NFPA 1321, Fire Investigation Unit (FIU) Should Be Changed To Fire and Explosion Investigation Unit

National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPar...
Public Input No. 104-NFPA 1321-2021 [ Global Input ]
Fire Investigation Unit (FIU) should be changed to Fire and Explosion Investigation Unit
(FEIU).
Statement of Problem and Substantiation for Public Input
This aligns better with NFPA 921 and includes those agencies that perform post-blast investigations.
Submitter Information Verification
Submitter Full Name: Paul Ayres

Organization: Donan
Street Address:
City:
State:
Zip:
Submittal Date: Thu Dec 30 09:35:46 EST 2021
Committee: FIC-AAA
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All References to Fire Investigation Unit (FIU) should also be accopanied by "or parent
organization".
The document currently gives the false perception that the Fire Investigation Unit should make policies
independent of the parent organization. The parent organization policies and procedures do in fact
govern the operation of subordinate units and the parent organization polices would suffice as required
or referenced by this document.
Submitter Full Name: Robert Schaal

Organization: Gulf Coast FIRE
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 04 18:07:13 EST 2022
Committee: FIC-AAA
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NFPA standards are only recommendations. Unless adopted by a state or territory they
should not be a mandatory requirement for any training or certification. States use an
established training program and criteria to train personnel and administer tests. While
NFPA documents are utilized in the training, it is not the sole source of the training and
testing. It also appears that in some sections 1033 is required and in others it is optional,
making this an either/or leaves much open to interpretation.

Please see narrative regarding 1033 and mandatory requirements
Submitter Full Name: Joey Lankford

Organization: Bedford Fire Dept
Affiliation: Bedford Fire Department
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 05 09:54:11 EST 2022
Committee: FIC-AAA
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Each section of the document should indicate that the FIU shall have a policy for...rather
than specifying what the FIU shall do. It is up to the FIU to determine what actions will be
taken within the unit and create policies and procedures accordingly.
Currently, several sections within the document dictate specific actions that the FIU shall take, rather
than indicating that the FIU shall have a policy to address those areas. It is appropriate to include, "The
FIU shall have a policy for..." allowing the FIU to create policies and procedures applicable to the
needs of their unit.
Submitter Full Name: Richard Jones

Organization: Forensic Investigations Group,
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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Change the standard to a guide. Change the use of the word shall to should in relation to
a guide.
This document needs to be published as a guide and not a standard. Much like NFPA 1402 that was
initially produced and followed as a guide, which will allow the fire investigation industry to adjust to
using it for a few cycles before it becomes more restrictive and mandatory as a standard. The fire
investigation field has undergone serval changes in the last twenty years and an abrupt issuance of
such a far reaching standard as this document would have more of a detrimental affect than a
beneficial one. Changing this document to a guide would provide a more measured implementation of
its recommendations and therefore create greater acceptance of its content.
Additionally, when reviewing the reference materials NFPA 1730: Standard on Organization and
Deployment of Fire Prevention Inspection and Code Enforcement, Plan Review, Investigation, and
Public Education Operations, 2019 Edition was not included. Since NFPA 1321 involves public fire
investigations units it should correlate with and reference NFPA 1730.
Submitter Full Name: Stephen Rinaldi

Organization: Chelan County Fire Marshal
Affiliation: N/A
Street Address:
City:
State:
Zip:
Submittal Date: Fri Nov 19 16:33:11 EST 2021
Committee: FIC-AAA
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Type your content here ...In relation to 6.5.4 (FIU Vehicle): (Verbiage to also
include) "Vehicle that's capable of temporarily storing evidence that's segregated from
the passenger compartment". We get very close to suggesting the use of pick-up trucks
with some sort of cover for the bed, but stop short. Using a reasonable person standard,
we know and understand trucks make logical sense. This document is meant to use
words of "shall" and "should". Instead of mandating same by saying "shall", why not
say "should" use pick up trucks? It doesn't carry the same heavy handed perception as
"shall", but is still pretty strong language which can and will make a world of difference
in the event those matters end up in civil litigation. The fact is, regardless of the
verbiage, some entities (public and private) will buck the document. If the intent and
purpose of the document is to create a better mechanism that standardizes work and
environmental safety for Investigators across the board, then why not include it? We
understand there's a cost associated with all of this, but the potential health cost to the
investigator and their families far outweigh a monetary cost to an employer. It's all about
exposure mitigation. We can't "shall" and "should" everything, but we can for big topic
items that make sense. If it didn't, so many Departments, Agencies, Companies, etc.
around the Country wouldn't have already switched. We know that years of documented
research supports it. It's time to acknowledge the elephant in the room and practically
address it. Your ongoing efforts remain appreciated.
It's another tool, a substantial tool, used to mitigate post fire scene exposure. It's also a common
sense and practical means by which Investigators are able to readily respond to carry the equipment
they need for what's encountered on a majority of fire/explosion scenes.
Submitter Full
John Bull
Name:
Organization: NC Farm Bureau Insurance Special Investigations Unit
Boonville Community Volunteer Fire Department, Davidson
Affiliation:
County Fire Investigation Task Force
Street Address:
City:
State:
Zip:
Submittal Date: Wed Dec 15 16:27:46 EST 2021
Committee: FIC-AAA
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Public Input No. 158-NFPA 1321-2022 [ Chapter 1 [Title Only] ]
Administration
This standard should be discarded due to the information being proposed is covered in NFPA
1033 and 921, thoroughly. The proposed information is also covered in the public sectors SOG's
and the private sectors policies and procedures.
This standard should be discarded due to the information being proposed is covered in NFPA 1033
and 921, thoroughly. The proposed information is also covered in the public sectors SOG's and the
private sectors policies and procedures.
Submitter Full Name: James Platt

Organization: Jackson County Fire
Affiliation: none
Street Address:
City:
State:
Zip:
Submittal Date: Sun Jan 02 12:04:49 EST 2022
Committee: FIC-AAA
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Public Input No. 41-NFPA 1321-2021 [ Section No. 1.1 ]
1.1 Scope.
1.1.1
This standard shall cover the minimum requirements relating to the guideline shall establish
guidelines and recommendations for the establishment, structure, operation, and management
of fire investigation units (FIUs).
1.1.2
This standard shall guideline does not provide requirements relating to fire investigation
methodology.
1.1.3
This standard shall giudeline does not provide requirements relating to professional
qualifications of fire investigators.
Make the document a guideline rather that a standard. This document, as written, introduces a weight
of bureaucracy, especially onto sole proprietors and small agencies. Having a mission statement has
no bearing on the performance of a fire/explosion investigation. This document will introduce an entire
line of questioning into depositions and trials seeking only to discredit a company or an investigator on
non-issues rather than focusing on the methodology used to determine origin and cause and
conclusions drawn.
Submitter Full Name: Samuel Campbell

Organization: Forensic Fire Inv
Street Address:
City:
State:
Zip:
Submittal Date: Mon Dec 13 23:34:34 EST 2021
Committee: FIC-AAA
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Public Input No. 42-NFPA 1321-2021 [ New Section after 1.1.1 ]
TITLE OF NEW CONTENT

Type your content here ...1.1.1 In cases where a FIU has a parent organization (such as a fire
department), if polices already exist that establish minimum requirements outlined within this
document, the FIU will be considered as having those requirements as part of their unit.
Most public sector FIUs are just one small arm of a much larger organization. The requirements in this
document such as having a budget (4..3.1), the entire Ethical Principles (4.1.1.3), Personnel
Management (specifically (4.2.1.1 and 4.2.1.2), Health and Safety 4.2.1.4.1 (written policy related to
medical screening) and 4.2.1.4.2, Workload Analysis (4.2.3.1) will be covered in existing documents
and policy of the parent organization. Most Fire Chiefs would balk at having a completing and/or
similar policy in a subordinate unit.
Additionally, section 4.2.1.3 establishes (in that section) exactly what I am referring to when it reads:
The FIU or parent organization...
By creating this caveat in the Administration Section, it allows an FIU to be compliant with the
Standard without crossing the parent organization. The other solution would be to add "...or the parent
organization..." into almost every subsection throughout the document.
Related Public Inputs for This Document
Related Input Relationship

Public Input No. 43-NFPA 1321-2021 [Section No. 4.1.1.3.1]
Public Input No. 49-NFPA 1321-2021 [Section No. 4.2.1.1]
Public Input No. 61-NFPA 1321-2021 [Section No. 6.1]
Public Input No. 62-NFPA 1321-2021 [Section No. 6.2.11]
Submitter Full Name: Daniel Heenan
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Organization: Clark County Fire Department

Street Address:
City:
State:
Zip:
Submittal Date: Tue Dec 14 15:43:25 EST 2021
Committee: FIC-AAA
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Public Input No. 153-NFPA 1321-2022 [ Section No. 1.1.1 ]
1.1.1
This standard shall guide shall cover the minimum requirements relating to the establishment,
structure, operation, and management of fire investigation units (FIUs).
Overall this document reads more like a guide than a standard. The "requirements" in the document
are generally vague and generally direct the FIU to have a certain policy without having much in the
way of what should be in that policy or how it should be written. I assume that the purpose of the
vagueness is to not pigeonhole an agency into doing things a certain way, but then that calls into
question the usefulness of this document. If all of the so-called requirements are very vague then how
is this "standard" to be enforced? It seems like the real reason that this document was put together
was to give the lawyers and experts a way to attack each other within the scope of a particular case
rather than to provide useful information for investigators.
Submitter Full Name: Matt Benfer

Organization:
Affiliation: None
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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1.1.1
This standard shall cover the specifies the minimum requirements relating to the
establishment, structure, operation, and management of fire investigation units (FIUs).
The current text reads like an instruction to a group writing a standard, rather than defining the scope
of the standard. The standard says what it says and writing in the style of what the standard shall
cover does not serve the user.
Submitter Full
Philip Crombie
Name:
Organization:
NIST OSAC Fire and Explosion Investigation
Affiliation:
Subcommittee
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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1.1.2
This standard shall not provide requirements relating to fire investigation methodology as
addressed in the most current edition of NFPA 921 Guide for Fire and Explosion Investigations .
NFPA 921 is the accepted (gold) standard of care for fire investigations
Submitter Full Name: Paul Haas

Organization: All Fire Solutions Inc.
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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Public Input No. 206-NFPA 1321-2022 [ Sections 1.1.2, 1.1.3 ]
Sections 1.1.2, 1.1.3

1.1.2
This standard shall not provide requirements relating to fire investigation methodology.
1.1.3
This standard shall not provide requirements relating to professional qualifications of fire
investigators.
This standard does set requirements for fire investigation methodology and professional qualification
both in the text and by referencing other documents. Setting procedures and requirements for the
work of the FIU is central to assuring that fire investigations are properly conducted. Similarly, defining
professional qualification requirements for FIU staff is an essential element of FIU management that is
an essential element of this standard. The draft later specifically cites to 1033, so the draft does in fact
provide requirements.
Submitter Full
Philip Crombie
Name:
Organization:
Affiliation:
Subcommittee
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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1.1.3
This standard shall not provide requirements relating to professional qualifications of fire
investigators. Those qualifications are found in the most recent edition of NFPA 1033 Standard
for Professional Qualifications for Fire Investigator.
Reference need to be made to the accepted Standard of 1033.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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Public Input No. 207-NFPA 1321-2022 [ New Section after 1.2 ]

Revise the sec�on and add associated annex material.
1.2* Purpose.
This standard shall specify the minimum elements necessary to support FIUs . The purpose of this
standard is to define the minimum requirements that are needed for the effec�ve opera�on and
management of FIUs to provide high quality fire and explosion inves�ga�ons. This is achieved through a
quality assurance program. The standard is a suitable basis for accredita�on of the FIU. This standard
does not require accredita�on of the FIU.
A1.2 Accredita�on is a cri�cal element of the quality triangle for forensic science. This standard was
developed to form the basis for accredita�on of fire inves�ga�on units. NFPA 921, 1033, and this
standard work together to form the basis for high quality fire inves�ga�ons. See
Beyler, C. et. al. (2021), Strengthening Fire and Explosion Inves�ga�on in the United States: A Strategic
Vision for Moving Forward , OSAC Technical Guidance Document 0005, The Organiza�on of Scien�fic
Area Commi�ees (OSAC) for Forensic Science. h�ps://doi.org/10.29325/OSAC.TG.0005
Na�onal Commission on Forensic Science, Recommenda�on to the A�orney General Universal for
Accredita�on, Universal Accredita�on (2015), h�ps://www.jus�ce.gov/archives/ncfs/file/477851
/download
Strengthening Forensic Science in the United States: A Path Forward Commi�ee on Iden�fying the Needs
of the Forensic Sciences Community, Na�onal Research Council, ISBN: 0-309-13131-6, 352 pages, 6 x 9,
(2009), h�p://www.nap.edu/catalog/12589.html
The goal here is to define requirements for FIUs so that the fire investigations conducted by the FIU
will be of high quality. Users need to be informed that accreditation based upon a QAP developed
under this standard is both possible and important. The absence of any meaningful mention of
accreditation in the first draft should be remedied. Providing a supporting framework for the
accreditation of FIUs was the principal purpose of the OSAC proposal for the development of this
standard. Fire investigation is currently lacking the third side of the quality triangle in forensic science,
which is accreditation. A copy of the New Project Initiation Form that was the basis for the founding of
the TC is attached.
Submitter Full
Philip Crombie
Name:
Organization:
Affiliation:
Subcommittee
Street Address:
City:
State:
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Zip:
Committee: FIC-AAA
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1.3.1 Nothing in this Standard shall supersede the most current editions of NFPA 921 Guide for
Fire Investigations and NFPA 1033 Standard for Professional Qualifications for Fire Investigator
There needs to be a clear and distinct statement that this document shall not infringe on or supersede
921 and 1033.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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1.3 Application.
This standard shall apply to all public and private FIUs public FIUs .
The contents of this document are over-reaching by the NFPA to apply to the private sector. The intent
of this document is to assist public fire investigation entities in streamlining their practices. This
standard should not be applied to the private sector. Additionally, this would represent a financial
burden to governments that may be tasked with the enforcement of this standard within the private
sector.

Submitter Full Name: Aaron Johnson

Organization: Aaron Johnson, LLC
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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2.2 NFPA Publications.

