The Boston Globe Special Report   pdf file

Geographic Information Systems (GIS)

The Importance of a 4 Minute Response in EMS

Over View EMS Report

Conclusion [A]

 Final Summary [B]

Executive Summary

This study examines predicted response times and geographic coverage areas for fire department units deployed from current fire stations of the Bay City Fire Department (BCFD), Michigan.  Upon analysis of resource deployment and the geographic areas expected to receive coverage from fire department units responding to an incident, it was revealed that the BCFD may meet apparatus response time performance objectives described in industry standards, but may be failing to meet NFPA 1710 staffing performance objectives.

Specifically, the following analysis of the BCFD concludes that:

• The BCFD should increase staffing on all engine, ladder and rescue companies to provide for a minimum of four personnel deployed on these types of apparatus at all times, thereby meeting company staffing objectives in NFPA 1710 Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments;

• The BCFD should staff the command vehicle with a Battalion Chief and one firefighter. NFPA Standard 1710, Section 5.2.1.2.5, states that, “supervisory chief officers shall have staff aides deployed to them for purposes of incident management and accountability at emergency incidents.”

These measures will work to ensure that the BCFD continues to evolve into compliance with established NFPA industry standards. Moreover, it promotes safer and more effective fire suppression and disaster incident mitigation, while expediting the delivery of essential fire and emergency medical services to the citizens of Bay City.

Introduction

This report summarizes the results of an analysis of station location and emergency response times for the BCFD, Michigan. Currently, BCFD deploys apparatus and personnel from four fire stations which respond to emergencies within Bay City. In recent years, there has been an increasing demand for emergency services.  IAFF Local 116 has generated this report addressing deployment and staffing issues, including the need for additional personnel to manage increasing demand for services. This study examines predicted response times and geographic coverage for fire department units deployed from current station locations.

The fire stations are staffed with a minimum number of personnel who respond on appropriate apparatus, determined by the type of call received.  Station location, staffing and apparatus deployment are detailed on page 4 of this report. The current deployment model has been evaluated using the Arc View 3.2a and Network Analyst Geographic Information Systems (GIS) software. The results are graphically depicted on the following pages.

 OVERVIEW REPORT

 In accordance with NFPA Standard 1710, Section 4.3.2 the Bay City Fire Department Equips all of its apparatus with AED’s and all requires all Fire Fighters to be trained in their use.

GIS Analysis

Using Arc View 3.2a and Network Analyst Geographic Information Systems (GIS) software, which analyzes a computer model of the street network; several plots were generated predicting which roads within Bay City could be covered by the BCFD within two time frames, using different combinations of apparatus and station locations.  The output of this process shows coverage based on information provided by Local 116.

Estimated response time, for the purposes of this analysis, is defined as “the time when units are reroute to the emergency incident and ends when the units arrive at the scene.”[1]  Accordingly, response times in this analysis are based on 4 and 8-minute travel times, for first due and full alarm assignments, respectively.  However, it should be noted that total response time, from the time the request for assistance is placed to the time personnel arrive on the scene, may take a few additional minutes, due to factors such as call processing, dispatch and turnout time. Typically, these components will add 2 additional minutes to overall response time.

Travel speed is based on reasonable and prudent road speeds (see chart below).  Colored polygons enclose areas where roads can be traveled within each response time criteria.  Colored lines show those roads predicted to be covered within each response time criteria.  Percentages of roads predicted to be covered within the stated response times are based on software calculated roads lengths.  The report that follows is a “best estimate” response time model of those roads covered by the BCFD.

Travel speeds were assigned based on road type.

Assigned Road Speeds:

Primary roads with limited access, interstates, un separated                                     55 mph

Primary roads with limited access, interstates, un separated, over passing                55 mph

Primary roads with limited access, interstates, separate                                          55 mph

Primary roads without limited access, interstates, un separated                                45 mph

Primary roads without limited access, interstates, separated                                   45 mph

Secondary or connecting roads, county highways, un separated                              35 mph

Secondary or connecting roads, county highways, separated                                  35 mph

Local, rural roads or Town streets, un separated                                                    25 mph

All other smaller roads, routes, trails, including freeway access ramps                     20 mph

Current BCFD Fire Department Apparatus, Field Staffing, and Deployment

Station                        Address                                   Apparatus                   Staffing

Station 1           1401 Center Ave.                     Engine 1                       2-Fire Fighter/EMT’s

