 1, the term
“fire chief” also should have been capitalized.
10 That is the name which also is given to the Department in its “constitution” as amended in 1987:
Amended Constitution of the Armstrong-Spallumcheen Volunteer Fire Department (1987), s. 1.
Amendments passed to Bylaw No. 1117, however, do begin to refer to the Department using this name.
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the Charter, or as one municipality providing the service to the other under section 13 of the
Charter. In addition, care should be taken to ensure that all rights, responsibilities, authorities
and administrative requirements are consistent between the two sets of bylaws.

Jurisdiction and Responsibility of the Department

The Department’s operational responsibilities are set out in section 4 of Part 1 of the Bylaw, as
amended by Bylaw No. 133711 and Bylaw No. 1815.12 As revised, the Department’s jurisdiction
and its authorized activities and responses are stipulated as follows:

a. To administer this By-law and the Fire Services Act; and National Fire Code and
the National Building Code of Canada and section 6.3 “Chimneys and Venting
Equipment”, Section 921 [sic],13 “Chimneys and Flues” and Section 9.22
“Fireplaces” of the National Building Code.14
b. To control the use of buildings, installation of equipment moved into buildings in
connection with their use and the maintenance of satisfactory conditions, for
occupancy, escape and firefighting.
c. To carry out all fire protection activities and such other activities as Council
directs.
d. To provide
i. Fire suppression and prevention
ii. Rescue operations
iii. Mutual aid to fire services including Ministry of Forests
iv. Responses to hazardous materials incidents, and
v. Public services.
e. The limits of the jurisdiction of the Fire Chief and the Officers and Members of the
Fire Department will extend to the areas and boundaries of the City of Armstrong
and the Corporation of the Township of Spallumcheen, and no part of the fire
apparatus may be used beyond the limits of the jurisdiction without:
i. the express authorization of a written contract or agreement providing for
the supply of firefighting and assistance response services outside the
established boundaries, or

11 Township of Spallumcheen Fire Department and Fire Prevention Amendment Bylaw No. 1337, 1994
(adopted 31 November 1994). This amendment added subsections (d) and (e) to Part 2, section 4 of
Bylaw No. 1117. Subsection (e) added yet another variant of the term used to refer to the Department.
12 Township of Spallumcheen Fire Department and Fire Prevention Amendment Bylaw 1815, 2011
(adopted 21 November 2011). This amendment added subsection (f) to Part 2, section 4 of Bylaw No.
1117. This revision added yet another variant of the term used to refer to the Department.
13 This should be section “9.21” not “921”.
14 In any update of the relevant bylaws, the Township and City likely should adopt the B.C. Fire Code and
B.C. Building Code, rather than the corresponding National codes.
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ii. the approval of Council.
f. The Armstrong Spallumcheen Fire Department is authorized to undertake and
carry out the use of Jaws of Life extrication services as follows:
i. within the fire protection area funded through the fire department budget,
and
ii. outside the fire protection area when authorized to do so by the provincial
authority, providing there is a mechanism for cost recovery available.
There are several issues to be considered with respect to these provisions. First, responses in
support of Wildfire Management Branch (“WMB”), which operates under the control of the
Ministry of Forests, Lands and Natural Resource Operations,15 no longer take place under an
agreement.16 Rather, the WMB has issued an operational guideline which specifies its
approach regarding responses to wildfires, or wildland – urban interface fires, by local fire
departments. This operational guideline covers both responses within a department’s own
jurisdiction, and extra-jurisdictional support provided to WMB. The language regarding how the
Department may support WMB’s operations (or obtain support from WMB if necessary, within its
own jurisdiction) should be reviewed.

As a related matter, the Township and City also should review the existing policy which
authorizes the Department to respond to incidents which are proximate to its jurisdiction and
which, if not addressed, may threaten either property or lives within its operational boundaries.17
First, the language in the existing policy should be tightened up. It speaks of risks arising from
“a fire on any Township boundary”, when it really intends to deal with matters outside of the
boundary.

Second, the question of the Department’s authority to operate in the Regional District also
needs to be clarified. This issue arises both in connection with providing support to WMB or
responding to events which are outside of the Department’s ordinary fire protection zone. In
both cases, the Township and City also need to ensure that there is both clear authority and a
clear grant or source of powers. The authority to respond can come from the City and
Township; the grant of powers, however, is a more complex issue.

With regard to the WMB’s operational guideline, the Township and City should review the
guideline and ensure that they are comfortable that it confers authority from the WMB to the
Department when carrying out such an extra-jurisdictional response.

15 As contemplated by subsection 4(d)(iii).
16 WMB replaced its separate agreements with local governments with a single operational guideline in
about 2001.
17 City of Armstrong, “Armstrong/Spallumcheen Fire Department Response – Interborder Lands,” Policy
4-400-5 (11 October 2011). It is assumed that comparable authorization has been granted by the
Township. If a comparable policy does not exist, one should be created – or, the power should be
included in a revised establishment and operational bylaw for the Department.
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