National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.
NFPA 1033, Standard for Professional Qualifications for Fire Investigator, 2022 edition.
NFPA 921, Guide for Fire and Explosion Investigations, 2021 edition.
NFPA 921 was not referenced as in Annex A.1.2 which is needed to fully capture referenced
publications.
Submitter Full Name: Kevin Hays

Organization: Kevin B Hays Fire Consulting
Affiliation: CEO
Street Address:
City:
State:
Zip:
Submittal Date: Sat Jan 01 11:59:37 EST 2022
Committee: FIC-AAA
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NFPA 1033, Standard for Professional Qualifications for Fire Investigator, 2022 edition.
Other NFPA documents are referenced in this publication, but not referenced in the document itself. All
referenced materials should be listed in the list.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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NFPA 1033, Standard for Professional Qualifications for Fire Investigator, 2022 edition, most
current edition of NFPA 921 Guide for Fire and Explosion Investigations .
NFPA 921 can not be left out. 921's importance has been proven time and time again in the courts. If
this new standard cannot conflict with 921.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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Fire Investigation Unit Definition

There should be a definition of what exactly a "FIU" is and will be as defined in this publication.
The definition should also contain how many personnel a FIU consists of i.e "2 or more
investigators meeting 1033 qualifications" etc.
Adding a definition of what a FIU is and what it consists of will help agencies know if this is something
they should/can adopt.
Submitter Full Name: Joseph P Hales Jr

Organization: Camden County (NJ) Fire Marshal
Street Address:
City:
State:
Zip:
Submittal Date: Tue Oct 12 15:17:37 EDT 2021
Committee: FIC-AAA
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3.2.3 Shall.
Indicates
Indicates a mandatory requirement.
My proposal to 3.2.3 is to change the word shall throughout the document with should until there
is direction on how to comply with the requirements in the document.
If there was clarification on how to satisfy this document's requirements, it could eliminate the
confusion if the requirement is met.
Submitter Full Name: Brian Gordon

Organization: Palm Beach County Fire Rescue
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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Add the following defini�ons:
3.2.6 Scien�fic Method: The systema�c pursuit of knowledge involving the recogni�on and
defini�on of a problem; the collec�on of data through observa�on and experimenta�on; analysis
of the data; the formula�on, evalua�on and tes�ng of hypotheses; and, where possible, the
selec�on of a final hypothesis. [921, 2021]
3.2.7 Standard Opera�ng Procedure (SOPs): A wri�en organiza�onal direc�ve that establishes or
prescribes specific opera�onal or administra�ve methods to be followed rou�nely for the
performance of designated opera�ons or ac�ons. [1521, 2008]
3.2.8 Standard Opera�ng Guidelines (SOGs): A wri�en organiza�onal direc�ve that establishes
or prescribes specific opera�onal or administra�ve methods to be followed rou�nely, which can
be varied due to opera�onal need in the performance of designated opera�ons or ac�ons. [1521,
2015]
3.2.9 Fire Inves�gator – An individual who has demonstrated the skills and knowledge necessary
to conduct, coordinate, and complete a fire inves�ga�on. [1033, 2021]
3.2.10 Fire Inves�ga�on – The process of determining origin, cause, and development of a fire or
explosion. [921, 2021]
3.3.13 Quality Assurance Program (QAP): An organized process with the means of preven�ng
mistakes and avoiding problems when delivering services to end users.
3.3.14 Stakeholder: A person or en�ty with an interest or a concern in something, especially an
organiza�on.
3.3.15 Audit: A systema�c and documented process for obtaining records, statements of fact or
other rela�ve informa�on and assessing them objec�vely to determine the extent to which
specified requirements are fulfilled.
3.3.16 Non-conforming work: When the ac�vi�es or the results of the FIUs work do not conform
to its own procedures.
3.3.17 Correc�ve Ac�on: Improvements to an organiza�on’s processes taken to eliminate causes
of non-conformi�es or other undesirable situa�ons.
3.3.18 Root Cause Analysis: An approach for iden�fying the underlying causes of nonconforming work so
that the most effec�ve solu�ons can be iden�fied and implemented.
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3.3.19 End User: A person or en�ty that could or does receive a service that is intended for or
required by this person or en�ty. An end user can be internal or external to the FIU.
3.3.20 Technical Review: An examina�on of work product to assess the quality of the
inves�ga�on, whether its conclusions and opinions are reached through the use of an appropriate
methodology and supported by the data, and is within constraints of validated scien�fic
knowledge.
3.3.21 Administra�ve Review: An examina�on of work product to assess its conformity with
policies and procedures of the FIU.
3.3.22 Cer�fica�on: An authorita�ve a�esta�on; specifically, the issuance of a document that
states that an individual has demonstrated the knowledge and skills necessary to func�on in a
par�cular professional field.
3.3.23 Accredita�on: Third-party a�esta�on related to an organiza�on conveying formal
demonstra�on of its competence to carry out specific func�ons.
These definitions for terms used in the standard will clarify the meaning of used terms within the
standard. NFPA terms are used where available and appropriate.
Submitter Full
Philip Crombie
Name:
Organization:
Affiliation:
Subcommittee
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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3.3.4 Fire Investigation Unit (FIU).

An entity within , either stand alone or within a public- or private-sector agency, with the
responsibility for fire or explosion investigation. This does not include a single-investigator
private-sector agency.
The definition, as written, contains two problems: 1) it is ambiguous as written as it is unclear whether
stand-alone entities are covered by the definition and 2) the standard is designed for multiple-person
organizations, and not for single-member organizations (e.g. sole investigator and employee in a
private sector fire investigation firm). The proposed language solves this ambiguity and clarifies that
the definition does not include a sole investigator (and sole employee), private sector fire investigation
firm.
Specifically, an entity consisting of a private-sector, sole investigator (and employee) should not be
included in this definition because many of the draft's mandates would be inappropriate and/or
unrealistic to meet. The draft, as written, is designed to address issues in largely public-sector, multi-
person units. For good reason, the draft looks to provide a framework for quality management and
focuses on things like supervisor-employee relationships, inspections and/or reviews, and mandates
designed to secure necessary resources from parent organizations. In a private-sector, sole
investigator (and employee) entity, these issues are mostly moot, or may require substantive third-
party reviews which may be prohibited due to contracting agreements and confidentiality issues.
For example, it would be near-useless for a single investigator, private-sector entity to have to maintain
SOPs concerning hiring (4.2.1.1), SOPs concerning performance evaluations, supervision, discipline,
etc. (4.2.1.3), SOPs on the coordination of multiunit investigations (4.2.1.5.2), and a Records
Management System that evaluates workloads and the allotment of resources (4.2.3.1).
Should the draft maintain the definition of FIU to include single investigator (and employee), private-
sector entities, then the draft is need of many revisions which need to address how these mandates
can be met by that specific type of entity. This will be a hurdle for future drafts as additional language
or mandates will always have to be contextualized to address the single investigator, private-sector
entity.
Submitter Full Name: Melvin D Robin

Organization: FIRE SEQUENCE INVESTIGATIONS LLC
Street Address:
City:
State:
Zip:
Submittal Date: Wed Sep 22 08:51:45 EDT 2021
Committee: FIC-AAA
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An entity within a public - agency or private-sector agency company with the responsibility for
fire or explosion investigation.
This section should be very clear as to who this definition applies to. I am not sure that many refer to
private companies as agencies. If they do, a definition for agency should be added.
Also, this definition should be clear as to the size of "agencies" or "companies" that this applies to?
Should the standard be making all of these requirements for a investigation company that has a single
investigator? Do all of these requirements apply in that case?

Organization:
Affiliation: None
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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An entity within a public- or private-sector agency public agency with the responsibility for fire
or explosion investigation.
The contents of this document are over-reaching by the NFPA to apply to the private sector. The intent
of this document is to assist public fire investigation entities in streamlining their practices. This
standard should not be applied to the private sector. Additionally, this would represent a financial
burden to governments that may be tasked with the enforcement of this standard within the private
sector.
This definition should include more determining factors. Would this standard apply to the private
investigation or engineering firm that may only consult on a few (1-5) fires per year?


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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An entity within a public- or the public or private-sector agency with the responsibility for fire or
explosion investigation.
I believe the word "entity" suffices...by adding agency it causes redundancy...you could even take out
sector...because both are distinguished by public and private...
Submitter Full Name: Karl Morgan

Organization:
Affiliation: Division of Investigative and Forensic Services, Florida
Street Address:
City:
State:
Zip:
Submittal Date: Mon Oct 25 14:03:42 EDT 2021
Committee: FIC-AAA
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An entity within a public- or private-sector agency with the responsibility for fire or explosion
investigation.
Gramatical
Submitter Full Name: John Heinen

Organization: Keystone Experts and Engineers
Affiliation: Private Fire Investigations
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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investigation. An entity may include a standalone fire investigation unit, section, or division with
an agency; it may also include a team or group within the organization with designated fire
investigation duties not organized as a separate unit.
The language as present implies that the standard only applies to formally designated fire investigation
units. If that is the intent of the standard, then disregard the change. On the other hand, many
organizations have fire investigators who work within an existing division or unit, such as Community
Risk Reduction or Fire and Life Safety. The standard should be structured to apply to agencies that
have fire investigators regardless of the number of investigators or how the supervisory or
organizational system is designed.
Submitter Full Name: Ronald Marley

Organization: San Ramon Valley FPD
Street Address:
City:
State:
Zip:
Submittal Date: Sun Nov 21 07:18:10 EST 2021
Committee: FIC-AAA
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investigation.
The proposed definition for a Fire Investigation Unit is vague and should address or define some
of the standards within this document. Some agencies within Florida may conduct non-criminal
origin and cause investigations, and their department does not require them to collect evidence.
Some agencies collect evidence and outsource the analysis to an outside laboratory but do not
say how their laboratory is set up and operated.
How could an International Code or Standard be applied without knowing how the majority are set up
to conduct origin and cause investigations. Some public sector departments utilize their Fire Inspectors
to conduct origin and cause investigations. This standard, as written, will open up Pandora's box as
soon as an origin and cause report is submitted. This guide creates more doubt for others to use to
discredit how one came up with cause determination. Is there any future consideration or discussion
for each committee member to create State task groups? Committee member Jones is responsible for
Florida, Georgia, and Louisiana to evaluate this standard's impact. (would be an example)

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
33 of 273 1/6/2022, 11:23 AM


An entity A unit or group of individuals within a public- or private-sector agency tasked with the
responsibility for fire or explosion investigation.
With the original term "entity" you refer to the individual investigator which is already covered in quite
good detail in NFPA 921. You need to avoid crossing over into the venue of NFPA 921 and 1033. This
down the line will cause a lot of issues with regard to courts and Daubert.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
34 of 273 1/6/2022, 11:23 AM

Origin and Cause Report

The act of providing an account of facts relating to a specific fire or explosion investigation, an
account of the acts of an organization or its individuals as related to that fire investigation, a
description of the use of all aspects of the scientific method, and an expert opinion as to the
origin and cause (and where necessary, classification) of the specific fire or explosion event.
The problem with the existing language in Section 3 is that it only defines a "Report". This is found in
Section 3.3.9 which states "The act of providing an account of facts relating to past events or the acts
of an organization or its individuals." Fire investigations typically generate a multitude of reports
(verbal vs. written, origin and cause vs. documenting a specific event like receipt of evidence, etc.) and
given the scope, mission, contractual agreements with a client, etc., the need for a particular type of
report will vary. Therefore, in setting out mandates for information to be included in a report (such as in
Section 8.3.1 which calls for all aspects of the scientific method to be addressed in reports), the type of
report should be specified before the mandate is defined. The existing definition of "Report" lacks
specificity and, critically, does not address rendering expert opinions as to origin and cause,
classification, or addressing the scientific method.
This distinction is critical because there are things that should be included in an Origin and Cause
report that should not necessarily be included in any other type of report. At times reports are
generated where the focus may be on only one small part of the investigation (i.e. an interview) and
addressing "all aspects of the scientific method" -as called for in Section 8.3.1 of this draft- would be
inappropriate. This is particularly true in the private sector where often times a client request only a
brief synopsis of investigative activities and findings. The appropriate place to address "all aspects of
the scientific method" is in a designated "Origin and Cause Report".
The added definition corrects the issue of ambiguity and conflicting mandate in Section 8.3.1 by
making the distinction between "Report" and "Origin and Cause Report".

Organization: Fire Sequence Investigations
Street Address:
City:
State:
Zip:
Submittal Date: Mon Jan 03 10:22:32 EST 2022
Committee: FIC-AAA
35 of 273 1/6/2022, 11:23 AM

3.3.9* Report.
The act of providing an account of facts and opinions relating to past events or the acts of an
organization or its individuals.
Later sections on report generation outline requirements of fire investigators based on NFPA 1033 in
support of developing opinions based on physical evidence. While it is recognized the basis for much
of public center reporting is considered factual, conclusions are drawn based on data observed and
therefore should be considered opinion. Speaking from the commenters perspective, many private
sector reports nearly always contain some form of opinion.
Submitter Full Name: John White

Organization: Fire Cause Analysis
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
36 of 273 1/6/2022, 11:23 AM

Public Input No. 175-NFPA 1321-2022 [ Chapter 4 ]
Chapter 4 Organization, Process, and Management Systems

4.1 Organization Systems.
4.1.1 Administrative Requirements.
4.1.1.1 Organizational Structure.
4.1.1.1.1
Written policies that establish the legal basis for the operation and compliance with the AHJ
shall be maintained by the FIU.
4.1.1.1.2
The FIU shall maintain an organizational chart of supervision and accountability outlined in
graphic form.
4.1.1.2 Mission Statement or Scope of Work.
4.1.1.2.1
The FIU shall have written protocols detailing services the unit will provide.
4.1.1.2.2
The FIU shall document their commitment to allocate personnel, support, and resources to
uphold the mission statement or scope of work.
4.1.1.3* Ethical Principles.
4.1.1.3.1
The FIU shall have policies addressing integrity, accountability, independence and impartiality,
respect, professional commitment, and professional conduct.
4.1.1.3.2
The FIU shall have policies regarding conflicts of interest and management of identified
conflicts.
4.1.1.3.3
The FIU shall have policies and procedures identifying the management of information obtained
or created through investigation activities to ensure confidentiality.
37 of 273 1/6/2022, 11:23 AM

4.1.
1.
3
.4
The FIU shall have written policies identifying the procedures for the handling of complaints, to
include receiving, recording, evaluating, validating, and resolving the complaint.
4.1.2 Policies and Procedures.
4.1.2.1
The FIU shall have written policies and procedures for personnel, administration,
management, records retention, and standardized practices and methods utilized by the unit.
4.1.2.2
Each policy or procedure shall include instructions for the safe performance of tasks,
documentation, analysis, interpretation, and reporting.
38 of 273 1/6/2022, 11:23 AM

4.1.3
Quality Manual.
The FIU shall have a written quality manual detailing how the unit complies with the
organizational goals and responsibilities as outlined in the unit’s policies and procedures.
4.2 Process Systems.
4.2.1 Personnel Management.
4.2.1.1
The FIU shall have policies and procedures for the hiring and placement of personnel to
operate in accordance with their defined mission or scope of work.
4.2.1.2
The FIU shall maintain written job descriptions.
4.2.1.
3*
The FIU or parent organization shall have policies for performance evaluations, supervision,
discipline, discrimination and harassment, continuing education, maintenance of personnel
records, document control, and periodic reviews.
4
.2.1.4
Health and Safety.
4.2.1.4.1
The FIU shall have a written policy detailing the physical performance and medical
screening required to identify individuals as fit for duty at predefined intervals.
4.2.1.4.2
The FIU shall have policies in place to account for the recurrent safety awareness training of
employees.
4.2.1.4.3
The FIU shall have documented procedures for the maintenance of employee health
records.
4.2.1.5 Technical Procedure (Subcontracting Procedures).
4.2.1.5.1
The FIU shall have documented procedures to ensure that outsourced subject matter
experts are competent and comply with relevant requirements.
4.2.1.5.2
The FIU shall have policies regarding coordination of multiunit investigations.
4.2.2 Facilities and Equipment.
The FIU shall have written procedures for the procurement, maintenance, and personnel
training for fire investigation facilities and equipment.
4.2.3 Workload Analysis.
4.2.3.
1*
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The FIU shall provide and maintain a records management system (RMS) that includes the
following:
(1) Means of evaluating workload analysis
(2) Resources
(3) Productivity of personnel
(4) Accounting of time and expenses
4.
2
.3.2
The FIU shall implement and utilize forms and records that aid in the collection of
information and document the unit’s compliance with written policies and procedures.
4.3
Management Systems
.
4.3.1 Budget.
4.3.1.1
The FIU shall have a budgetary system that supports the goals, objectives, and outcomes of
the unit in accordance with accepted accounting practices.
4.3.1. 4.3.2
2
The FIU shall have written policies and procedures detailing a system of accounts for
financial administration to include records of funds received and expenditures.
4.3.1.3
Policies and procedures shall be implemented for the selection of vendors and purchasing of
services, equipment, and supplies.
Strategy Planning.
The FIU shall establish procedures for the review of the goals, objectives, and
effectiveness of the unit at pre-defined intervals.
4.3.3 Quality Assurance—Management and Internal Reviews.
4.3.3.1 *
The FIU shall have a policy for the review of guiding documents and management
systems.
4.3.3.2
The FIU shall have a policy for the maintenance of documented corrective actions and
preventative measures.
Much of this section deals with private business practices. This seems to be an over-reach of NFPA.
As licensed companies, organizations, or agencies the users of this document are already subject to
40 of 273 1/6/2022, 11:23 AM

much of these requirements and guidelines.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
41 of 273 1/6/2022, 11:23 AM

Chapter 4 Organization, Process, and Management Systems

4.1.1.1.1
4.1.1.1.2
graphic form.
4.1.1.2.1
4.1.1.2.2
4.1.1.3 * Ethical Principles.
4.1.1.3.1
4.1.1.3.2
conflicts.
4.1.1.3.3
The FIU shall have policies and procedures identifying the management of information
obtained or created through investigation activities to ensure confidentiality.
4.1.1.3.4
4.1.2.1
The FIU shall have written policies and procedures for personnel, administration, management,
records retention, and standardized practices and methods utilized by the unit.
4.1.2.2
4.1.3 Quality Manual.
42 of 273 1/6/2022, 11:23 AM


4.2.1.1
4.2.1.2
4.2.1.3 *
4.2.1.4 Health and Safety.
4.2.1.4.1
The FIU shall have a written policy detailing the physical performance and medical screening
required to identify individuals as fit for duty at predefined intervals.
4.2.1.4.2
employees.
4.2.1.4.3
The FIU shall have documented procedures for the maintenance of employee health records.
4.2.1.5.1
The FIU shall have documented procedures to ensure that outsourced subject matter experts
are competent and comply with relevant requirements.
4.2.1.5.2
4.2.3.1 *
following:
(2) Resources
4.2.3.2
The FIU shall implement and utilize forms and records that aid in the collection of information
and document the unit’s compliance with written policies and procedures.
4.3 Management Systems.
4.3.1 Budget.
43 of 273 1/6/2022, 11:23 AM