                                                                        Aerial 1                        2-Fire Fighter/FR’s

                                                                        Rescue 1                      2-Fire Fighter/EMT’s

                                                                        Battalion Car                1-Battalion Chief

Station 2           1000 Freemont             Engine 2                       3-Fire Fighter/EMT’s

                                                                        Haz-Mat 1                   Cross-staffed[2]

Station 4           212 S. Dean                             Engine 4                       3-Fire Fighter/EMT’s

Station 5           1209 Smith St.                         Engine 5                       3-Fire Fighter/EMT’s

Recommended BCFD Fire Department Apparatus, Field Staffing, and Deployment

*Changes identified in red italics*

Station                        Address                                   Apparatus                   Staffing

Station 1           1401 Center Ave.                     Engine 1                       4-Fire Fighter/EMT’s

                                                                        Aerial 1                        4-Fire Fighter/FR’s

                                                                        Rescue 1                      4-Fire Fighter/EMT’s

                                                                        Battalion Car                1-Battalion Chief

                                                                                                            1-Chief’s Aide

Station 2           1000 Freemont             Engine 2                       4-Fire Fighter/EMT’s

                                                                        Haz-Mat 1                   Cross-staffed

Station 4           212 S. Dean                             Engine 4                       4-Fire Fighter/EMT’s

Station 5           1209 Smith St.                         Engine 5                       4-Fire Fighter/EMT’s

Maps

Map 1

Map 1 shows the general layout of the response area with current fire stations, City road network, hospitals, schools, rail lines, the Saginaw River, municipal airport, and Bay City boundaries identified.
 Map 2

NFPA 1710 Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments states the “fire department’s fire suppression resources shall be deployed to provide for the arrival of an engine company within a 4-minute response time to 90% of the incidents.”

The 4-minute arrival goal, while important for the extinguishment of small fires, is essential for EMS first response.  Cardiac arrest is one of the most critical medical emergencies that can be treated in the field.  The use of an automated external defibrillator by trained personnel is integral to the treatment and survival of cardiac arrest.  According to the National Institutes of Health: National Heart, Lung, and Blood Institute, there need to be sufficient first responder units deployed in the community at all times to ensure a rapid response to all life-threatening calls.  “As a rule of thumb, a first responder should arrive on the scene less than 5 minutes from the time of dispatch in 90% of all such calls.”[3]

Map 2 shows that 98% of all roads within the response area may be reached by at least one unit from current stations within 4 minutes.  This scenario assumes that at least one staffed unit from each station is available for response.  If any unit is unavailable, for any reason, a second due unit must provide the required assistance, with some delay.

Map 3

Map 3 shows that 59% of all roads within the response area may be reached by at least one ladder company within 4 minutes.  This scenario assumes that at least one staffed unit from each ladder company station is available for response.  If any unit is unavailable, for any reason, a second due unit must provide the required assistance, with some delay.

Map 4

Map 4 shows those areas that are currently covered within 8 minutes from all fire stations.  Apparatus may reach approximately 100% of roads within 8 minutes.  This 8-minute goal for arriving companies is critical because the progression of a structural fire to the point of “flashover” (the very rapid spreading of a fire due to super heating of room contents and other combustibles) generally occurs in less than 10 minutes.  As there is a potential delay between fire ignition, discovery, and the transmission of an alarm, it may be said that flashover is likely to occur within 8 minutes of fire fighters receiving the alarm.[4]   It is critical that apparatus arrive on the scene within 8 to 10 minutes, before the fire’s exponential growth exceeds the capabilities of the on-scene resources to mitigate the emergency.[5]  In reality, due to simultaneous calls, or calls requiring multiple units, actual response times may be longer.

In addition, structure fires occurring at the farthest reaches of the 8-minute polygons indicated in Map 4 are more likely to burn up to and beyond the point of flashover, which presents significant risk to fire fighters operating within a structure.  This may force operations to shift from an offensive mode to a defensive mode.  This is especially true in structures which have no automatic suppression or detection systems, as seen in older buildings.

