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Testimony of Bill Stewart
Aircraft Rescue and Fire Fighting Working Group
before the
National Civil Aviaiton Review Commission
October 8th, 1997.

Good afternoon, on behalf of the Aircraft Rescue and Fire Fighting Working Group membership I would like to thank you for the opportunity to address this panel. The Aircraft Rescue and Fire Fighting Working Group or ARFF Working Group is a nonprofit organization

and was created to represent the interests of airport fire protection personnel. We currently represent more than one thousand members in twenty-six countries. It is our mission to improve the science and methods of aircraft fire protection and prevention through education, training and information exchange programs. Projects we are currently involved with include; Pilot/Incident Commander communications which will enable the pilot to talk directly to the chief fire officer in an effort to evaluate the immediate environment, standardized aircraft familiarization information which will better prepare the airport firefighter when working around commercial and commuter aircraft, and the development and promotion of an aircraft rescue fire fighter national standard in which all ARFF personnel could be trained and certified under. We conduct both regional and annual meetings in which new information is exchanged, along with past disasters examined to learn what procedures were conducted with success, as well as what procedures were not successful.

One of our main issues has been the content or lack of content involving Federal Aviation Regulation, Part 139 Certification and Operations: Land Airports Serving Certain Air Carriers. To be more concise, section 139.319 Aircraft rescue and firefighting Operational Requirements. The FAA is very specific in describing index determination, response requirements, as well as equipment and agents capacities needed to support airport operations. Areas within Part 139 that need to be developed can be found under section (j) sub-section (2) and are defined as the training curriculum. The items outlined in this section are extremely vague and can be interpreted in many different ways. The ARFFWG has requested through the FAA's Safety Office that Part 139 be rewritten or that some clarification be added in the section. FAA has stated they have no plans of rewriting or clarifying any part of Part 139. That is why it is the ARFFWG recommends that National Fire Codes and Standards 402M and 403 as written by the National Fire Protection Association (NFPA) be adopted and used as a minimum standard for all aircraft rescue and fire fighting services certificated by the FAA. NFPA 402M has been developed as a manual for Aircraft Rescue and Fire Fighting Operations and covers all aspects of Emergency Response, Aircraft Construction and Materials, Evacuation and Rescue, Fire Control and Extinguishment, Post Aircraft Accident Procedures along with many other pertinent subjects. NFPA 403 deals with administration and organization, Extinguishing Agents, Emergency Vehicles, Communications, Protective Clothing, and Fire Station Location and Response Capability. As mentioned earlier, the ARFFWG has requested that part 139 be reopened with hopes that we could assist in the clarification process of this document. Since the NFPA reviews and amends all codes written, the ARFFWG would have direct input in this document by serving on the various review committees.

Aviation safety and fire fighting response would be enhanced with the adoption of NFPA 402M and 403. Fire fighters would be better prepared by having an in-depth knowledge of what is expected in the event of an emergency. Fire fighters would be able to better protect the flying public by being prepared for fire/emergency response procedures and operations.