4.3.1.1
The FIU shall have a budgetary system that supports the goals, objectives, and outcomes of
the unit in accordance with accepted accounting practices.
4.3.1.2
The FIU shall have written policies and procedures detailing a system of accounts for financial
administration to include records of funds received and expenditures.
4.3.1.3
4.3.2 Strategy Planning.
The FIU shall establish procedures for the review of the goals, objectives, and effectiveness of
the unit at pre-defined intervals.
4.3.3.1 *
The FIU shall have a policy for the review of guiding documents and management systems.
4.3.3.2
This entire section is an unjustified and systematic bureacratic micromanagement and overregulation
of business practices. There is no viable reason for requiring every single fire investigation unit
throughout the United States and Canada to follow these rules. The committee should realize that this
section could easily be construed as being a hamfisted attempt by 1321 committee members to
micromanage the business practices of fire investigation units that compete with their own.
Submitter Full Name: James Coté

Organization: Coté Marine LLC
Street Address:
City:
State:
Zip:
Submittal Date: Fri Dec 24 10:20:08 EST 2021
Committee: FIC-AAA
44 of 273 1/6/2022, 11:23 AM

Chapter 4 Organization, Process, and Management Systems - REMOVE CHAPTER 4 - I'M

FROM THE PRIVATE SECTOR, THIS DOCUMENT SHOULD NOT BE DICTATING HOW
PRIVATE SECTOR COMPANIES ORGANIZE/OPERATE THEIR BUSINESS.
4.1.1.1.1
4.1.1.1.2
graphic form.
4.1.1.2.1
4.1.1.2.2
4.1.1.3.1
4.1.1.3.2
conflicts.
4.1.1.3.3
or created through investigation activities to ensure confidentiality.
4.1.1.3.4
4.1.2.1
4.1.2.2
45 of 273 1/6/2022, 11:23 AM


4.2.1.1
4.2.1.2
4.2.1.3*
4.2.1.4 Health and Safety.
4.2.1.4.1
The FIU shall have a written policy detailing the physical performance and medical screening
required to identify individuals as fit for duty at predefined intervals.
4.2.1.4.2
employees.
4.2.1.4.3
4.2.1.5.1
4.2.1.5.2
4.2.3.1*
following:
(2) Resources
4.2.3.2
The FIU shall implement and utilize forms and records that aid in the collection of information
and document the unit’s compliance with written policies and procedures.
46 of 273 1/6/2022, 11:23 AM


4.3.1 Budget.
4.3.1.1
The FIU shall have a budgetary system that supports the goals, objectives, and outcomes of the
unit in accordance with accepted accounting practices.
4.3.1.2
The FIU shall have written policies and procedures detailing a system of accounts for financial
administration to include records of funds received and expenditures.
4.3.1.3
4.3.2 Strategy Planning.
The FIU shall establish procedures for the review of the goals, objectives, and effectiveness of
the unit at pre-defined intervals.
4.3.3.1*
The FIU shall have a policy for the review of guiding documents and management systems.
4.3.3.2
This proposed national standard is over-reaching into private sector company business
organization/operations. Is there really a problem on how companies/departments organize/operate
their investigation units?! Dictating how companies/departments organize/operate also opens them up
for legal action if each item in the proposal are not met. The ASTM standards and NFPA 921 already
address what is needed.
Submitter Full Name: Dennis Kerr

Organization: Kerr Fire Investigations Inc
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
47 of 273 1/6/2022, 11:23 AM


Revise the title to read:
Chapter 4 Organiza�on, Process, and Management System s Requirements
Insert the following text before Sec�on 4.1
The FIU shall establish, implement, and maintain a management system appropriate to the scope
of its ac�vi�es. The FIU shall document its policies, systems, programs, procedures, guidelines, and
instruc�ons to the extent necessary to assure the quality of fire inves�ga�ons. The system’s
documenta�on shall be communicated to, understood by, available to, and implemented by the
appropriate personnel.
The FIU shall perform and document a management review annually that assesses performance
against all requirements of this standard.
The FIU shall have wri�en policies and procedures for all personnel, administra�on,
management, records reten�on, and standardized prac�ces and methods u�lized by the
unit.
...
The title of the section needs to be a concise title that is descriptive of the contents of the section.
The suggested revision reflects the title definition in most accreditation documents. The added text
provides an overview of the requirements for the management system. It calls out the needed
elements of the system. The last sentence of the addition is moved from 4.1.2.1 as it is a high-level
requirement more consistent with this location in the text.
Submitter Full
Philip Crombie
Name:
Organization:
Affiliation:
Subcommittee
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
48 of 273 1/6/2022, 11:23 AM

Public Input No. 210-NFPA 1321-2022 [ New Section after 4.1.1.1.1 ]

Revise Sec�on 4.1.1.1, 4.1.1.2, 4.1.1.3 and related annex material as follows:
4.1.1.1 Organiza�onal Structure.
4.1.1.1.1
Wri�en policies that establish the legal basis for the opera�on and compliance with the
AHJ shall be maintained by the FIU.
4.1.1.1.2
The FIU shall maintain an organiza�onal chart of supervision and accountability outlined
in graphic form.
4.1.
4.1.1.2.1
The FIU shall have wri�en protocols detailing services the unit will provide.
4.1.1.2.2
The FIU shall document their commitment to allocate personnel, support, and resources
to uphold the mission statement or scope of work.
The FIU shall maintain wri�en policies that establish the following:
- Legal basis for the opera�on of the FIU
- Services that the FIU will provide
- When, where, and how the FIU services will be provided
- When and how to request addi�onal resources form outside en��es
- Basic organiza�onal structure
- Func�ons that FIU members are expected to perform
- Mission statement
- Code of ethics
- Organiza�onal values
- Commitment to provide adequate personnel and support to conduct the organiza�onal
mission.
- Commitment to fund and support the professional development of personnel
- Service delivery objec�ves
49 of 273 1/6/2022, 11:23 AM

The FIU shall evaluate and document its level of service and delivery on an annual basis.
FIUs have criteria for avoiding conflicts of interest, have criteria for
right of entry, protec�ng confiden�ality of informa�on, and requirements for liability
insurance. Each of these issues shall be addressed in the organiza�on’s wri�en policies.
4.1.1.2* Mission Statement or Scope of Work.

4.1.1.2.1 The FIU shall develop a mission statement summarizing its aims and goals, to which each
member of the FIU can subscribe.
A.4.1.1.2 Mission Statement.

Properly cra�ed mission statements incorporate all of the following:
(1) Serve as filters to separate what is important from what is not
(2) Clearly state which markets will be served and how
(3) Communicate a sense of intended direc�on to the en�re organiza�on
4.1.1.3 Scope of Work

4.1.1. 2 . 3 .1
The FIU shall have wri�en protocols detailing services the unit will provide.
4.1.1. 2 3 .2
The FIU shall document their its commitment to allocate personnel, support, and resources to uphold
the mission statement or and scope of work.
.
The existing organizational policy requirements is too narrow. The provided list of policies includes the
ones in the existing text and adds other essential policies.
The existing text conflates mission with scope of work. These are two different concepts that should
exist individually. Their conflation is confusing and reduces the focus on each concept. A mission
statement is a formal summary of the purpose, values and goals of a company, organization, or
individual. The scope of work is the activities which FIUs provide.
There is a need for evaluating the service provided on an annual basis.
Submitter Full
Philip Crombie
Name:
Organization:
Affiliation:
Subcommittee
Street Address:
City:
State:
Zip:
50 of 273 1/6/2022, 11:23 AM


Committee: FIC-AAA
51 of 273 1/6/2022, 11:23 AM

Public Input No. 103-NFPA 1321-2021 [ Section No. 4.1.1.1.1 ]
4.1.1.1.1
Written policies that establish the legal basis for the operation of the FIU and compliance with
the AHJ shall applicable federal, state, and local law shall be maintained by the FIU.
While the term "AHJ" may be correct, many FIUs consider themselves to be the AHJ and this may lead
to some confusion. The proposed change would clarify this section, requiring FIUs to document their
legal authority to provide the services they offer and document their compliance with the laws that
govern them.

Organization: Donan
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
52 of 273 1/6/2022, 11:23 AM

4.1.1.1.1
shall should be maintained by the FIU.
legality varies

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
53 of 273 1/6/2022, 11:23 AM

4.1.1.1.1
shall be maintained by the FIU. Documenta�on will be maintained describing the legal authority
under which the FIU operates.
The second part of the sentence is confusing. If the intent of "and compliance with the AHJ" is to direct
members to stay with the described legal boundaries, try "The FIU and its members will comply with
and not exceed the parameters of the FIU’s legal authority."

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
54 of 273 1/6/2022, 11:23 AM

4.1.1.1.2
The FIU shall maintain an organizational chart chain of supervision and accountability outlined
in graphic form written or graph form .
To narrow of a stipulation

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
55 of 273 1/6/2022, 11:23 AM

4.1.1.1.2
The FIU shall maintain FIU should maintain an organizational chart of supervision and
accountability outlined in graphic form.
Organizations with small numbers would be producing documents for the sake of producing a
document with no benefit other than to comply with the standard.
Submitter Full Name: John Schaefer

Organization: Nicholasville Fire Department
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
56 of 273 1/6/2022, 11:23 AM

4.1.1.1.2
graphic form .
This is getting into directing business line operations rather than just having a standard that you should
have an established and outlined management flow.

Affiliation: Private Fire Investigation
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
57 of 273 1/6/2022, 11:23 AM

4.1.1.2.2
Suggested changes 4.1.1.2.2 The FIU shall document the personnel, support, and resources necessary
to uphold the mission statement or scope of work.
Add: 4.1.1.2.2.1 The parent organiza�on or member organiza�ons of an FIU shall document their
commitment to allocate personnel, support, and resources to uphold the mission statement or scope of
work of the FIU .
Context:
What can the FIU really do about a commitment to personnel and resources without commitment from
the parent organization or member organizations of a multi organization unit? It would seem more
appropriate to break this into two categories.
The FIU should have written protocols of the number of personnel, support, and resources to uphold
the mission statement or scope of work. The parent organization, or member organizations of the FIU
shall document their commitment to allocate the necessary support and resources for the FIU to fulfil
the mission statement or scope of work of the FIU.
Submitter Full Name: Laurie Christensen

Organization: Harris County Fire Marshal’s O
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
58 of 273 1/6/2022, 11:23 AM

Public Input No. 68-NFPA 1321-2021 [ New Section after 4.1.1.3 ]

Policies and procedures regarding ethical practices for the FIU may be established and
maintained at the agency or organization level under another department, division or office
responsible for personnel policies within the organization.
Some organizations or agencies have departments or divisions responsible for establishing and
managing all personnel policies dealing with ethical practices. Establishing policies and procedures
specific to an FIU when higher level policies or procedures within the organization address the issues
is a duplication of effort and promotes inefficiency and ineffectiveness of FIU resources.

Organization: Chelan County Fire Marshal's Office
Affiliation: N/A
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
59 of 273 1/6/2022, 11:23 AM

Public Input No. 232-NFPA 1321-2022 [ Section No. 4.1.1.3 ]

4.1.1.3.1
4.1.1.3.2
conflicts.
4.1.1.3.3
4.1.1.3.4
While Ethical considerations are a must, I believe that this should fall under the guidelines and
responsibility of the parent organization, not a specific unit or division of the entire organization. Too
much is left to chance when a policy is in effect for one area and a different policy is in effect for the
remainder of the organization.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
60 of 273 1/6/2022, 11:23 AM

4.1.1.3.1
The FIU shall have policies addressing integrity, accountability, independence and ,
impartiality, respect, professional commitment, and professional conduct.
"and" twice in a sentence; removal of the word professional...under an accredited body, having a policy
is deemed professional.

Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
61 of 273 1/6/2022, 11:23 AM

4.1.1.3.1
respect, professional commitment, and professional conduct. Fire Inves�ga�on Units may u�lize
exis�ng organiza�onal ethics statements, policies, procedures, or contracts when those items meet or
exceed the requirements of 4.1.1.3.1 and apply to all members of the fire inves�ga�on unit.
If, by contractual obligation, FIU members have already signed ethic statements, this requirement is
redundant. Additionally, it may be problematic to have separate ethics statements in an organization
where fire investigators are not full-time and assigned to a standalone unit. In my organization, all of
my investigators are either sworn operational responders or members of the Fire and Life Safety
Division and, in both cases, have signed ethics statements upon initial hire.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
62 of 273 1/6/2022, 11:23 AM

4.1.1.3.1
The FIU shall , or its parent organization, shall have policies addressing integrity,
accountability, independence and impartiality, respect, professional commitment, and
professional conduct.

Public Input No. 42-NFPA 1321-2021 [New Section after 1.1.1]

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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4.1.1.3.1
The FIU. or its parent organization, shall have policies addressing integrity, accountability,
independence and impartiality, respect, professional commitment, and professional conduct.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
64 of 273 1/6/2022, 11:23 AM

4.1.1.3.2
The FIU shall have policies regarding conflicts of interest (definition) and management of
identified conflicts.
Need a definition for "conflict of interest"...absent another entity with jurisdiction, who would a public
agency turn the investigation over to work.

Affiliation: Division of Investigative and Forensic Services. Florida
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
65 of 273 1/6/2022, 11:23 AM

4.1.1.3.2
The FIU, or its parent organization, shall have policies regarding conflicts of interest and
management of identified conflicts.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
66 of 273 1/6/2022, 11:23 AM

4.1.1.3.3
The storage and maintanance of records and information is not really an ethics issue and is more of a
management policies and procedures issue. Additionally, while some information received or
developed by an FIU may be confidential, there is also a lot of information developed that is not and
would be subject to public records requests if maintained by a public sector agency. This does not
seem to be addressed.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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4.1.1.3.3
or created through investigation activities to ensure confidentiality the information is retained
securely and only released in accordance with existing policies and procedures or in
accordance with legal mandates .
I do not believe this section is really an ethics issue per se and the entire section should be moved to
the policies and procedures area. Additionally, I do not believe that confidentiality is the the most
significant aspect of securely maintaining records as an FIU might be subject to public records laws
that would govern the release of file information. The records might also be subject to release under
other laws or legal mandates. Confidentiality may play some role with sensitive information or as it
relates to work for hire but this section as written does not seem to account for any exceptions that
might come into play.

Public Input No. 228-NFPA The original submission calls for total deletion of the section. The
1321-2022 [Section No. current submission provides alternative language but still argues
4.1.1.3.3] that the paragraph is misplaced.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
68 of 273 1/6/2022, 11:23 AM

4.1.1.3.3
The FIU shall , or its parent organization, shall have policies and procedures identifying the
management of information obtained or created through investigation activities to ensure
confidentiality.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
69 of 273 1/6/2022, 11:23 AM

4.1.1.3.4
The FIU shall have written policies identifying the procedures for the handling of ethics
complaints, to include receiving, recording, evaluating, validating, and resolving the complaint.
Even though this is under the Ethics section, it helps to clarify that the policy should be for ethics
complaints and not just complaints in general.

Organization: Donan
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
70 of 273 1/6/2022, 11:23 AM

4.1.1.3.4
The FIU, or its parent organization, shall have written policies identifying the procedures for the
handling of complaints, to include receiving, recording, evaluating, validating, and resolving the
complaint.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
71 of 273 1/6/2022, 11:23 AM


Policies and procedures regarding the FIU may be established and maintained at the agency or
organization level under another department, division or office responsible for personnel policies
within the organization.
Some organizations or agencies have departments or divisions responsible for establishing and
managing all personnel policies. Establishing policies and procedures specific to an FIU when higher
level policies or procedures within the organization address the issues is a duplication of effort and
promotes inefficiency and ineffectiveness of FIU resources.

Affiliation: N/A
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
72 of 273 1/6/2022, 11:23 AM

Sections 4.1.2, 4.1.3

4.1.2.1
4.1.2.2
Policies and Procedures is a non-parallel construction with respect to the other headers in this section.
There are policies and procedures in all these third level sections, so this is not needed or appropriate.
4.1.2.1 was moved by another proposal. The quality manual is included in another proposal to that
describes the QAP program, so it makes more sense there. 4.1.2.2 requirements are located in
specific sections where they apply, and this is also detailed in another proposal.
Submitter Full
Philip Crombie
Name:
Organization:
Affiliation:
Subcommittee
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
73 of 273 1/6/2022, 11:23 AM

4.1.2.2
Each policy or procedure shall should include instructions for the safe performance of tasks,
to restrictive

Street Address:
City:
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Committee: FIC-AAA
74 of 273 1/6/2022, 11:23 AM


The FIU shall should have a written quality manual detailing how the unit complies with the
to complex to stipulate

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
75 of 273 1/6/2022, 11:23 AM


removed
This oversteps the boundaries of sovereign business / commerce .