Map 5

Map 5 illustrates that 97% of all City roads can be reached by a truck company within 8-minutes. Truck companies perform an invaluable service on the fire ground and are assigned to forcible entry, ventilation, search and rescue, utility control, illumination, overhaul, and salvage work. NFPA 1710 states that, “The initial full alarm assignment shall provide for the following… (5) A minimum of one search and rescue team shall be part of the initial full alarm assignment. Each search and rescue team shall consist of a minimum of two personnel. (6) A minimum of one ventilation team shall be part of the initial full alarm assignment. Each ventilation team shall consist of a minimum of two personnel. (7) If an aerial device is used in operations, one person shall function as an aerial operator who shall maintain primary control of the aerial device at all times.”

NFPA Standard 1710 further states that, “Fire companies whose primary functions are to perform the variety of services associated with truck work, such as forcible entry, ventilation, search and rescue, aerial operations for water delivery and rescue, utility control, illumination, overhaul, and salvage work, shall be known as ladder or truck companies.  These companies shall be staffed with a minimum of four on-duty personnel…In jurisdictions with tactical hazards, high hazard occupancies, high incident frequencies; geographical restrictions…these companies shall be staffed with a minimum of five or six on-duty personnel.”[6]

Map 6

Map 6 shows that 97% of all roads within the response area may be reached by the Battalion Chief within 8 minutes.  This scenario assumes the Battalion Chief is responding from the assigned station. 

NFPA Standard 1710, Section 5.2.1.2.5 states, “Supervisory chief officers shall have staff aides deployed to them for purposes of incident managements and accountability at emergency incidents. NFPA Standard 1710, Section A.3.3.37, outlines the requirements and duties of a staff aide. It states that, “this member is assigned to a supervisory chief officer who assists at incident scene operations, which can include personnel accountability, communications, and other logistical and administrative support. In addition this member can assist in coordinating training activities, respond to citizen inquiries, coordinated staffing issues and sick leave follow-up, and resource allocations for facilities and apparatus under the supervisory chief officer’s jurisdiction. Staff aides can be known as field incident technicians, staff assistants, battalion fire fighter, or battalion adjutant.”

The BCFD should make it a priority to assign a staff aide to the Battalion Chief to ensure that the Battalion Chief has all the necessary resources available to safely, effectively, and efficiently manage any emergency incident.

Map 7

Minimally, a crew of four is desired to make a safe initial attack on a fire, with a crew of two working inside the burning structure and a backup crew of two standing by to assist as necessary.  This is known as the “2 In/ 2 Out Standard.”[7] Map 7 illustrates that an interior attack can currently be safely initiated for structures located on 97% of all City roads within 8 minutes, assuming that all units are available. Two of the most important elements in limiting fire spread are the quick arrival of sufficient numbers of personnel and equipment to attack and extinguish the fire as close to the point of origin as possible, we well as rescue any trapped occupants and care for the injured. Several existing National Fire Protection Association standards address this time-critical issue. NFPA 1500 States, “while members can be assigned and arrive at the scene of an incident in many different ways, it is strongly recommended that interior fire fighting operations not be conducted without an adequate number of qualified firefighters operating in companies under the supervision on company officers. It is recommended that a minimum acceptable fire company staffing level should be four members responding on or arriving with each engine and each ladder company responding to any type of fire.” NFPA Standard 1710 further recommends that “fire companies whose primary functions are to pump and deliver water and perform basic fire fighting at fires, including search and rescue…shall be staffed with a minimum of four on-duty personnel,”[8] while “fire companies whose primary functions are to perform the variety of services associated with truck work, such as forcible entry, ventilation, search and rescue, aerial operations for water delivery and rescue, utility control, illumination, overhaul and salvage work…shall [also] be staffed with a minimum of four on-duty personnel.”[9]

The “2 In/ 2 Out” Standard, codified as OSHA 29 CFR 1910.134, requires a crew of two working inside the burning structure to be protected by a crew of two standing by to assist as necessary, to make a safe initial attack on a fire. Currently, the BCFD maintains minimum staffing on all companies at 2-3 personnel. The operator of the apparatus must remain with the apparatus to safely operate the engine pump or quint pump and/or ladder. This can leave a crew of as little as two or three personnel (depending on the station) to initiate fire attack and search and rescue activities. Therefore, such activities initiated by a single company would not be in compliance with the “2 in/ 2 Out” regulation until a second unit arrives to assist the first-due company.

