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February 6, 2004
Memorandum
To: |
NWCG Members; Chairs-Working Teams and Advisory Groups |
From: |
Chair, NWCG |
/s/ J L Stires |
Subject: |
National Incident Operations Driving Standards |
This memo revises the 02/26/03 NWCG interagency standards concerning emergency
hours of driving, hereinafter referred to as “incident operations driving”.
Further in-depth research and legal consultation has resulted in a determination
that state and federal fire agencies are exempted from several requirements
under Department of Transportation 49 CFR (CDL requirements). These include
hours of service (duty day hours) and record of duty status (log book). These
exemptions intentionally provide fire agencies the latitude for more flexibility
within incident operations driving than we originally interpreted and subsequently
reflected in the 02/26/03 standards.
These revised driving standards set forth limitations consistent with the
new 02/06/04 NWCG work/rest standards, while allowing significantly improved
operational functionality over the earlier standards. Notably, this revised
standard eliminates earlier duty day hour differences between CDL and non-CDL
engine operators, which resulted in serious operational difficulties for the
field. These incident operations driving standards have already been adopted
as policy through the “Standards for Fire and Fire Aviation Operations
2004” Handbook by federal signatory agencies.
These new driving standards will provide improved incident operations within
the interagency wildland fire community. Please insure that this information
is made available to your fire management personnel.
Cc: Chairs, Geographic Area Coordinating Groups
Attachment
Incident Operations Driving
These standards address driving by personnel actively engaged in wildland
fire or all-risk response activities, including driving while assigned to a
specific incident or during initial attack fire response (includes time required
to control the fire and travel to a rest location). In the absence of more restrictive
agency policy, these guidelines will be followed during mobilization and demobilization
as well. Individual agency driving policies shall be consulted for all other
non-incident driving.
- Agency resources assigned to an incident or engaged in initial attack fire
response will adhere to the current agency work/rest policy for determining
length of duty day.
- No driver will drive more than 10 hours (behind the wheel) within any duty-day.
- Multiple drivers in a single vehicle may drive up to the duty-day limitation
provided no driver exceeds the individual driving (behind the wheel) time
limitation of 10 hours.
- A driver shall drive only if they have had at least 8 consecutive hours
off duty before beginning a shift.
Exception: Exception to the minimum off-duty hour requirement is allowed when
essential to:
- accomplish immediate and critical
suppression objectives, or
- address immediate and critical firefighter
or public safety issues.
- As stated in the current agency work/rest policy, documentation of mitigation
measures used to reduce fatigue is required for drivers who exceed 16 hour
work shifts. This is required regardless of whether the driver was still compliant
with the 10 hour individual (behind the wheel) driving time limitations.