Street Address:
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Committee: FIC-AAA
76 of 273 1/6/2022, 11:23 AM


I don't believe that a Quality Manual is necessary for the FIU to be successful. It they have proper
SOPs, which are mandated within this standard, that should suffice to make the FIU effective. The
standards created are for the "minimum standards", I believe a QM is something more advanced that
is not necessary to be effective.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
77 of 273 1/6/2022, 11:23 AM

4.2.1.1
The policy would not apply to some public sector departments. Some agencies u�lize their fire inspectors
to conduct non-criminal origin and cause inves�ga�ons. The sec�ons within a public safety government
may suggest policies and procedures for hiring though the responsibility lies with Human Resources.
Either eliminate or change the wording to eliminate confusion

Street Address:
City:
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Committee: FIC-AAA
78 of 273 1/6/2022, 11:23 AM

4.2.1.1
The FIU, or its parent organization, shall have policies and procedures for the hiring and
placement of personnel to operate in accordance with their defined mission or scope of work.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
79 of 273 1/6/2022, 11:23 AM

4.2.1.1
The FIU, or its parent organization, shall have policies and procedures for the hiring and
placement of personnel to operate in accordance with their defined mission or scope of work.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
80 of 273 1/6/2022, 11:23 AM

4.2.1.2
Directing business line operations.

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Committee: FIC-AAA
81 of 273 1/6/2022, 11:23 AM

4.2.1.2
The FIU, or parent organization, shall maintain written job descriptions.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
82 of 273 1/6/2022, 11:23 AM

4.2.1.4.1
The FIU, or parent organization, shall have a written policy detailing the physical performance
and medical screening required to identify individuals as fit for duty at predefined intervals.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
83 of 273 1/6/2022, 11:23 AM

4.2.1.4.2
The FIU, or parent organization, shall have policies in place to account for the recurrent safety
awareness training of employees.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
84 of 273 1/6/2022, 11:23 AM

4.2.1.4.3
The FIU shall have documented procedures for the maintenance of employee health records in
accordance with HIPAA .
Gives further structure to the protection of medical records.
Submitter Full Name: David Tucker

Organization: HCFR
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
85 of 273 1/6/2022, 11:23 AM

4.2.1.4.3
(HIPPA)
Is there a legal justification for this specifically? Some jurisdictions may not to be able to comply with
this from a legal and ethical perspective.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
86 of 273 1/6/2022, 11:23 AM

4.2.1.4.3
The FIU, or its parent organization, shall have documented procedures for the maintenance of
employee health records.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
87 of 273 1/6/2022, 11:23 AM


Revise sec�ons as follows:
4.2.1.5 Technical Procedure ( Contrac�ng and Coopera�on Procedures ).
4.2.1.5.1
The FIU shall have documented procedures to ensure that outsourced subject ma�er
experts are competent and comply with relevant requirements.
4.2.1.5.2
The FIU shall have policies regarding coopera�ve agreements and coordina�on of mul�unit
inves�ga�ons.
4.2.1.5.3
The FIU shall have documented procedures for selec�on of vendors and purchasing of supplies,
equipment, and services that assure these meet the requirements of inves�ga�ons and the FIU.
Contracting and Technical Procedures are vastly different and should not be combined. The technical
procedures are not actually present in the current draft and are the subject of another proposal. A
requirement for procurement of materials, equipment, and services is added to complete the scope of
the section. Cooperative agreements with other FIUs are essential for quality investigations when the
size of the event is large or multiple events arise. 4.2.1.5.3. is text that the draft inserted in the budget
section that is more appropriate here.
Submitter Full
Philip Crombie
Name:
Organization:
Affiliation:
Subcommittee
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
88 of 273 1/6/2022, 11:23 AM

4.2.1.5.1
Not all FIU use outsourced subject matter experts. With my organization it would be the rare occasion
if we were to use anything outsourced other than another government entity.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
89 of 273 1/6/2022, 11:23 AM


Revise the sec�on as follows:
4.2.3.1*
The FIU shall provide and maintain a records management system (RMS) that includes
the following:
(1) Means of evalua�ng workload analysis
(2) Resources
(3) Produc�vity of personnel
(4) Accoun�ng of �me and expenses
The FIU shall develop and maintain a Management Informa�on System (MIS) to support
the management of the FIU by providing the leaders with data that indicate the
effec�veness of the organiza�on in its programs and procedures.
The MIS shall provide a means of measuring performance outcomes and trends for each
the following:
-Ac�ve cases, closed cases, and �mes to case specific milestones
-Resource Evalua�on
-Benchmarking
-Time accoun�ng and produc�vity of personnel
Workload analyses shall be carried out at least annually and shall be included in the annual
documenta�on for the FIU.
The draft focuses on the data to be collected, but even there does it in very broad terms. The new text
focuses on the analyses that the collected data needs to support, and as such focuses on the analysis
and not just the data. Further, the existing text provides no requirement to carry out and report on
workload analyses. The terminology of RMS does not recognize the key role of workload analysis in
the management of the FIU, the use of the term MIS has that focus.
Submitter Full
Philip Crombie
Name:
Organization:
90 of 273 1/6/2022, 11:23 AM


Affiliation:
Subcommittee
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
91 of 273 1/6/2022, 11:23 AM

4.2.3.1*
following:
(2) Resources
(5) Means of storing, searching, viewing, and securely sharing FIU work products
Adds a basic component of an effective RMS.

Organization: Donan
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
92 of 273 1/6/2022, 11:23 AM

4.2.3.1*
following:
(2) Resources
Does this RMS and desired outcomes listed above already exist? Our current RMS vendor does
not have the capability of tracking the referenced items.
Does this RMS and desired outcomes listed above already exist? Our current RMS vendor does not
have the capability of tracking the referenced items.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
93 of 273 1/6/2022, 11:23 AM

4.2.3.1*
The FIU, or its parent organization, shall provide and maintain a records management system
(RMS) that includes the following:
(2) Resources


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
94 of 273 1/6/2022, 11:23 AM


Revise sec�ons as follows:
4.3. 1 Budget.
4.3.1. 1
The FIU shall have a budgetary system that supports the goals, objec�ves, and
outcomes of the unit in accordance with accepted accoun�ng prac�ces.
4.3.2
The FIU shall have wri�en policies and procedures detailing a system of accounts for
financial administra�on to include records of funds received and expenditures.
4.3.1.3
Policies and procedures shall be implemented for the selec�on of vendors and
purchasing of services, equipment, and supplies.
4.4 Strategic Planning
The FIU shall establish procedures for the review of the goals, objec�ves, and
effec�veness of the unit at pre-defined intervals.
The FIU shall develop a long-range strategic plan that shall include goals, objec�ves, and
ac�on plans for the period covered by the plan. The strategic plan shall be reviewed and
updated periodically.
*A.4.4 A three-year dura�on for the long-range strategic plan with annual upda�ng has
been found to be effec�ve.
Management Systems was deleted as subheading to avoid duplication. Budgeting and Strategic
Planning should be discussed in separate sections. Vendors was covered in another proposal, so it
has been deleted here. The new text is more directly focused on developing and updating a strategic
plan rather than merely having procedures for developing a long-range plan. FIUs need more than
procedures, they need the long-range plan implemented and maintained.
Submitter Full
Philip Crombie
Name:
Organization:
95 of 273 1/6/2022, 11:23 AM


Affiliation:
Subcommittee
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
96 of 273 1/6/2022, 11:23 AM

4.3.1.1
The FIU, or its parent organization, shall have a budgetary system that supports the goals,
objectives, and outcomes of the unit in accordance with accepted accounting practices.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
97 of 273 1/6/2022, 11:23 AM

4.3.1.2
The FIU, or its parent organziation, shall have written policies and procedures detailing a
system of accounts for financial administration to include records of funds received and
expenditures.


Street Address:
City:
State:
Zip:
Committee: FIC-AAA
98 of 273 1/6/2022, 11:23 AM

4.3.2 Strategy Planning Strategic Planning .

The FIU shall establish procedures for the review of the mission, goals, objectives, and
effectiveness of the unit at pre-defined intervals.
Changes title to the more common term. Adds an evaluation of the mission of the organization and if
the services provided are still necessary or effectively being accomplished.

Organization: Donan
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
99 of 273 1/6/2022, 11:23 AM


Revise the Sec�on as follows:
4.3.3 Quality Assurance—Management and Internal Reviews. Quality Assurance Program (QAP)
Requirements
4.3.3.1 The FIU shall establish, implement, and maintain a QAP that documents policies and procedures
that govern how the FIU operates.
4.3.3.2* The QAP shall include a Quality Manual, quality procedures, technical procedures, forms, and
records.
A.4.3.2 Goult R., Quality System Documenta�on, in Peach, R., (Ed.), The ISO 9000 Handbook , Irwin,
Chicago, 1997, 315.
4.3.3.1*
The FIU shall have a policy for the review of guiding documents and management
systems.
4.3.3.2
The FIU shall have a policy for the maintenance of documented correc�ve ac�ons and
preventa�ve measures.
4.3.3 Quality Manual
The Quality Manual addresses how the FIU complies with each requirement of this
standard and shall include an organiza�on’s mission statement, commitment to and
policies to ensure impar�ality and independence, confiden�ality, organiza�onal structure,
and an outline of the organiza�on’s goals and responsibili�es to each group of
stakeholders. The Quality Manual also addresses the Organiza�on’s commitment to
professional prac�ce and complying with the manual, means of familiarizing the staff
with the QAP and defines the responsibili�es and authority of QAP manager.
4.3.3.4 Quality Assurance Principles and Strategies
The FIU shall develop SOPs to include:
4.3.3.4.1 Document Control Procedures that address:
• Unique iden�fica�on of each document.
• Controlling all documents (internal and external) rela�ng to the QAP.
• Approving and issuing documents (including maintaining a master list) before use.
• Periodically reviewing and upda�ng quality documents.
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• Iden�fying any changes from previous version.
• Ensuring that the current documents are being used and unintended uses of obsolete
documents are prevented.
4.3.3.4.2 Records Control Procedures that address:
• What records are within the FIU’s contractual and legal requirements, including
quality records and case-specific records.
• Storage, protec�on, reten�on, and disposi�on of hard-copy and electronic records.
4.3.3.4.3 Internal Audit Procedures that address:
• Conduc�ng internal audits and implemen�ng findings.
• The scope of the audit, areas that should be audited, and frequency of audits.
• Documenta�on of audits.
• Training of auditors.
4.3.3.4.4 Complaint Procedures that address:
• Receiving, recording, evalua�ng, valida�ng, and resolving both internal and external
complaints.
• Communica�ng resolu�on to interested stakeholders.
4.3.3.4.5 Non-conforming work Procedures that address:
• How to iden�fy non-conforming work.
• Responsibili�es and authori�es for the management of non-conforming work
• Response to non-conforming work based on frequency and impact iden�fied by the
FIU.
4.3.3.4.6 Correc�ve ac�ons procedures that address:
Standard for the Organiza�on and Opera�on of Fire Inves�ga�on Units
• Taking correc�ve ac�on when non-conforming work or faults in the QAP have been
iden�fied.
• Performing a root cause analysis on the non-conforming work to iden�fy areas where
this may occur and implement correc�ve ac�ons.
• Reviewing the effec�veness of the correc�ve ac�on.
• Retaining records of the correc�ve ac�ons, root cause, and ac�ons taken.
4.3.3.4.7 Subcontrac�ng Services
• The FIU shall be responsible for the quality of the services provided by
subcontractors
• The FIU shall have wri�en requirements for the qualifica�ons of subcontractors.
101 of 273 1/6/2022, 11:23 AM

• The FIU shall maintain records of qualifica�ons of subcontractors that were used.
• The FIU shall maintain records of what services were provided by subcontractors for
each inves�ga�on.
4.2.3.3* Technical Procedures: Instruc�ons for carrying out specific tasks (May be separate from
the main body of the QA manual).
The FIU shall have procedures for standardized prac�ces and methods used by the unit (SOPs /
SOGs). These shall include the applica�on of the scien�fic method to the following tasks:
(1) scene processing and documenta�on
(2) collec�ng, processing, and preserving evidence
(3) interviewing and interroga�on
(4) origin determina�on to include arc mapping, fire pa�erns, fire dynamics, and witness
informa�on
(5) cause determina�on to include iden�fica�on of first fuel(s), heat source(s), and oxidizer, and
(6) report wri�ng.
Each policy shall have instruc�ons for performing the task safely, documenta�on, analysis and
interpreta�on, and repor�ng. SOPs and SOGs shall be based on published industry methods and
peer reviewed journals.
*A.4.2.3.3 NFPA 921 and NFPA 1033 include examples of industry methods. Other standards
include ASTM E678, Standard Prac�ce for Evalua�on of Scien�fic or Technical Data
ASTM E860, Standard Prac�ce for Examining And Preparing Items That Are Or May Become
Involved In Criminal or Civil Li�ga�on, ASTM E1188, Standard Prac�ce for Collec�on and
Preserva�on of Informa�on and Physical Items by a Technical Inves�gator, and ASTM E1459,
Standard Guide for Physical Evidence Labeling and Related Documenta�on
4.2.3.4 Quality Records and Forms
The FIU shall maintain and use forms and records that facilitate the collec�on and
preserva�on of informa�on and document the FIU’s compliance with its wri�en
procedures.
4.2.4 Audit.
The FIU shall develop a policy regarding retrospec�ve reviews of case files and reports to ensure that
the expressed policy is QAP policies and procedures have been implemented.
The QAP is the core institutional system to assure high quality fire investigations. It is key to the
formulation and maintenance of the FIU such that it supports and demands quality fire investigations.
102 of 273 1/6/2022, 11:23 AM

This text defines the elements of the system and how it is implemented and maintained. The technical
procedures used in fire and explosion investigations are key and essential. This was effectively
missing in the draft standard.
Submitter Full
Philip Crombie
Name:
Organization:
Affiliation:
Subcommittee
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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Chapter 5 Resources, Facilities, and Equipment

5.1* Resources.
5.1.1
The FIU shall have written policies for when and how to request additional resources anytime
the needs of the investigation exceed the available manpower and expertise.
5.1.2*
The FIU shall not operate outside its area of expertise.
5.1.3
The FIU shall have a written policy to identify the need to involve other resources and entities.
5.1.4*
The FIU written policy for evaluating the need for additional resources shall be based on when
an event exceeds the FIU’s capabilities or resources.
5.2 Indoor/Outdoor Facilities.
5.2.1*
The FIU shall have a written policy for the collection, storage, security, and evaluation of all
evidence.
5.2.2 Lighting.
5.2.2.1
In evidence storage areas, lighting systems shall have installed and maintained light fixtures.
5.2.2.2
Lighting systems in evidence storage areas shall not emit hot particles upon failure unless a
shield is in place.
5.2.3
Self-powered materials-handling equipment that rely on fuel gas, batteries, or gas or petroleum
products for operation shall be all should consider all of the following:
(1) Maintained without fuel or gas leaks
(2) Separated from evidence storage Consideration shall be exercised to minimize risk of
evidence contamination when storing or utilizing fuel powered equipment.
(3) Maintained in accordance with the manufacturer’s instructions
5.2.4
Test chambers for burn tests shall be inspected and approved by the AHJ.
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5.2.5
Hazardous materials used for testing or maintenance purposes shall be stored in an approved
manner.
5.2.6
Hazardous materials used for testing or maintenance purposes shall be separated from
evidence storage in an approved manner .
5.2.7 *
Evidence shall be stored in noncombustible storage areas that are outside of any defined flood
plains or inland wetland areas.
5.2.8
Written policies, procedures, and controls to prevent and limit unauthorized access to
evidence shall be established by the FIU.
5.3 Equipment.
FIUs shall have the types and quantity of equipment needed to perform their duties.
Gas and or LP-powered handling equipment, such as a Bobcat and fork-lifts are frequently utilized to
move evidence and are stored in the same building as evidence. I think it would be more practical to
say, Care and consideration should be utilized when storing any material handling equipment in the
evidence storage area. "Not Separated" which indicates equipment being stored in a completely
separate area of the building, another building or outside all together. This doesn't seem very feasible
in most cases.
Neil Zierden, Detective
Florida, Bureau of Fire & Arson Investigations
Submitter Full Name: Neil Zierden

