In the fall of 2002, the NWCG tasked the Safety & Health and Incident Business
Practices Working Teams with reviewing the NWCG work/rest and length of assignment
standards. Proposed interim changes were tested during the 2003 fire season,
with request for comments by October 1, 2003.
The standards have been revised to reflect the strong consensus that: 1. the
previous standards be simplified, 2. managers be provided increased flexibility
to meet operational needs, and 3. appropriate fatigue management be emphasized.
Work/rest guidelines have basically not changed. The 2:1 work to rest ratio
is still valid and will be followed. However, flexibility to exceed the guidelines
is allowed when warranted under certain circumstances.
This revised standard maintains a 14-day length of assignment. Fatigue management
concerns, as well as many state contracts allowing only 14-day assignments,
strongly indicated that the 14-day assignment length be retained. The new standard
provides for a simplified assignment extension process when necessary.
For fatigue management purposes and in line with credible research recommendations,
a 2-day-off-after-14 day assignment standard (exclusive of travel) has been
adopted.
Please insure that this information is made available to your fire management
personnel.
12.7 – Work/Rest, Length of Assignment, and Days Off
To maintain safe and productive incident activities, incident management
personnel must appropriately manage work and rest periods, assignment duration
and shift length for personnel, including casuals (AD), contracted crews,
and EERA resources.
To assist in mitigating fatigue, days off are allowed during and after assignments.
If necessary to reduce fatigue, the Type 1/2 incident commander (IC) or agency
administrator (AA) (incident host or home unit) may provide time off supplementary
to mandatory days off requirements. For Type 3-5 incidents, paid days off
should be rare exceptions. However, if necessary, the Agency Administrator
(incident host or home unit) may authorize day(s) off with pay.
The IC or AA authority to grant a day off with pay lies within 5 U.S.C.
6104, 5 CFR 610.301-306, and 56 Comp. Gen. Decision 393 (1977).
12.7-1 – Work/Rest Guidelines. Work/rest guidelines should
be met on all incidents.
Plan for and ensure that all personnel are provided a minimum 2:1 work to
rest ratio (for every 2 hours of work or travel, provide 1 hour of sleep and/or
rest).
Work shifts that exceed 16 hours and/or consecutive days that do not meet
the 2:1 work/rest ratio should be the exception, and no work shift should
exceed 24 hours. However, in situations where this does occur (for example,
initial attack), incident management personnel will resume 2:1 work/rest ratio
as quickly as possible.
The Incident Commander or Agency Administrator must justify work shifts that
exceed 16 hours and those that do not meet 2:1 work to rest ratio. Justification
will be documented in the daily incident records. Documentation shall include
mitigation measures used to reduce fatigue. The Excess Hours Log found in
the Appendix Tool Kit of this handbook is an acceptable method of documentation.
The Time Officer’s/Unit Leader’s approval of the Emergency Firefighter
Time Report (OF-288), or other agency pay document, certifies that the required
documentation is on file and no further documentation is required for pay
purposes.
The work/rest guidelines do not apply to aircraft pilots assigned to an
incident. Pilots must abide by applicable Federal Aviation Administration
(FAA) guidelines, or agency policy if more restrictive.
12.7-2 - Length of Assignment.
1. Assignment Definition
An assignment is defined as the time period (days) between the first full
operational period at the first incident or reporting location on the original
resource order and commencement of return travel to the home unit.
2. Length of Assignment
Standard assignment length is 14 days, exclusive of travel from and to home
unit, with possible extensions identified below.
Time spent in staging and preposition status counts toward the 14-day limit,
regardless of pay status, for all personnel, including incident management
teams.
3. Days Off
After completion of a 14 day assignment and return to the home unit, two
mandatory days off will be provided (2 after 14) (State regulations may preclude
authorizing this for State employees). Days off must occur on the calendar
days immediately following the return travel in order to be charged to the
incident. (See Section 12.1-2) (5 U.S.C. 6104, 5 CFR 610.301-306, and 56 Comp.
Gen. Decision 393 (1977). If the next day(s) upon return from an incident
is/are a regular work day(s), a paid day(s) off will be authorized.
Pay entitlement, including administrative leave, for a paid day(s) off cannot
be authorized on the individual’s regular day(s) off at their home unit.
Agencies will apply holiday pay regulations, as appropriate. A paid day off
is recorded on home unit time records according to agency requirements.
Casuals (AD) are not entitled to paid day(s) off upon release from the incident
or at their point of hire.
Contract resources are not entitled to paid day(s) off upon release from
the incident or at their point of hire.
Home unit agency administrators may authorize additional day(s) off with
compensation to further mitigate fatigue. If authorized, home unit program
funds will be used.
All length of assignment rules apply to aviation resources, including aircraft
pilots, notwithstanding the FAA and Agency day off regulations.
4. Assignment Extension
Prior to assigning incident personnel to back-to-back assignments, their
health, readiness, and capability must be considered. The health and safety
of incident personnel and resources will not be compromised under any circumstance.
Assignments may be extended when:
- life and property are imminently threatened,
- suppression objectives are close to being met,
- a military battalion is assigned, or
- replacement resources are unavailable, or have not yet arrived.
Upon completion of the standard 14 day assignment, an extension of up to
an additional 14 days may be allowed (for a total of up to 30 days, inclusive
of mandatory days off, and exclusive of travel). Regardless of extension duration,
two mandatory days off will be provided prior to the 22nd day of the assignment.
Contracts and Emergency Equipment Rental Agreements (EERA) should be reviewed
for appropriate pay requirements and length of assignment. If the contract
or EERA do not address, the incident Finance/Administration Section Chief
or the procurement official should be consulted as to whether compensation
for a day off is appropriate.
- Single Resource/Kind Extensions:
- The Section Chief or Incident Commander will identify the need for assignment
extension and will obtain the affected resource’s concurrence. The
Section Chief and affected resource will acquire and document the home unit
supervisor’s approval.
The Incident Commander approves the extension. IF a convened geographic
or national multi-agency coordinating group (GMAC/NMAC) directs, the incident
commander approves only after GMAC/NMAC concurrence.
If the potential exists for reassignment to another incident during the
extension, the home unit supervisor and affected resource will be advised
and must concur prior to reassignment.
- Incident Management Team Extensions:
- Incident management team extensions are to be negotiated between the
incident Agency Administrator, the Incident Commander, and the GMAC/NMAC
(if directed).
The Assignment Extension form can be found in the Appendix Tool Kit section
of this handbook. A copy of the documentation should be attached to timesheets.
Upon release from the assignment, regardless of extension duration, two mandatory
days off will be provided immediately following the return to the home unit
and are chargeable to the incident. (See above for compensation and days off
guidelines.)