Those structure fires located within the area depicted in Map 7, where a sufficient number of adequately staffed apparatus can arrive at a common destination within 8 minutes, will receive the equipment and personnel required to initiate safe and effective fire suppression and rescue operations in accordance with OSHA and NFPA “2 in/ 2 Out” guidelines outlined in this report. As the progression of a structural fire to the point of flashover generally occurs in less that 10 minutes, it is predicted that those structure fires at the furthest reaches, and beyond the extent of, the 8 minute polygons indicated above are more likely to continue to burn up to and beyond the point of flashover. Currently, those areas that can expect to receive adequate coverage to institute “2 in/ 2 Out” fire suppression and rescue operations total 97% of all response area roads.

Map 8

In addition to the NFPA guidelines which offer recommendations on response times for a full alarm assignment, this standard also provides criterion for the capabilities of a full alarm contingent.  Including incident command, there should be no less than 15 fire fighters on the scene of a full alarm incident, 17 if a second Pump and Aerial device are in operation.[10]  These 15-17 personnel provide for “establishment of incident command outside of the hazard area (includes commander and aide)[11]…an operator who shall ensure uninterrupted water application…attack and backup lines operated by a minimum of two personnel each to effectively and safely maintain the line…one support person for each support and backup line to provide hydrant hookup, assist in line lays, utility control, and forcible entry…a minimum of one victim search and rescue team consisting of a minimum of two personnel…a minimum of one ventilation team consisting of a minimum of two personnel…an aerial operator who shall maintain primary control of the aerial device at all times…establishment of an IRIC[12] that shall consist of a minimum of two properly equipped and trained personnel.”[13]^,[14]

According to information provided by the BCFD, a full alarm consists of 4 engines, 1 ladder, and 1 Rescue, 1 Battalion Chief. This equates to a total of at least 15-18 personnel on-scene (depending upon daily staffing levels), satisfying NFPA 1710 5.2.3.2.2 initial full alarm assignment capability. The response area above assumes that the nearest units are dispatched, for a total response of at least 15 personnel. The above area does not take into account actual dispatch procedures, but rather is a reflection of the total area that could be covered by a NFPA 1710 compliant response if the nearest units were to be dispatched upon alarm. Currently, the BCFD is capable of assembling at least 17 firefighters, in compliance with NFPA Standard 1710, on 75% of all roads located within the response area. Unless 90% of all calls occur on these 75% of roads, the BCFD is not in compliance with NFPA Standard 1710.

Fire Suppression Deployment Issues

Increased Fire Staffing: Data generated by the National Fire Protection Association provides evidence that rapid and aggressive interior attack can substantially reduce the human and property loss associated with structural fires. At each stage of a fire’s extension beyond the room of origin, the rate of civilian deaths, injuries, and property damage grows exponentially. Clearly, an early and aggressive offensive initial interior attack on a working structural fire results in greatly reduced loss of life and property damage. Consequently, given that the progression of a structural fire to the point of “flashover” (the very rapid spreading of fire due to super heating of room and contents and other combustibles) generally occurs in less than 10 minutes[15], two of the most important elements in limiting fire spread are the quick arrival of sufficient numbers of personnel and equipment to attack and extinguish the fire as close to the point of origin as possible.

Assuming a crew of 5 fire fighters is 100% effective in performing the critical tasks required for an interior fire attack, the following table[16] shows the impact that reduced staffing has on the effectiveness of fire ground operations involving a single-family residential structure.

The results in the table above have recently been supported for small fire departments by the Westerville, Michigan Fire Department.[17] Using standard firefighting tactics, the results of the Westerville Fire Department study showed that 4 fire fighters could perform rescue of potential fire victims 80% faster than a 3 fire fighter crew. The enhancements that increased crew size can have on rescue operations are all the more dramatic when victim survivability is considered. Data produced by the Dallas Fire Department showed that when rescue occurred between 12 and 15 ½ minutes, the survival rate was 46.6%. The rate dropped to 5.5% when rescue occurred between 15 and 17 ½ minutes. Thus a variance of only 2 to 3 minutes in the speed with which rescue operations could be completed can increase fire victim survivability eightfold.

Consequently, the fire service in North America has for most of the twentieth century accepted the premise and the expectation that fire fighters will perform aggressive interior fire attacks when confronted with a working structure fire whenever possible. This has been and still is the industry’s standard of performance.

Crew Safety

The linkage between fire fighter safety and the number of personnel on the initial fire attack has been demonstrated in study after study. In 1982, the U.S. Fire Administration conducted a survey of over 150 fire departments as to current crew size and standard response practices.[18] When asked to identify those factors that were most important in determining crew size and initial response, fire chiefs and city managers ranked crew safety at the top of the list.