Organization: State of Florida
Affiliation: Bureau of Fire & Arson
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
105 of 273 1/6/2022, 11:23 AM

Evidence
Physical Evidence shall be documented, collected, chain of custody attached and documented,
secured, and stored in a manner consistent with NFPA 921:17.
NFPA 921:17 covers evidence

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
106 of 273 1/6/2022, 11:23 AM

Revise �tles as follows:
Chapter 5 Outside Resources, Facili�es, and Equipment
5.1* Outside Resources
Resources is a broad term that is inclusive of the facilities and equipment and in house staff. The intent
in this section is clearly geared to resources not resident in the FIU.
Submitter Full
Philip Crombie
Name:
Organization:
NIST OSAC Fire and Explosion investigation
Affiliation:
Subcommittee
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
107 of 273 1/6/2022, 11:23 AM

5.1.1
The FIU shall FIU should have written policies for when and how to request additional
resources anytime the needs of the investigation exceed the available manpower and expertise.
too restrictive

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
108 of 273 1/6/2022, 11:23 AM

5.1.1
The FIU shall have written policies for when and how to request additional resources anytime
the needs of the investigation exceed the available manpower and expertise.
Written policies over and above what is specified in NFPA 921 would be unnecessary for small FIUs
and could be a wasteful use of manpower for a standalone FIU with a single or only a few
investigators.
It would be onerous and burdensome to require every FIU in North America to prepare and store such
documents.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
109 of 273 1/6/2022, 11:23 AM

5.1.2*
Exception: An expert was consulted either in person or telephone offering direction for
continuation.
I think the entire statement of an "expert" is broad and who is determining who is an "expert". An
"expert" in rural situations is sometimes days away. I think this would add other options to those
affected by certain situations. In addition, during times of civil unrest, the possibility of destroyed
evidence may be a consideration. There may not be time to wait for an "expert".
Submitter Full Name: Jason Albers

Organization: Eden Prairie Fire
Street Address:
City:
State:
Zip:
Submittal Date: Tue Sep 14 12:37:36 EDT 2021
Committee: FIC-AAA
110 of 273 1/6/2022, 11:23 AM

5.1.2*
The FIU shall not operate outside its area only operate within the areas of expertise for which
it is qualified .
I can see this becoming an easy target for an opposing attorney. The proposed change says the same
thing, but in a way that makes it less of a target. The original sentence puts the burden of proof to
discredit the claimed area of expertise on the opposing attorney. Instead, the burden of proof should be
on the FIU to justify its competence and qualifications in a specific area of expertise.

Organization: Donan
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
111 of 273 1/6/2022, 11:23 AM

5.1.2*
define expertise?

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
112 of 273 1/6/2022, 11:23 AM

Sections 5.1.2, 5.1.3

5.1.2 *
5.1.3
Sections 5.1.2 and 5.1.3 are redundant in that they repeat the FIU requirement that is stated in 5.1.1.
The statement, as made in 5.1.1, is sufficient to address the policy requirement.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
113 of 273 1/6/2022, 11:23 AM

5.1.3
The FIU shall should have a written policy to identify the need to involve other resources and
entities.
too restrictive

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
114 of 273 1/6/2022, 11:23 AM

5.1.3
Requiring a written policy would be unnecessary for small FIUs and could be a wasteful use of
manpower for a standalone FIU with a single or only a few investigators.
It would be onerous and burdensome to require every FIU in North America to prepare and store such
documents particularly those with good communications between its stakeholders.

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
115 of 273 1/6/2022, 11:23 AM

5.1.4*
The FIU written policy for evaluating the need for additional resources shall should be based
on when an event exceeds the FIU’s capabilities or resources.
too narrow and restrictive

Street Address:
City:
State:
Zip:
Committee: FIC-AAA
116 of 273 1/6/2022, 11:23 AM


Revise the sec�on as follows:
5.2 Indoor/Outdoor Facili�es.
5.2.1*
The FIU shall have a wri�en policy for the collec�on, storage, security, and evalua�on o
all evidence.
5.2.2 Ligh�ng.
5.2.2.1
In evidence storage areas, ligh�ng systems shall have installed and maintained light
fixtures.
5.2.2.2
Ligh�ng systems in evidence storage areas shall not emit hot par�cles upon failure
unless a shield is in place.
5.2.3
Self-powered materials-handling equipment that rely on fuel gas, ba�eries, or petroleum
products for opera�on shall be all of the following:
(1) Maintained without leaks
(2) Separated from evidence storage
(3) Maintained in accordance with the manufacturer’s instruc�ons
5.2.4
5.2.5
Hazardous materials used for tes�ng or maintenance purposes shall be stored in an
approved manner.
5.2.6
Hazardous materials used for tes�ng or maintenance purposes shall be separated from
evidence storage.
5.2.7*
Evidence shall be stored in noncombus�ble storage areas that are outside of any
117 of 273 1/6/2022, 11:23 AM

defined flood plains or inland wetland areas. But nothing on recordkeeping and security?
5.2.8
Wri�en policies, procedures, and controls to prevent and limit unauthorized access to
5.3 Equipment. inadequate
FIUs shall have the types and quan�ty of equipment needed to perform their du�es.
5.2.1 The FIU shall provide (or contract with another en�ty to provide) adequate facili�es and
equipment to achieve its mission including, where applicable:
-Office space
-Evidence storage (including temporary evidence storage)
-Tools and equipment
-Library (to include digital resources)
-Examina�on space
-Document storage (to include digital documents)
-IT infrastructure
-Decontamina�on
-Vehicles
-Building Security
-Access Control
-Inventory System
-Environmental Systems
-Communica�on Systems
-Maintenance
-Fire Protec�on Systems
5.2.2 The evidence storage facility shall be operated and maintained according to ASTM
E1492, Standard Prac�ce for Receiving, Documen�ng, Storing, and Retrieving Evidence
in a Forensic Science Laboratory. Collec�on, labeling, and preserva�on of evidence shall
conform to ASTM E1188, Standard Prac�ce for Collec�on and Preserva�on of
Informa�on and Physical Items by a Technical Inves�gator and ASTM E1459, Standard
Guide for Physical Evidence Labeling and Related Documenta�on.
The coverage of the draft standard includes only evidence facilities. This is a very narrow cut of the
facilities needed for an operational FIU. Within the scope of evidence facilities, the existing text is very
118 of 273 1/6/2022, 11:23 AM

focused on selected aspects, like lighting. A broader and comprehensive view will assist FIUs.
Submitter Full Name: Philip Crombie

Organization:
Affiliation: NIST OSAC Fire and Explosion Investigation
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Committee: FIC-AAA
119 of 273 1/6/2022, 11:23 AM

5.2 Indoor/Outdoor Facilities.

5.2.1 *
evidence.
5.2.2 Lighting.
5.2.2.1
5.2.2.2
shield is in place.
5.2.3
Self-powered materials-handling equipment that rely on fuel gas, batteries, or petroleum
products for operation shall be all of the following:
5.2.4
5.2.5
manner.
5.2.6
evidence storage.
5.2.7 *
5.2.8
Written policies, procedures, and controls to prevent and limit unauthorized access to evidence
shall be established by the FIU.
Evidence collection, handling, and storage is addressed in NFPA 921 and multiple ASTM standards.
120 of 273 1/6/2022, 11:23 AM


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121 of 273 1/6/2022, 11:23 AM

5.2.1*
The FIU shall have a written policy on facilities used for the collection intake , storage,
security processing , and and evaluation of all evidence of evidence .
The original version should be moved to the documentation section. This section should be focused on
facilities and the minimum requirements for those facilities.

Organization: Donan
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122 of 273 1/6/2022, 11:23 AM

5.2.1*
evidence and/or follow the recommendations in NFPA 921 .
While a written policy may have some utility for training and employee discipline for large FIUs, many
small FIUs would have no use for such documentation. Compliance with NFPA 921 should suffice

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123 of 273 1/6/2022, 11:23 AM

Public Input No. 198-NFPA 1321-2022 [ Sections
5.2.2, 5.2.3, 5.2.4, 5.2.5, 5.2.6, 5.2.7 ]
Sections 5.2.2, 5.2.3, 5.2.4, 5.2.5, 5.2.6, 5.2.7

5.2.2 Lighting.
5.2.2.1
5.2.2.2
shield is in place.
5.2.3
5.2.4
5.2.5
manner.
5.2.6
evidence storage.
5.2.7 *
The general purpose of this document should be to provide general guidance on operations and policy
development. While this information may have merit as a recommendation in the annex section, it
should not be a requirement within the core of the document. The parent organization or government
is often responsible for the provision of resources and facilities and these sections are too specific to
be required for a general fire investigation unit.

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124 of 273 1/6/2022, 11:23 AM

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125 of 273 1/6/2022, 11:23 AM

Public Input No. 251-NFPA 1321-2022 [ Sections
5.2.2, 5.2.3, 5.2.4, 5.2.5, 5.2.6, 5.2.7 ]
Sections 5.2.2, 5.2.3, 5.2.4, 5.2.5, 5.2.6, 5.2.7

5.2.2 Lighting.
5.2.2.1
5.2.2.2
shield is in place.
5.2.3
5.2.4
5.2.5
manner.
5.2.6
evidence storage.
5.2.7 *
Sections 5.2.2-5.2.7 need to be deleted as they dictate what actions the FIU must take, rather than
indicating that the FIU shall have a policy addressing these aspects. The blanket statement regarding
a policy is covered in 5.2.1.

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127 of 273 1/6/2022, 11:23 AM

5.2.2.1
Not sure why we are getting this far into the weeds. How does the condition of lighting within a storage
area effect the successfulness of an FIU? What if the storage area had skylights that were used to
provide lights. What if there were no lights but investigators used hand lights and/or battery operated
lights. These could be used if the unit is using an external, long-term storage unit that did not have
lights. If they don't have light fixtures are they now ineffective? I don't believe that this is essential so it
shouldn't be within the standard.


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128 of 273 1/6/2022, 11:23 AM

5.2.2.1
Is the committee requiring lighting in outdoor evidence storage areas or evidence storage areas with
adequate natural lighting?
What business is it of the NFPA to regulate what type of lighting that an individual businesss wishes to
use in its storage facilities? Wouldn't portable lighting be appropriate in some situations?

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129 of 273 1/6/2022, 11:23 AM

5.2.2.2
shield is in place comply with NFPA 70 .
NFPA 70 more that fully covers electrical compliance

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5.2.2.2
Lighting systems in , such as high intensity discharge (HID) lighting, in evidence storage areas
shall not emit hot particles upon failure unless a non-combustible shield is in place. Florescent
light fixtures with open bulbs are an acceptable means of interior lightning in evidence storage
facilities.
As the standard was written, it would seem that the intent was to point out the apparent known hazards
of HID lighting without allowing for an alternative and acceptable source of interior lighting such as
fluorescent lighting. Additionally, if the intent is to cover all forms of interior lighting, such as florescent
lighting, this would impose an unreasonable requirement upon FIU's when the known coverings are
not non-combustible.

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131 of 273 1/6/2022, 11:23 AM

5.2.2.2
shield is in place.
This section does not appear to be within the scope of this document nor does it clearly outline what
the requirement is or how to address it.
Why is this document including a building fire safety/ignition source requirement? It should be
removed. Also, of these light fixtures are allowed by relevant local codes, why would they not be
allowed by this document?
If there is a particular type of fixture or fixtures that is prohibited, state this. Make references to
applicable NFPA Standards

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Affiliation: None
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132 of 273 1/6/2022, 11:23 AM

5.2.2.2
Lighting systems in , if present in evidence storage areas, shall not emit hot particles upon
failure unless a shield is in place.
Not sure why we are getting this far into the weeds. How does the condition of lighting within a storage
area effect the successfulness of an FIU? What if the storage area had skylights that were used to
provide lights. What if there were no lights but investigators used hand lights and/or battery operated
lights. These could be used if the unit is using an external, long-term storage unit that did not have
lights. If they don't have light fixtures are they now ineffective? I don't believe that this is essential so it
shouldn't be within the standard.


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133 of 273 1/6/2022, 11:23 AM

5.2.3
(2) Separated When idle are kept separated from evidence storage
Clears up the separation of equipment

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5.2.3
(2) Separated from evidence storage Self-powered materials-handling equipment shall be
stored in a manner to contain and prevent cross contamination of evidentiary items.
The current standard language does not consider that other evidence items being stored may contain
batteries, fuel gas or petroleum products that must be preserved as evidence. Properly packaged and
preserved evidence provides for an acceptable means of evidence storage among other evidentiary
items, and it does not need to be segregated, such as burned items containing lithium battery packs
when packaged properly.

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135 of 273 1/6/2022, 11:23 AM

5.2.3
(2) Separated from evidence storage by a minimum of 25 ft
The requirement should have a minimum separation distance or method. Without this, the requirement
does not have any effect.

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Affiliation: None
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136 of 273 1/6/2022, 11:23 AM

5.2.4
Test If required by the AHJ, test chambers for burn tests shall be inspected and approved by
the AHJ.
Only if required by ordnance of AHJ authority

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137 of 273 1/6/2022, 11:23 AM

5.2.4
This section is problematic to say the least. There is no definition of a burn cell in this document. Also,
how would the AHJ approve something that is likely not included in the building codes? What about
when sprinklers would be required by the current building codes but were not present in the subject
location? What about instances where materials or building methods I'm the subject location were not
accounted for in the current building codes?
Would the AHJ then be required to testify in a legal proceeding as to how they required changes to a
burn cell?
If the committee wants to regulate this particular item, it should develop a list of requirements for the
installation of a "burn cell" including: construction, location within a building or a safe distance from a
building, protection required, etc. NFPA codes can be referenced.

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Affiliation: None
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138 of 273 1/6/2022, 11:23 AM

5.2.5
Hazardous materials as defined by NFPA 1:60 -71 used for testing or maintenance purposes
shall be stored in an approved manner according to NFPA 1 & 101 ..
needs defining

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139 of 273 1/6/2022, 11:23 AM

5.2.5
manner accordance with the appropriate NFPA Standard(s) .
NFPA Standards should be referenced. Otherwise, this item doesn't do anything more than the
building codes which are already in place and apply and the section is redundant.

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140 of 273 1/6/2022, 11:23 AM

5.2.6
evidence storage in accordance with NFPA 1 & 101 .
corresponds with fire codes

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141 of 273 1/6/2022, 11:23 AM

5.2.6
evidence storage by a minimum of 25 ft .
This section should have a separation distance used or a separation method (i.e., non-combustible
barrier) otherwise it is not an effective requirement.

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Affiliation: None
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142 of 273 1/6/2022, 11:23 AM

5.2.7*
plains or inland wetland areas. accordance with NFPA 1 & 101.
corresponds with fir codes

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143 of 273 1/6/2022, 11:23 AM

5.2.7 *
This section seems to overstep the scope of this document; the appropriate building codes should be
referenced and used.
Why should storage of evidence not be allowed in a building of combustible construction of it is

properly sprinkler protected? Also, what about roof construction that contains combustible materials or
wood framed structures that are covered with drywall? The intent of this section seems to be aimed at
some sort of fire prevention effort, but does not account for a large number of situations or the
presence of sprinkler protection?
Also, what would be the difference in having a combustible building storing largely non-combustible
evidence and a non-combustible building storing large quantities of foam plastics? The end result of a
fire in these two situations could be the same.

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144 of 273 1/6/2022, 11:23 AM

5.2.7 *
I am not against the concept of this section but wonder why we are only talking about flood plains. It
seems like the author of this section had some type of experience related to flooding. If we are going
to "mandate" items like this, why is there not a section about earthquake proofing an evidence storage
area or precluding storage areas in WUI areas. It seems like this "mandate" within the standard is very
geographically specific and dependent. I also don't believe that this section is necessary for an FUI to
be effective.

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145 of 273 1/6/2022, 11:23 AM

5.2.7*
plains or inland wetland areas adequately protected from spoliation by fire, flooding, and the
elements .
This standard is onerous and excessive, As written it would prohibit storing evidence on wooden
shelves, plastic storage containers.and in wood frame buildings. A FIU should be capable of making
good fire protection decisions
Wetlands are not defined nor is consideration given to flooding mitigation measures, such as on raised
structures.

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146 of 273 1/6/2022, 11:23 AM

5.2.8
Written policies, procedures, and controls to prevent and limit unauthorized access to evidence
shall be established by the FIU. The FIU will maintain chain of custody, security, and
quarantine of all evidence in storage.
Stated in a clear manner.

