NFPA 1582 and the Training Officer

By: John K. Murphy JD, MS, PA-C, EFO

A question for training officers and chief officers – do you have a medical/physical evaluation program and a physical abilities test in your department providing bi-annual (or annual) testing for your firefighters? If not, why not? Almost 50% of firefighter deaths are caused by a preventable disease such as heart disease and cardiac arrest. Is this one of the responsibilities of the Training Division or department to implement and manage? What do your firefighters do on a daily basis and how do you test their capacity for doing work? Using your department’s job description, job analysis and essential elements of the job is the foundation for continuing medical evaluations and abilities testing. There are two distinct processes in play to determine the fitness of your firefighters. The first is the entry standards of a CPAT and using the NFPA 1582 guidelines as a basis for new entry level firefighters. The second, for your established firefighters or one returning from an injury or disability is an entirely different process which we will discuss later in this article. Entry Level Firefighters – Preplacement. There are usually no issues with a Physical Abilities test for entry level firefighters as it is generally a pass/fail proposition and the Training Division may administer this portion of the entry test in some form or fashion. Many fire departments are now using the CPAT testing model with good results. If not using the CPAT, then your physical abilities test should test the essential functions of the job and not use a Combat Challenge or other similar competitive process. Failure of this physical abilities test automatically disqualifies the candidate. Candidate Medical Physical - After the offer of employment by the department, the candidate is sent to a qualified medical practitioner for a complete and thorough medical examination. Again, many departments use the NFPA 1582 as a guideline for the components of the medical/physical evaluation with a physician or other qualified health care practitioner fully versed in what the fire department actually does on a day to day basis. The NFPA 1582 are guidelines for your use unless adopted by your State or your department in their entirety then become the regulation which departments must follow. If there are medical issues discovered during the candidate medical/physical, you may want to dig a little deeper with additional medical testing with a specialist to see if the medical condition actually disqualifies this candidate. You also need to closely read and understand the categories “A” disqualifiers and the “B” allowances for all medical conditions to make sure your candidate is either qualified or unqualified due to a limiting medical condition. I have sent candidate firefighters to specialists for further evaluation as there was some abnormality on the EKG, Pulmonary Function Test or the blood tests. If they return from these specialists with a clearance to continue, then the candidate can proceed in the process to hopefully the ultimate hire. Existing Firefighters - This is where the Training Division/Officer comes into the picture. It is my learned opinion that the Training Officer and Training Division evaluates, teaching and trains your firefighters more than other officers in your department. You observe their ability to work at high levels of performance and can determine if a firefighter is poorly conditioned, deconditioned or in general, is a hazard to himself/herself and others. These are the ones that should be identified as high risk and sent for medical evaluations and many times these are your existing long term firefighters showing signs of a critical medical condition. I highly recommend that your department have an annual or bi-annual medical/physical examination program in place for all firefighters and possibly a for-cause medical testing for firefighters showing signs of a condition preventing them from working at 100% of capacity. For those firefighters with a possible critical medical condition (hypertension, hypercholesterolemia, coronary artery disease or diabetes to name a few) discovered in the physical, the department must have a policy and program to allow the firefighter to find a medical solution to the discovered medical issue. What should be (at a minimum) included in a periodic medical standard is: basic questions about current health history, current immunizations with the addition of specific blood work to include liver function, cholesterol, blood glucose level, a CBC (complete blood count), your immunity to Hepatitis B, chest x-ray or PPD, hearing testing, pulmonary function testing, mask fit testing and other testing as determined by your health care provider based on your job description or job analysis. For male firefighters a PSA to detect possible prostate cancer. There are a number of blood tests to detect certain cancers however those tests have some false positive results. They should be used judiciously by your health care provider during the physical examination. It is developing technology that will make our firefighters healthier. For those of you on the Haz/Mat team, include baseline testing for the most common heavy metals to include lead, mercury, arsenic, cadmium, copper and zinc. All firefighters should be examined for developing skin or throat cancers. These tests are closely correlated with your job description, job analysis and essential functions of the job. What is very important, is the resting EKG and stress treadmill testing to ensure cardiovascular health and the results evaluated by a cardiologist. Injured Firefighters – Return to work independent medical examinations (IME) Using the NFPA 1582 as a return-to-work standard is the wrong standard to utilize when returning an injured or disabled firefighter to work. The NFPA 1582 guidelines have been designed as an entry level standard for firefighters and there are certain medical elements contained within that document that would disqualify an injured firefighter (or some existing firefighter if tested) seeking to return to work. My suggestion is to have an IME predicated on the actual functions of the job performed by a qualified physician. For example a firefighter out with a rotator cuff repair, an orthopedist should perform the IME using the essential functions of the job and a job analysis. There are a number of firefighters successfully returning to work after a heart attack, rotator cuff repair, spinal disk repair, hip or knee replacement surgery and other medical conditions. Finally - As an attorney and health care practitioner, I have toss in this little nugget - you may have to make reasonable accommodations under the ADA rules and regulation for firefighters that cannot pass the medical/physical or physical ability test. Under the law (eeoc.gov), Title I of the ADA requires an employer to provide reasonable accommodation to qualified individuals with disabilities who are employees or applicants for employment, except when such accommodation would cause an undue hardship on the employer. As this is a complex issue, I suggest employers look at the EEOC website and discuss this issue with your HR director and the department’s attorney for guidance. Our responsibilities as Training Officers is safety on the training grounds. Ensuring your firefighters are healthy enough to participate in training activities is also your responsibility.