To test the relationship between staffing effectiveness and fire fighter injuries, Jon Cushman of the Seattle Fire Department undertook three separate analyses over a 5-year period. The studies showed: average time per disability increased as company strength decreased for both types of companies (engine and ladder). The results indicated that the rate of fire fighter injuries expressed as total hours of disability per hours of fire ground exposure where 54% greater for engine companies staffed with 3 personnel when compared to those staffed with 4 fire fighters, while companies staffed with 5 personnel had an injury rate that was only one-third of that associated with 4-person companies. An even more telling statistic relates to the severity rates in Cushman’s subsequent analysis that also concluded that average hours per disability associated with 3-person Company staffing were nearly 50% greater than those occurring when units were staffed with 4 and 5 personnel. One in three fire fighters was injured in the line of duty.[19]

The Dallas Fire Department, in 1969 and again in 1984, also conducted textbook drills and live fire tests to compare the effectiveness among various levels of staffing.[20] The study concluded that deficient levels of staffing will result in an inability to cover critical tasks. As the numbers of fire fighters decrease without eliminating any of the tasks to be accomplished the Department must delay some of the required tasks of attempt to perform all the tasks unsafely with inadequate staff.  Consequently, the Dallas Fire Department concluded that in a residential fire: The five-person crews demonstrated a more coordinated and effective attack on the fire and search and rescue operations, while the four person crew was capable of performing satisfactorily in controlling the fire and in effecting the rescue operation. The study’s conclusion regarding the three-person crew was that not all the required critical tasks could be accomplished within the given time span. Regarding the three person crew, the report stated: At this level there was little margin for error and any appreciable delay in arrival might place control of the fire beyond their capability.

This is an extremely important statement given that the Dallas Fire Department took great care to insure that the time spent to complete critical tasks was not made at the expense of sound operating practices or safety. However, this would not be the situation in actual fire ground operations. Fire fighters operating in understaffed environments are too often expected to perform beyond their capabilities. The National Fire Academy also noted in a research project developed for its Executive Development III Program that: The average time of the Engine Company (in the Dallas Studies) is revealing. The first (simulation) consisted of a three-man team and their average time was 18.18 minutes. All personnel were exhausted, rubber legged, and had difficulty standing up and all three were unfit for further fire fighting. The four-man team conducting the very same test, averaged 10.29 minutes and upon completing they were nearing exhaustion. Next came the five-man team which averaged 6.15 minutes, and afterwards all showed little evidence of fatigue.[21]

In 1993, the Austin Fire Department embarked on a study to determine whether companies staffed with 4 fire fighters were safer and more effective than the 3 person companies the Department was currently employing. In order to compare effectiveness, physiological impact on fire fighters and Austin Fire Department injury rates at various staffing levels, the Fire Department conducted drills consisting of a series of common fire ground tasks divided into three scenarios: a simulated two-story residential fire, a simulated aerial ladder evolution, and a simulated engine company high-rise fire. These simulations revealed, once again, that regardless of the experience or how prepared firefighters are, with an insufficient number of personnel to conduct tasks efficiently, inevitably life and property continue to suffer. Severity and the degree of hazard increases until controlled or the fire passes the critical point. Consequently, the Austin Fire Department concluded that the effectiveness significantly improved when the company was increased from 3 to 4 personnel. The Austin Fire Department’s report stated: In the two story residential fire the efficiency or time improvement between three person and four person crews was 73%. In aerial ladder evolution the efficiency improvement between three and four person crews was 66%. In the engine company high-rise fire the efficiency improvement between three and four person crews was 35%. Averaging all scenarios the improved efficiency was 58%.

The Austin Study also examined the physiological impact of increased company level staffing fire fighters. Before and immediately after the completion of each scenario, medical evaluations including pulse, respiration, blood pressure, EKG strips, body temperature, and visual assessment were given to each fire fighter. Not surprisingly, the crews consisting of 4 fire fighters recorded a notable decrease in the pulse rate (cardiovascular stress level) and respirations than did 3 person crews. For three person crews the average pulse rate per minute, post drill was 127.28; whereas, the average pulse rate per minute for the four person staff was 119.69. This is a 16% increase with the two crews having equal baseline pulse rates. Air consumption for each firefighter working on a four-person crew as opposed to a three person crew decreased by 53%. The dramatic increase was determined to be a result of less exertion involved in the exercises with four-person crews. Visual assessment of each firefighter verified the additional exhaustion level of the three person crew members. The importance of this study is not so much what it directly revealed, but what conclusions can be drawn from combining this information along with firefighter death studies. Thirty-nine percent of firefighter deaths are the result of heart attacks[22]. If four person crews result in decreased physiological stress, then it follows that there should be fewer deaths from heart attacks.