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147 of 273 1/6/2022, 11:23 AM

5.2.8
Written policies Policies , procedures, and controls to prevent and limit unauthorized access to
There is no need for a sole proprietor FIU to keep a written record of how to lock its storage facility.

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148 of 273 1/6/2022, 11:23 AM

5.3 Equipment.
FIUs shall have the types and quantity of equipment needed to perform their duties.
This section is very vague and does not provide any helpful information. It should be eliminated.

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149 of 273 1/6/2022, 11:23 AM

5.3 Systems and Equipment.

FIUs shall have the types and quantity of systems and equipment needed to perform their
duties.
By adding systems to the section, this accounts for building systems, such as lighting, etc..., which I
recommended removing in the sections above.

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150 of 273 1/6/2022, 11:23 AM

Public Input No. 29-NFPA 1321-2021 [ Chapter 6 [Title Only] ]
Health and Safety
Some mention of health should be within the FIU's requirements. It will possibly be mentioned in
NFPA 921's section in the future.

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151 of 273 1/6/2022, 11:23 AM

6.1 General.
The FIU shall have a safety program consistent with NFPA 921:13 .
NFPA 921:13 covers safety

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152 of 273 1/6/2022, 11:23 AM

6.1 General.
The FIU shall have a safety program that meets all federal, state, and local requirements .
This requirement should have some references to other federal state and local requirements which
drive the actual implementation of safety items.

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Affiliation: None
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Committee: FIC-AAA
153 of 273 1/6/2022, 11:23 AM

6.1 General.
The FIU shall have a safety program. For further information regarding the creation,
implementation, and operation of safety programs, please refer to the safety chapter in NFPA
921.
NFPA 921 is the resource for guidance on fire investigation related safety matters. It has been stated
that NFPA 1033 tells you what is required of a fire investigator, NFPA 921 tells you how to do it. NFPA
1321 is telling the FIU what is required but not how to do it. NFPA 921 will provide the "how to".
Further, NFPA 921 is currently open for public input. As chair of the NFPA 921 safety chapter task
group, I am aware that a complete re-write, and expansion, of the safety chapter will be submitted as
public input. If accepted by the committee, the requirements of NFPA 1321 will be fully addressed in
NFPA 921. It is essential that the reader be pointed to a resource that will aid them in meeting the
requirements of NFAP 1321.
Submitter Full Name: Joseph Sesniak

Organization: Forensic Fire Consultants, Ltd
Street Address:
City:
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Submittal Date: Thu Sep 23 15:57:26 EDT 2021
Committee: FIC-AAA
154 of 273 1/6/2022, 11:23 AM

6.1 General.
The FIU shall , or its parent organziation, shall have a safety program.


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155 of 273 1/6/2022, 11:23 AM

Public Input No. 236-NFPA 1321-2022 [ Sections 6.1, 6.2 ]
156 of 273 1/6/2022, 11:23 AM

Sections 6.1, 6.2

Chapter 6 Health and Safety
6.1
General
The FIU
shall have a safety program

or parent organization shall conduct an annual hazard assessment and develop a health and
safety program appropriate for the risks identified or likely to be encountered .
6.2
*
Health and Safety Program
6.2.1
A
The health and safety program shall establish policies
,
and procedures for hazard identification , mitigation, and
reporting.
personal protection
6.2.2
The health and safety
program
policy shall
generate policies for the health and safety of personnel
157 of 273 1/6/2022, 11:23 AM

establish protocols for reporting and documentation of workplace injuries or exposures to

hazardous substances .
6.2.3
The
safety program shall include any local, state, provincial, tribal, or federal
health and safety
regulations in place in the particular jurisdiction

policy shall identify a process for the review or investigation of workplace injuries or exposures
to hazardous substance incidents .
6.2.4
A
The health and safety program shall
describe and specify baseline personal protective equipment (PPE) needed to meet the policy
requirements
incorporate legally mandated regulations applicable to the authority having jurisdiction .
6.2.5
The safety program shall be managed for compliance, including a means to address issues of
noncompliance
Standard Personal Protective Equipment (PPE) necessary to mitigate or protect against the
hazards identified or likely to be encountered shall be identified, and the requirements for use
and maintenance shall be outlined .
6.2.6
The safety program shall contribute to the budget process of the parent agency to ensure
funding for safety requirements
Specialized Personal Protective Equipment necessary to mitigate or protect against hazards

identified on special scenes or events shall be identified and the requirements for use and
maintenance shall be outlined .
6.2.7
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The health and safety program shall
include a regular periodic review of

be managed by competent personnel to ensure compliance with policies and procedures
at no less than on an annual basis

.
6.2.8
The health and safety
program shall have a process for the investigating and reporting of any workplace incidents,
injuries, or illnesses to FIU members.
6.2.9
The information gathered
policies and procedures shall be reviewed on a regular basis and updated accordingly with
consideration given to evolution of governing regulations, updated hazard assessments, and
lessons learned from the
safety program shall be considered and addressed in policy

review and
change
investigation of workplace incidents .
6.2.
10 * A
9
The health and safety program
shall have policies addressing

policies and procedures shall address the following:
•* Baseline medical screening

•* Scene safety and development of a written safety plan
• Respiratory protection
• Control of safety hazards
• Decontamination of personnel, equipment, evidence, vehicles
• PPE
• Vehicle use
•* Exposure reporting
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6.2.11 *
Parent agency policy and regulations shall be considered in the formation of policies for the
FIU.
(1) General Fitness for Duty Requirements
(2) Base Line Medical Examination Requirements
(3) General Health and Welfare
(4) Specialized Equipment Requirements
(5) Personal Protective Equipment Requirements
(6) How and When Equipment is Utilized
(7) Maintenance of Equipment
(8) Training and Refresh Requirements
(9) Inspection and Replacement Procedures
(10) Use of Specialized PPE Policies and Procedures
(11) Scene Safety Assessment Requirements
(12) Hazard Identification
(13) Hazard Control or Mitigation Employed
(14) Decontamination of Personnel, equipment, vehicles, etc.
(15) Exposure Reporting
Additional Proposed Changes
File Name Description Approved

Alternate
Language for
1321_Section_6.1_and_6.2_alternate_language_Schaal_.docx Section 6.1 and
6.2 in clean
format
Current sections 6.1. and 6.2 are not as clear as they should be to encourage an effective health and
safety program. The revised language clarifies the information presented.

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161 of 273 1/6/2022, 11:23 AM

Chapter 6 Health and Safety
6.1 General
The FIU or parent organization shall conduct an annual hazard assessment and
develop a health and safety program appropriate for the risks identified or likely to be
encountered.
6.2 Health and Safety Program
6.2.1
The health and safety program shall establish policies and procedures for hazard
identification, mitigation, and personal protection
6.2.2
The health and safety policy shall establish protocols for reporting and documentation of
workplace injuries or exposures to hazardous substances.
6.2.3
The health and safety policy shall identify a process for the review or investigation of
workplace injuries or exposures to hazardous substance incidents.
6.2.4
The health and safety program shall incorporate legally mandated regulations
applicable to the authority having jurisdiction.
6.2.5
Standard Personal Protective Equipment (PPE) necessary to mitigate or protect against

the hazards identified or likely to be encountered shall be identified, and the
requirements for use and maintenance shall be outlined.
6.2.6
Specialized Personal Protective Equipment necessary to mitigate or protect against

hazards identified on special scenes or events shall be identified and the requirements
for use and maintenance shall be outlined.
6.2.7
The health and safety program shall be managed by competent personnel to ensure
compliance with policies and procedures.
6.2.8
The health and safety policies and procedures shall be reviewed on a regular basis and
updated accordingly with consideration given to evolution of governing regulations,
updated hazard assessments, and lessons learned from the review and investigation of
workplace incidents.
6.2.9
The health and safety program policies and procedures shall address the following:
(1) General Fitness for Duty Requirements

(2) Base Line Medical Examination Requirements
a. General Health and Welfare
b. Specialized Equipment Requirements
(3) Personal Protective Equipment Requirements
a. How and When Equipment is Utilized
b. Maintenance of Equipment
c. Training and Refresh Requirements
d. Inspection and Replacement Procedures
e. Use of Specialized PPE Policies and Procedures
(4) Scene Safety Assessment Requirements
a. Hazard Identification
b. Hazard Control or Mitigation Employed
(5) Decontamination of Personnel, equipment, vehicles, etc.
(6) Exposure Reporting
6.2.11 *
Parent agency policy and regulations shall be considered in the formation of policies for the
FIU.
See public input 61. This will make this section unnecessary if adopted.


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162 of 273 1/6/2022, 11:23 AM

6.3.1
Members of an FIU shall be provided with PPE that is specific to the hazards reasonably
expected at fire and explosion incidents and test burns .
Makes PPE selection specific to the hazard, and adds emphasis on protective ensembles for test
burns.

Organization: Donan
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163 of 273 1/6/2022, 11:23 AM

6.3.2
Members of an FIU shall be trained in the use, care, and decontamination of PPE PPE as
describe in the Investigation Operations section of NFPA 1585 .
Section 7.7 of NFPA 1585 Standard for Exposure and Contamination Control specifies methods fire
investigators should follow to limit exposure and cross contamination when conducting fire
investigations.

Affiliation: N/A
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164 of 273 1/6/2022, 11:23 AM

6.3.3
All PPE shall meet or exceed the requirements set forth in 29 CFR 1910.1020 governmental
regulations and the applicable NFPA standards.
1910.1020 is not the appropriate reference for PPE as it deals with Employee Records (29 CFR §
1910.1020 - Access to employee exposure and medical records.) Having a general statement would
serve the purposes of this document.

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165 of 273 1/6/2022, 11:23 AM

6.3.3
All PPE shall meet or exceed the requirements set forth in 29 CFR 1910.1020 134 and the
applicable NFPA standards.
The currently referenced section (1020) pertains to the access of medical records. 1910.134 is the
respiratory protection standard.
Submitter Full Name: Jeff Pauley

Affiliation: IAAI Health & Safety Committee Chairman
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Committee: FIC-AAA
166 of 273 1/6/2022, 11:23 AM

6.3.3
All PPE shall meet or exceed the requirements set forth in 29 CFR 1910.1020 and the
applicable NFPA standards.
29 CFR 1910.1020 is in reference to Acess to Employee Medical Records. Not sure if this is
correct, I could not find anything in that code that it would referencing for appropriate PPE. It
may be the wrong code number that's referenced. In chapter 2 refrenced publications, 2.3.1
has Title 29 CFR 1910.120. This may be the correct code section that is trying to be refrenced
in 6.3.3.
A correct code being referenced
Submitter Full Name: Ryan Sprunger

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Committee: FIC-AAA
167 of 273 1/6/2022, 11:23 AM

6.3.3
All PPE shall meet or exceed the requirements set forth in 29 CFR 1910.1020 and the
applicable in applicable NFPA standards.
29 CFR 1910.1020 addresses access to employee exposure and medical records, rather than PPE. If
this is going to remain in the document, the reference needs to be corrected.

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6.3.5*
FIU members shall conduct a hazard and risk assessment to evaluate environmental
conditions, weather, structural integrity, and other factors prior to determining what PPE and
safety control measures to use in any scene.
Already addressed in NFPA 921 Chapter 13 Safety, important detail but I believe it encroaches on
methodology.
Submitter Full Name: David Tucker

Organization: HCFR
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Committee: FIC-AAA
169 of 273 1/6/2022, 11:23 AM

Sections 6.3.5, 6.3.6

6.3.5*
FIU members shall conduct have a policy for conducting a hazard and risk assessment to
evaluate environmental conditions, weather, structural integrity, and other factors prior to
determining what PPE and safety control measures to use in any scene.
6.3.6*
Minimum PPE based on the identified hazards shall include the following:
(1) Protective disposable outerwear or structural fire suppression outerwear
(2) Foot protection
(3) Eye protection
(4) Head protection
(5) Hearing protection
(6) Respiratory protection
(7) Hand protection
(8) Disposable gloves for evidence removal and recovery
The purpose of the standard is to require FIUs to have appropriate policies rather than to dictate what
specifically the FIU is to do; therefore, it is appropriate for the section to state, "The FIU shall have a
policy..."

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170 of 273 1/6/2022, 11:23 AM

6.3.6*
Minimum PPE based on the identified hazards shall include the following:
(1) Protective disposable outerwear or structural , structural fire suppression outerwear, or
other garments as described by industry best-practices.
(2) Foot protection
(3) Eye protection
(4) Head protection
(5) Hearing protection
(6) Respiratory protection
(7) Hand protection
(8) Disposable gloves for evidence removal and recovery
The current text is too restrictive and seems to approve of only two types of PPE outwear. Technical
rescue gear is becoming more popular, and mechanics coveralls are accessible to nearly everyone.
The language could also be made such that the outerwear should be based on the existing industry
recommendations and best practices.
Submitter Full Name: Cameron Novak

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Submittal Date: Tue Sep 14 13:57:53 EDT 2021
Committee: FIC-AAA
171 of 273 1/6/2022, 11:23 AM

6.3.7
Employers shall provide have a policy or procedure providing a method for the disposal of
used PPE in a manner that will not contaminate vehicles, tools, or clothing worn by fire
investigation unit members after the scene is cleared and decontamination has occurred.
The purpose of the FIU Standard is to require FIUs to have appropriate policies and procedures, rather
than dictating what actions the FIU is to take.

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172 of 273 1/6/2022, 11:23 AM

6.3.7
Employers shall provide a method for the disposal or transport of used PPE in a manner that
will not contaminate vehicles, tools, or clothing worn by fire investigation unit members after the
scene is cleared and decontamination has occurred.
Since it will not be feasible for every FIU to issue disposable PPE, this revision will reflect the use and
transport of both disposable and reusable PPE.

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173 of 273 1/6/2022, 11:23 AM

Sections 6.4.2, 6.4.3

6.4.2
The employer shall ensure that have a policy for ensuring that all employees at the time of
initial assignment to the FIU or private company are in compliance with federal, state, or local
requirements.
6.4.3*
A hazard The FIU shall have a policy for the completion of a hazard and risk assessment shall
be completed prior to starting the scene examination.
The purpose of the FIU standard is to ensure that FIUs have appropriate policies and procedures in
place addressing the necessary aspects of a fire investigation, not to dictate the actions that the FIU is
to take.

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174 of 273 1/6/2022, 11:23 AM

6.4.4* (6.3.5)
A hazard and risk assessment shall include the following components:
(1) Hazard identification
(2) Risk assessment
(3) Controlling the hazard, as follows:
(4) Elimination
(5) Substitution
(6) Engineering controls
(7) Administrative controls
(8) Personal protective equipment (PPE)
(9) Monitoring and review (i.e., audit)
Should this be added to the 6.3.5 to keep from having redundancy?

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Committee: FIC-AAA
175 of 273 1/6/2022, 11:23 AM

6.5 Vehicle Use.

6.5.1 Fleet Management.
6.5.1.1
The employer or appointed fleet manager shall provide its personnel with a vehicle applicable
for fire investigation.
6.5.1.2*
The employer or appointed fleet manager shall provide a policy regarding the use of vehicles.
6.5.1.3*
The employer or appointed fleet manager shall list prohibited and misuse practices in the
policy provided.
6.5.2 Driver Safety.
6.5.2.1
The employer or appointed fleet manager shall require that drivers maintain a valid license to
operate a motor vehicle by the governing body in the jurisdiction of record.
6.5.2.2
The employer or appointed fleet manager shall require that vehicle operation be conducted in a
safe manner and done in accordance with local laws and regulations and in compliance with
the policy set forth by the employing body.
6.5.2.3
The employer or appointed fleet manager shall provide training in the safe operation of a motor
vehicle, including defensive driving and emergency operation if this is a foreseeable use.
6.5.3 Reporting Vehicular Damage or Operator Citation.
6.5.3.1
The vehicle-use policy shall set forth a reporting procedure in the event of vehicular damage or
involvement in a collision.
6.5.3.2
The vehicle-use policy shall detail required notifications at the time of damage and the
subsequent responsibilities of those being notified.
6.5.3.3
The vehicle-use policy shall require an incident investigation to include documentation,
photography, diagraming, and interviews of witnesses where appropriate.
6.5.3.4
The vehicle-use policy shall include the procedure for a driver to report any citation incurred
during operation of the unit’s vehicle when said violation is deemed reportable by the
employing body.
6.5.3.5
The vehicle-use policy shall include the procedure for resolving the responsibilities of the driver
regarding any penalties or fines incurred while operating the unit’s vehicle.
6.5.4 FIU Vehicle.
176 of 273 1/6/2022, 11:23 AM

6.5.4.1
The vehicle provided shall provide personnel with a vehicle configured to protect occupants
from scene processing equipment during normal operation and in the event of collision.
6.5.4.2*
The vehicle provided shall physically segregate occupants from scene contaminants and
minimize occupant exposure to contaminants.
6.5.4.3
To prevent occupant exposure to contaminants in the vehicle, a storage compartment or trailer
shall be provided that is physically separate from the passenger compartment.
6.5.4.4
The vehicle shall provide for secure temporary storage of collected evidentiary items.
The entire section 6.5 should be removed with the exception of 6.5.4.2, 6.5.4.3, and 6.5.4.4. This is the
responsibility of the parent organization, not the proposed FIU. You can ask for specific items in the
purchase a vehicle, but if the parent organization does not support the expenditure it will not happen.
The parent organization is responsible for rules of use and drivers responsibilities for use of the
vehicle.

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Committee: FIC-AAA
177 of 273 1/6/2022, 11:23 AM

6.5 Vehicle Use.

6.5.1.1
6.5.1.2 *
6.5.1.3 *
The employer or appointed fleet manager shall list prohibited and misuse practices in the policy
provided.
6.5.2.1
6.5.2.2
6.5.2.3
6.5.3.1
6.5.3.2
6.5.3.3
6.5.3.4
employing body.
6.5.3.5
6.5.4 FIU Vehicle.
178 of 273 1/6/2022, 11:23 AM

6.5.4.1
6.5.4.2 *
6.5.4.3
6.5.4.4
The Vehicle sections appear misplaced and are not really a core safety issue related to fire
investigation. Additionally, it seems to get somewhat in the weeds and does not account for other
private sector issues that may arise where the investigator is a contract type employer or receives a
stipend for personal vehicle usage.

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179 of 273 1/6/2022, 11:23 AM

6.5.1 Fleet Management for Agency Issued Vehicles .

6.5.1.1
6.5.1.2*
6.5.1.3*
provided.
Most if not all public agencies issue vehicles as part of every job (including fire investigations).
However, this standard covers both private and public agencies. As a small business owner with
several fire investigators, to say I now have to incur the expense of providing a vehicle to every fire
investigator which conducts investigations is a huge financial burden. Additionally, this does not
change what is currently being done with conducting proper fire investigations with applicable tools
required. I'm struggling with the reasoning that this committee has come to the decision that all
employers have to now provide a vehicle for investigators. I'm also aware of many volunteer fire
organizations that will not be able to comply with this unduly burdensome requirement. As a fire
investigator for many years, having worked in both the public and private industry, I cannot support this
standard as written with regard to fleet management. I have had department issued vehicles in the
public sector and have used my own vehicle for private investigation companies. So, I believe there
needs to be a provision in the standard that allows for the use of privately owned vehicle in the fire
investigation field.

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Committee: FIC-AAA
180 of 273 1/6/2022, 11:23 AM

Public Input No. 261-NFPA 1321-2022 [ Sections 6.5.1, 6.5.2, 6.5.3, 6.5.4 ]
Sections 6.5.1, 6.5.2, 6.5.3, 6.5.4

6.5.1.1
6.5.1.2 *
6.5.1.3 *
provided.
6.5.2.1
6.5.2.2
6.5.2.3
6.5.3.1
6.5.3.2
6.5.3.3
6.5.3.4
employing body.
6.5.3.5
6.5.4 FIU Vehicle.
181 of 273 1/6/2022, 11:23 AM

6.5.4.1
6.5.4.2 *
6.5.4.3
6.5.4.4
The FIU shall establish a vehicle use policy to include: operation, maintenance, damage,
decontamination, and necessary equipment.
The purpose of the standard is to require FIUs to have appropriate policies and procedures in place,
rather than dictating specifically what actions the FIU is to take. These sections specify what the FIU is
to do as it relates to vehicles, which is inappropriate. A blanket statement regarding the policy is
sufficient.

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Committee: FIC-AAA
182 of 273 1/6/2022, 11:23 AM

6.5.1.1
The employer or appointed fleet manager shall provide its ensure its personnel with have a
vehicle applicable with the required capabilities for fire investigation and/or evidence
collection .
This section implies that public companies should actually provide or pay for a vehicle for it's
investigators. This should not be a requirement for public companies. In addition, the requirements in
this section should apply separately to investigation and evidence collection operations which can be
carried out by different vehicles.

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Affiliation: None
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Committee: FIC-AAA
183 of 273 1/6/2022, 11:23 AM

6.5.1.1
The employer or appointed fleet manager shall may provide its personnel with a vehicle
applicable for fire investigation.
Not all investigators are supplied with a vehicle.

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Committee: FIC-AAA
184 of 273 1/6/2022, 11:23 AM

6.5.1.1
The employer or appointed fleet manager shall of public sector fire investigation
units shall provide its personnel with a vehicle applicable for fire investigation. If the employer
or AHJ of private sector fire investigation units authorizes the use of a privately owned vehicle
for fire investigation duties or responsibilities, the vehicle shall meet certain requirements, such
as, but not limited to, ensuring segregation of contaminants from the passenger compartment
and secure temporary storage of evidence items during transit.
My review of the proposed NFPA 1321 standard, specifically Chapter 6, Section 6.5, reveals that the
standard as written does not adequately capture the differentiation between public and private sector
fire investigation units, specifically the manner in which vehicles are used by the private sector fire
investigators and the companies that employ them. I have attempted to assist the Committee, through
my input with sharing my experience both as a former public sector fire investigator with a large
municipal fire department and subsequently with multiple private sector forensic science agencies with
the responsibility for investigation of fires and explosions. Thank you for the opportunity to provide this
input.
Submitter Full Name: Timothy Augustine

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Committee: FIC-AAA
185 of 273 1/6/2022, 11:23 AM

6.5.1.1
The employer or appointed fleet manager shall provide its personnel with a provide or
require its personnel with to use a vehicle applicable for fire investigation.
When a vehicle cannot be provided by the employer, the vehicle used by personnel shall meet
the minimum standard in this requirement and safety as per NFPA 921.
Many small and large private investigation firms do not have the resources to personally provide the
vehicle. The vehicle normally is the property of the employee and they are expensed out for it's use.
Safety is a priority and having the proper compartments or separate from equipment is important as
well. In the proposed change this would address this problem as well as ensure the safety of the
investigator is covered.
Submitter Full Name: Andrew Bennett

Organization: Envista
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Committee: FIC-AAA
186 of 273 1/6/2022, 11:23 AM

6.5.1.1
The employer or appointed fleet manager shall provide, or require their personnel to use a
vehicle applicable for fire investigation.
To require the employer to provide the vehicle is cost prohibitive-
This section as written is cost prohibitive
Submitter Full Name: David Harlow

Organization: Envista Forensics
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Committee: FIC-AAA
187 of 273 1/6/2022, 11:23 AM

6.5.1.1
The employer or appointed fleet manager shall provide or require its personnel with to use a
vehicle applicable for fire investigation.
Employers should not be required to provide fleet vehicles to experts as the intent of this section is to
insure the safety of fire investigators which can be through many means. NFPA should not dictate
that this be the only way to achieve fire investigator safety in vehicles.
Submitter Full Name: Michael Driscoll

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Committee: FIC-AAA
188 of 273 1/6/2022, 11:23 AM

6.5.1.1
The employer or appointed fleet manager shall provide or require its personnel with to use a
vehicle applicable for fire investigation. When a vehicle is not provided by the employer, the
vehilce used by the fire investigation personnel shall meet the minimum standard in this
requirement and general safety as outlined in NFPA 921 and other applicaple documents.
Directing a business model. Not all employers want to own 100 fleet vehicles nor should this standard
direct that they have to own them and supply them. It should provide the option to have the
appropriate vehicle be utilized to perform the core job functions of a fire investigator.

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Committee: FIC-AAA
189 of 273 1/6/2022, 11:23 AM

Public Input No. 230-NFPA 1321-2022 [ Sections 6.5.1.1, 6.5.1.2 ]
Sections 6.5.1.1, 6.5.1.2

6.5.1.1
The employer or appointed fleet manager shall provide provide or require its personnel with
with to use a vehicle applicable for fire investigation.
6.5.1.2*
The employer or appointed fleet manager shall provide a policy regarding the use of
vehicles when issued, or a policy for the use of vehicles when in the performance of their job
duties .
6.5.4.1.1 (New Section I Added)
When a vehicle is not provided, the employer shall ensure the vehicle used by fire investigators
within its employ, meet all requirements set forth in this standard.
Fire investigators may use a vehicle where items such as tools, equipment and clothing are in
the passenger compartment if they are able to be stored or isolated in a manner which
prevents exposure to contaminants during the use of the vehicle.
The current section on vehicles would put an undue burden on some public and many private entities
to provide vehicles for employees. Where they are not provided companies reimburse their employees
for the vehicle wear and tear when used for jobs. This is common practice in the industry and I don't
believe having a company provide vehicles for fire investigation solves any problems or is necessary.
Training, audits and safe practices can be used to ensure the safety of the employees using their own
personal vehicle, including using trailers, totes, bins, and/or bags to store contaminated clothing, tools
and evidence, or by performing cleaning/sanitization before leaving the site.
Submitter Full Name: Wesley Grandlienard

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Committee: FIC-AAA
190 of 273 1/6/2022, 11:23 AM

6.5.1.2*
The employer or appointed fleet manager shall manager of public sector fire investigation
units shall provide a policy regarding the official use of vehicles by the use of
vehicles. employees. If the employer or AHJ authorizes the use of a privately owned vehicle for
fire investigation duties or responsibilities, a policy regarding the use of the vehicle shall be
provided that includes, but is not limited to, ensuring the vehicle is approved and is maintained
as dependable and safe means of travel for performance of official work related duties.
input.

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Committee: FIC-AAA
191 of 273 1/6/2022, 11:23 AM

6.5.1.2*
The employer or appointed fleet manager shall provide a policy regarding the use of vehicles,
when issued, or a policy for the use of vehicles when in the performance of their job duties .
Policy for the use of a vehicle not provided by the employer -

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Committee: FIC-AAA
192 of 273 1/6/2022, 11:23 AM

6.5.1.2*
The employer or appointed fleet manager shall provide a policy regarding the use of vehicles
when in the performance of their job duties as a fire investigator .
Many fire investigators utilize personal vehicles that meet the safety requirements associated with their
role as a fire investigator and vehicle use should not be limited to fire investigation.

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Committee: FIC-AAA
193 of 273 1/6/2022, 11:23 AM

6.5.1.2*
The employer or appointed fleet manager shall provide a policy regarding the use of vehicles, if
they are issued by the employer, or a policy for the vehicle when it is in the performance of their
job duties .
include if they are provided and to only cover items while it is utilized for the specific job function of fire
investigations.

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Committee: FIC-AAA
194 of 273 1/6/2022, 11:23 AM

6.5.1.3*
The employer or appointed fleet manager of public sector fire investigation units shall provide a
list of prohibited and misuse practices in the policy provided.
input.

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Committee: FIC-AAA
195 of 273 1/6/2022, 11:23 AM

6.5.2.1
The employer or appointed fleet manager of public sector fire investigation units and the
employer or AHJ of private sector fire investigations units shall require that drivers maintain a
valid license to operate a motor vehicle by the governing body in the jurisdiction of record.
input.

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Committee: FIC-AAA
196 of 273 1/6/2022, 11:23 AM

6.5.2.2
The employer or appointed fleet manager of public sector fire investigation units shall require
that vehicle operation be conducted in a safe manner and done in accordance with local laws
and regulations and in compliance with the policy set forth by the employing body.
input.

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Committee: FIC-AAA
197 of 273 1/6/2022, 11:23 AM

6.5.2.3
vehicle, including defensive driving and emergency operation if this is a foreseeable use for
agency issued vehicles .
Training shall only be applicable for agency issued vehicles and should not be extended to employee-
owned vehicles.

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Committee: FIC-AAA
198 of 273 1/6/2022, 11:23 AM

6.5.2.3
The employer or appointed fleet manager of public sector fire investigation units shall provide
training in the safe operation of a motor vehicle, including defensive driving and emergency
operation if this is a foreseeable use.
input.

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Committee: FIC-AAA
199 of 273 1/6/2022, 11:23 AM

6.5.2.3
The When a vehicle is provided, the employer or appointed fleet manager shall provide training
in the safe operation of a motor vehicle, including defensive driving and emergency operation if
this is a foreseeable use.
Requiring an employer to provide a vehicle places an undo burden on private fire investigation
companies and their employees who may be compensated in other means in lieu of a company
vehicle.

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Committee: FIC-AAA
200 of 273 1/6/2022, 11:23 AM

6.5.3 Reporting Vehicular Damage or Operator Citation When Operating Agency Issued
Vehicles or when on official company business .
6.5.3.1
6.5.3.2
6.5.3.3
6.5.3.4
during operation of the unit’s vehicle when said violation is deemed reportable by the employing
body.
6.5.3.5
Once again, this Standard needs to address the disparity between Agency issued and privately owned
vehicles in use for fire investigations.

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Committee: FIC-AAA
201 of 273 1/6/2022, 11:23 AM

6.5.3 Reporting Vehicular Damage or Operator Citation for Public Sector Fire Investigation
Units .
6.5.3.1
6.5.3.2
6.5.3.3
6.5.3.4
during operation of the unit’s vehicle when said violation is deemed reportable by the employing
body.
6.5.3.5
input.

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Committee: FIC-AAA
202 of 273 1/6/2022, 11:23 AM

6.5.3.3
The vehicle When an employer provides a vehicle, the vehicle -use policy shall require an
incident investigation to include documentation, photography, diagraming diagramming , and
interviews of witnesses where appropriate.
Employers should not be required to provide a vehicle.

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Committee: FIC-AAA
203 of 273 1/6/2022, 11:23 AM

6.5.4 FIU Vehicle.

6.5.4.1
6.5.4.2*
6.5.4.3
6.5.4.4
Again, the Standard must accommodate personally owned vehicles for use by fire investigators.

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Committee: FIC-AAA
204 of 273 1/6/2022, 11:23 AM

6.5.4 FIU Vehicle for Public or Private Sector Fire Investigation Units .
6.5.4.1
The vehicle provided or authorized for use shall provide personnel with a vehicle configured to
protect occupants from scene processing equipment during normal operation and in the event
of collision.
6.5.4.2*
The vehicle provided or authorized for use shall physically segregate occupants from scene
contaminants and minimize occupant exposure to contaminants.
6.5.4.3
shall be provided or authorized for use that is physically separate from the passenger
compartment.
6.5.4.4
The vehicle provided or authorized for use shall provide for secure temporary storage of
collected evidentiary items.
input.

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Committee: FIC-AAA
205 of 273 1/6/2022, 11:23 AM


6.5.4.1.1 (New Section Added)
When a vehicle is not provided, the employer or AHJ, shall ensure the vehicle used by fire
investigators within its employ, meet all requirements set forth within this Standard
Provides guidance for private owned vehicles

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Committee: FIC-AAA
206 of 273 1/6/2022, 11:23 AM

When a vehicle is not provided

When a vehicle is not provided by the employer, the employer shall ensure the vehicle used by
fire investigators, meet all requirements set forth in this standard. Fire Investigators may use a
vheicle where items such as tools, equipment and clothing are in the passenger compartement
if they are able to be stored or isolated in a manner which prevents exposure to contaminants
and provides for proper safety during the use of the vehicle.
The standard goes to far to direct the business model rather than provide an industry standard of best
practices. Best practices can be achieved through alternate methods and the standard should allow for
that and support it. In private fire investigations it is very common to fly to a scene exam and check
equipment and then rent a vehicle to get to the scene. It is not always possible to rent a vehicle that
has a separate cargo area and there is a way to travel with your gear and tools that is both safe and
prevents cross contamination.

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Committee: FIC-AAA
207 of 273 1/6/2022, 11:23 AM

6.5.4.1
The vehicle provided used for fire investigation shall provide personnel with a vehicle
configured to protect occupants from scene processing equipment during normal operation and
in the event of collision.
Vehicles should not be required to be provided in order to meet this safety concern.

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Committee: FIC-AAA
208 of 273 1/6/2022, 11:23 AM

6.5.4.1
The vehicle provided FIU shall provide personnel with a vehicle configured to protect
occupants from scene processing equipment during normal operation and in the event of
collision.
This makes the sentence easier to read and understand.

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Committee: FIC-AAA
209 of 273 1/6/2022, 11:23 AM

6.5.4.2*
NFPA should not require that a vehicle be provided in order to meet this safety requirement.