Conclusion

This analysis shows the extent of coverage provided by the BCFD with units responding from current station locations. Upon analysis of resource deployment and the geographic areas expected to receive coverage from fire department units responding to an incident, it was revealed that, while the BCFD progressively allocates its existing resources, additional staffing on all fire suppression companies, as well as the addition of a Chiefs Aide to the Battalion Chief, are needed to better comply with established National Fire Protection Association (NFPA) and industry standards.

Information provided by Local 116 indicated that there are approximately 4,000 emergency responses annually. The frequency of emergency responses continues to increase, due to growth in the area. Therefore, fire department units are frequently already assigned to a response when a simultaneous or concurrent call is received.   The maps in this study are based on the assumption that all fire department units are available for immediate response when a call for service is received.  If units are already responding to other calls, then the coverage as shown in this report will decrease.  The addition of more stations, staffed apparatus, and increased staffing on all apparatus will assist in reducing time citizens spend waiting for emergency response.

The BCFD utilizes a minimum staffing of 2-3 firefighters on each company. The fire department contends that this policy enables the Department to handle increased call activity without adding costly resources. However, according to the National Fire Protection Handbook, staffing an Engine or a Ladder with insufficient personnel may lead to a loss of efficiency and increased fire losses. The Handbook states, “Staffing fire apparatus at a level below minimum requirements can result in a less effective and less safe fire fighting performance,” and that calling for additional assistance “should not be relied upon to replace adequately the required staffing and equipment needed immediately at the scene for initial attack and rescue.”[23]

Several existing National Fire Protection Association standards address these minimum staffing requirements.  NFPA 1500 Standard on Fire Department Occupational Safety and Health Program states, “while members can be assigned and arrive at the scene of an incident in many different ways, it is strongly recommended that interior firefighting operations not be conducted without an adequate number of qualified fire fighters operating in companies under the supervision of company officers. It is recommended that a minimum acceptable fire company staffing level should be four members responding on or arriving with each engine and each ladder company responding to any type of fire.” NFPA 1710 states “Fire companies whose primary functions are to pump and deliver water and perform basic fire fighting at fires, including search and rescue, shall be known as engine companies.  These companies shall be staffed with a minimum of four on-duty personnel…Fire companies whose primary functions are to perform the variety of services associated with truck work, such as forcible entry, ventilation, search and rescue, aerial operations for water delivery and rescue, utility control, illumination, overhaul, and salvage work, shall be known as ladder or truck companies. These companies shall be staffed with a minimum of four on-duty personnel…In jurisdictions with tactical hazards, high hazard occupancies, high incident frequencies; geographical restrictions…these companies shall be staffed with a minimum of five or six on-duty personnel.”[24] Many structures in the BCFD response area are tactical hazard occupancies[25] as they present an unusually significant fire or life safety hazard. These include high-rise residential units, commercial occupancies, and mixed-occupancy buildings.

While there is little precedence governing how the various fire protection standards, such as NFPA 1710, NFPA 1500, and the OSHA “2 In/2 Out Regulation” might be used in lawsuits, and potentially relied upon by courts to determine the “industry standard” for fire protection and safety measures, it is safe to assume that the level of fire and emergency medical services provided by a jurisdiction will be compared to these standards in courts considering such lawsuits, even where the particular jurisdiction has not specifically adopted these standards. As such, it is fair to say that Bay City may assume some additional legal risk by failing to abide by these national safety benchmarks. Therefore, it is imperative that staffing on all companies be increased to a minimum of four personnel at all times to ensure both fire fighter and citizen safety. 

Further evaluation of deployment and staffing in the BCFD is warranted. System evaluation should be completed using industry standards and safety regulations as guides. System evaluation should use Arc View or an equivalent geographic information system model to assess any potential changes in deployment. All options should be modeled and explored before any changes are implemented. The fire department should incorporate options into a long-term strategic plan which would assist in deferring costs of enhanced staffing and equipment utilization over a period of time.