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Committee: FIC-AAA
210 of 273 1/6/2022, 11:23 AM

6.5.4.2*
Add 'employ the clean cab concept'
Adding the statement ‘employ the clean cab concept’ to coincide with the proposed language in the
next edition of NFPA 921 Health & Safety chapter.

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211 of 273 1/6/2022, 11:23 AM

6.5.4.3
shall be provided that is physically separate from the passenger compartment. Fire
investigators may use a vehicle where items such as tools, equipment and clothing are in the
passenger compartment if they are able to be stored or isolated in a manner which prevents
exposure to contaminants during the use of the vehicle.
Many private fire investigators utilize SUV type vehicles where alternate means like physical
containers can isolate the occupants of vehicles from any contaminants. As originally written, this
section would place an undo burden on a private investigator.

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Committee: FIC-AAA
212 of 273 1/6/2022, 11:23 AM

6.5.4.4
Move this section to Facilities and Equipment. It does not belong in the Safety section.

Organization: Donan
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Committee: FIC-AAA
213 of 273 1/6/2022, 11:23 AM

6.6.1*
Special scenes are those with circumstances that are beyond the require the use of PPE,
equipment, or investigative techniques beyond the capabilities of the responding agency.
The original language is too limiting and not presented in proper context.

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Committee: FIC-AAA
214 of 273 1/6/2022, 11:23 AM

6.6.2
Special scenes that require specialized Specialized PPE or equipment shall required for the
processing of Special scenes shall only be used by qualified personnel.
The revised language places appropriate empahsis on the use of PPE or Equipment by specially
trained personnel where the original language was vague and unclear.

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Committee: FIC-AAA
215 of 273 1/6/2022, 11:23 AM

6.6.2
Special scenes that require The specialized PPE or equipment shall equipment required by
these special scenes shall only be used by qualified personnel.
As written, the scenes will be used by qualified personnel, not the equipment.

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Committee: FIC-AAA
216 of 273 1/6/2022, 11:23 AM

217 of 273 1/6/2022, 11:23 AM

Revise Chapter 7 as follows:
7.1.1*
All fire inves�gators shall maintain the requisite knowledge as specified in NFPA 1033. The FIU shall
define the educa�on, cer�fica�on, and training requirements for personnel assis�ng in cri�cal tasks
related to fire inves�ga�on. The FIU shall assure that all personnel have and maintain educa�on,
training, licensing, or cer�fica�ons specific to their job tasks.
Fire inves�gators in the FIU shall receive educa�on and training in the field of fire inves�ga�on.
A.7.1.1 The educa�on and training for fire inves�gators shall be in accordance with the JPRs of
NFPA1033 as well as the fire inves�ga�on methodologies and techniques as prescribed in NFPA 921.
This educa�on and training can include , but is not limited to, formal educa�on through a post-
secondary school, online training, peer-to-peer training, research, self-study, formal and informal
con�nuing educa�on classes, professional development, and mentoring.
7.1.3.2
The educa�on and training records shall include a current curriculum vitae (CV) for each fire
inves�gator and other professional staff inves�gator , including all suppor�ng documenta�on.
7.2.1*
Fire inves�gators in an FIU shall be cer�fied as mee�ng according to the requirements of NFPA 1033.
7.2.2
FIU management shall encourage and materially support its employees in obtaining cer�fica�ons (or
professional designa�ons) in their respec�ve disciplines. Cer�fica�ons shall be awarded by an
independent cer�fying body.
7.2. 2 3
The FIU management shall require personnel inves�gators to maintain their cer�fica�on through
con�nuing educa�on as determined by the FIU.
7.3.1*
The FIU shall establish a wri�en protocol for all personnel opera�ng within the FIU to a�end ongoing
professional development.
A.7.3.1 Professional development can be achieved through internal or external organiza�ons u�lizing a
variety of instruc�onal methods. Professional development helps build and maintain the morale within
the FIU, encourages personnel to be�er themselves thus crea�ng a synergis�c effect within the
organiza�on. Didac�c methods of professional development provide inves�gators with theore�cal
knowledge. Examples include such classes as that of college-level coursework or any collegiate-level
structured course which issues a grade . Addi�onal educa�onal opportuni�es include online
coursework, a�ending lectures, or other similar venues. Professional development that is training
related could include educa�onal opportuni�es outside the classroom or hands-on training. Examples
include live-fire observa�on, field observa�on, shadowing senior inves�gators, evidence collec�on
scenarios, and so on.
7.3.3*
The FIU shall establish a wri�en policy for minimum hourly training requirements.
A.7.3.3 NFPA 1033 and ASTM standard requirements for training are dependent upon unit opera�on
and personnel opera�ng within the unit. Professional development should be consistent with policies
and procedures of the FIU. For fire inves�gators it is recommended that the minimum number of
professional development hours be in compliance with the current edi�on of NFPA 1033. The
correla�on of hours should be on an annual basis or over mul�ple years. The training should be
relevant to the mission of the FIU.
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The scope of this section needs to encompass all professionals in the FIU, not just fire investigators.
The establishment of job descriptions and requisite knowledge for all staff is necessary to achieve
quality in the FIU work product.
Submitter Full
Philip Crombie
Name:
Organization:
Affiliation:
Subcommittee
Street Address:
City:
State:
Zip:
Committee: FIC-AAA
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Public Input No. 112-NFPA 1321-2021 [ Section No. 7.1.1 [Excluding any Sub-
Sections] ]
Fire investigators Investigators in the FIU shall receive education and training in the field of fire
investigation and explosion investigations .
Adds emphasis on training for explosion investigations. Aligns better with NFPA 921.

Organization: Donan
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Sections] ]
Fire investigators in the FIU shall receive education and training in the field of fire
investigation and explosion investigations .
Think it is important to add the "explosion" into the requirement.

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Sections] ]
Fire investigators in the FIU shall receive education and training meet the minimum
professional qualifications listed in the field of fire investigation. most recent edition of NFPA
1033 Standard for Professional Qualifications for Fire Investigator. .
Fire Investigators have a standard NFPA 1033 and that minimum standard shall be met in order to be
identified as a fire investigator.

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7.1.1.1
The FIU shall establish procedures for education and training for members to remain current on
the requirements listed in NFPA 1033 and methods and procedures adopted by the
FIU addressed in the most current edition of NFPA 921 Guide for Fire and Explosion
Investigations .
921 cant be excluded

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7.1.1.1
The FIU shall establish procedures for education and training for members to remain current on
the requirements listed in NFPA 1033 and , NFPA 921, and methods and procedures adopted
by the FIU.
921 cannot be excluded

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7.1.2 Minimum Education Requirements.

7.1.2.1
All personnel assigned as an a lead investigator to the FIU shall have a minimum of a high
school diploma or general education diploma (GED) meet the education requirements of NFPA
1033 .
7.1.2.2
The fire investigator shall have met the education requirements of NFPA 1033. All personnel
assigned in a supporting role to the FIU shall meet the education requirements and
professional qualifications specific to their discipline (e.g., evidence collection technician, fire
protection engineer).
There needs to be a distinction between lead investigators and support personnel. Our industry needs
to allow for entry-level positions, such as evidence collection technicians, and give them opportunities
to learn fire investigations without being immediately thrown into a lead investigator role. In addition,
metallurgists and engineers have their own education requirements and don't necessarily need to be in
compliance with NFPA 1033, even though they participate in fire investigations.

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7.1.2.1
All personnel assigned as an investigator to the FIU shall have a minimum of a high school
diploma or general education diploma (GED).
Delete this section. Propsed section 7.1.2.2 refernces that investigators shall meet
requirements of NFPA 1033. NFPA 1033 Section 1.3.2.8 already addresses the requirments of
an investigator to have a hgh school diploma.
It will remove a conflict and duplication of a requirement found in a referenced NFPA document (NFPA
1033)
Submitter Full Name: John Frantz

Organization: South Whitehall Twp
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Submittal Date: Thu Oct 14 14:22:36 EDT 2021
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7.1.2.1
diploma or general education diploma (GED).
This section is not necessary, as it is covered within NFPA 1033, which is outlined in section 7.1.2.2

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7.1.2.1
diploma or general education diploma (GED).(Outside the Scope reuirements - should remain
with NFPA 1033 in case of a change).
I thought I read in the Scope it would not get into 921/1033 and is this not a specific topic that is being
addressed.

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7.1.2.1
All personnel assigned as an investigator to the FIU shall have at a minimum of a level
of education equivalent to to a high school diploma or general education diploma
(GED) level .
simplifies it

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7.1.4
FIU personnel shall demonstrate both competency and proficiency in their respective tasks
before conducting independent work.
7.1.4.1
FIU personnel task competency and proficiency shall be documented, including documenting
the results of competence and proficiency testing .
7.1.4.2*
Management shall develop and implement a method for the periodic evaluation of the
proficiency and competency of FIU personnel.

Explanatory rationale for proposed changes to
Comments_on_NFPA_1321.docx
text
The proposed changes to the text reflect the fact that the forensic community distinguishes between
proficiency and competency testing, and generally calls for both.
Here is how the OSAC community defines these terms:

• Competency testing: Evaluation of a person’s knowledge and ability to perform work before
authorization to do so independently.
• Proficiency testing: Evaluation of participant performance against pre-established criteria by
means of interlaboratory comparisons.
As is, NFPA 1321 does not does not define competency and does not require testing. It only lists
various potential ways of establishing competence, with testing being one possible way.
The standard should both define competency and require testing, including “proficiency testing,” as
part of an FIU. It should also make clear that such testing needs to be done in minimum time intervals
(e.g. once a year) and needs to reflect the range of casework that the examiner will encounter (i.e., the
test can’t be unrealistically easy in a way that doesn’t accurately reflect the full range of difficult cases).
Proficiency testing should also include case file review, testimony reviews and performance reviews.
To be concrete, we suggest making NFPA 1321 consistent with the related standard being considered
by ASTM, “Standard Practice for Forensic Science Practitioner Training, Continuing Education, and
Professional Development Programs,” that has a helpful definition of competency and sets forth
appropriate requirements for establishing both. It defines “competency” 2.1.2 as a “demonstration that
a forensic science practitioner has acquired and demonstrated specialized knowledge, skills, and
abilities (KSAs) in the standard practices necessary to conduct examinations in a discipline or category
of testing prior to performing independent casework.” It further requires “competency testing” for
FSSPs (5.2.2.9)
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Public Input No. 195-NFPA 1321-2022 [Section No. A.7.1.4.2]
Submitter Full
Andrea Roth
Name:
Organization: UC Berkeley School of Law
UC Berkeley School of Law (also LTG OSAC chair, but
Affiliation: submitting comment only in my individual capacity and not on
behalf of LTG)
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Comments on NFPA 1321
January 4, 2022
From: Andrea Roth, Professor of Law, UC Berkeley (also chair of OSAC Legal Task Group, but
submitting these comments on an individual basis, not on behalf of LTG or OSAC
The proposed changes to the text reflect the fact that the forensic community distinguishes
between proficiency and competency testing, and generally calls for both.

• Competency testing: Evaluation of a person’s knowledge and ability to perform work
before authorization to do so independently.
• Proficiency testing: Evaluation of participant performance against pre-established
criteria by means of interlaboratory comparisons.
The standard should both define competency and require testing, including “proficiency
testing,” as part of an FIU. It should also make clear that such testing needs to be done in
minimum time intervals (e.g. once a year) and needs to reflect the range of casework that the
examiner will encounter (i.e., the test can’t be unrealistically easy in a way that doesn’t
accurately reflect the full range of difficult cases). Proficiency testing should also include case
file review, testimony reviews and performance reviews.
To be concrete, we suggest making NFPA 1321 consistent with the related standard being
considered by ASTM, “Standard Practice for Forensic Science Practitioner Training, Continuing
Education, and Professional Development Programs,” that has a helpful definition of
competency and sets forth appropriate requirements for establishing both. It defines
“competency” 2.1.2 as a “demonstration that a forensic science practitioner has acquired and
demonstrated specialized knowledge, skills, and abilities (KSAs) in the standard practices
necessary to conduct examinations in a discipline or category of testing prior to performing
independent casework.” It further requires “competency testing” for FSSPs (5.2.2.9)
7.1.4
FIU
personnel shall demonstrate competency in their respective tasks before conducting

independent work
Supervisory personnel shall evaluate the technical competencies of all personnel prior to
assigning them to conduct independent work assignments .
7.1.4.1
FIU personnel task competency shall be documented
This review shall document that the investigator meets all of the job performance requirements
outlined in NFPA 1033 and other requirements designated by the FIU or Parent Organization .
7.1.4.2
Management shall develop and implement a method for the periodic evaluation of the
competency of FIU personnel
FIU management shall periodically evaluate all assigned personnel to ensure the continued
maintenance of requisite knowledge and skills outlined in the Job Performance Requirements
of NFPA 1033 and other requirements designated by the FIU or Parent Organization .
The revised language provides clarity consistent with other guiding documents.

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7.1.4.2*
Management shall develop and implement a method for the periodic evaluation
annual evaluation of the competency of FIU personnel by an experienced and competent
evaluator .
The sentence as written does not adequately define the term "periodic" which, in turn, gives little
guidance. By establishing it as "annual", the proposed language provides specificity much-needed in
this standard. In addition, the scene as written does not adequately describe the evaluator. This is
problematic as in the case of public sector agencies, at times the "management" of the FIU may have
no background in fire investigation, or limited experience. Some fire officers assigned to manage an
FIU come from different parts of the department and have little or no background in fire investigation.
Therefore, their assessment of their employees' competency may not be as thorough as someone with
more experience.
The annual competency testing is justified for a variety of reasons, as it will ensure continuing quality
management and is in line with how most accreditation programs are run (requiring annual
competency testing). Annual competency testing will help maintain and increase fire investigator skill
sets (and thereby generate better investigations), assist FIU management to identify deficiencies in
skills by its investigators, and help FIU management craft training programs or plans for its employees.
Virtually all investigators (unless self-employed) undergo an annual evaluation by their employer - an
evaluation which examines their past performances and notes deficiencies, issues, or excelled
performance. In theory a competency test is an extension of this evaluation but in a more structured
environment with hands on supervision and evaluation.
The annual competency review also is modelled on the requirement by most accreditation programs.
For example, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) National Response
Team (NRT) is accredited through the ANSI National Accreditation Board (ANAB) to ISO 17020
(investigative bodies that render professional judgment). This accreditation requires annually
proficiency or competency testing of NRT members who are to write origin and cause reports. For the
past three years, the NRT has successfully conducted this testing of its members during its annual (in-
house) training.
Notably, the section language and the proposed revisions do not detail the type, amount or nature of
the competency training. These are all details to be determined by the FIU.

Organization: Fire Sequence Investigations LLC
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7.2.1*
Fire investigators in an The FIU shall be certified according to the requirements of have a
policy to certify that assigned personnel meet or exceed the job performance requirements
outlined in NFPA 1033.
The revised language is intended to broaden the existing language to include other policies for
certification of personnel other than third party certification. While third party certification is
meaningful, FIU's should be provided the latitude to have internal policies and procedures to certify
their personnel meet the NFPA 1033 requirements.

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7.2.1*
Fire investigators in an FIU shall be certified according to meet the minimum requirements of
NFPA 1033.
I fully believe in certification but by addressing this in this standard, it appears that it is an attempt to
usurp the intent of the NFPA 1033 committee. 1033 outlines the minimum qualification to be a fire
investigator. It does not talk about being certified. The only mention of being certified is in an
appendix, where they refer to those conducting evaluations should e certified as a fire investigator
(A.1.3.2.3). This section should refer to the investigators within the unit meeting the minimum
requirements as outlined by NFPA 1033.


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7.2.2
The FIU management shall require investigators to maintain their certification through
minimum qualifications, as defined in NFPA 1033, through continuing education as determined
by the FIU.
As stated in public input 63, NFPA 1033 does not reference certification but is the standard for
minimum qualifications. As such, this section should state that investigators should continue to meet
the minimum qualifications per NFPA 1033 versus using the word "certification". I believe that this
section, by using the word "certification" is encroaching on NFPA 1033's area of responsibility.


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7.3.1*
The FIU shall establish a written protocol for all personnel operating within the FIU to attend
ongoing professional development. This policy shall include a requirement for fire investigators
to attend tested training annually.
The section needs clarification as written and should be more specific as to the timeline for required
training. The added language proposed provides this needed specificity.
The proposed language is justified as there should be an annual tested training requirement for
investigators. The fire investigation profession is slowly moving towards valuing tested training over
non-tested. This is evidenced by the International Association of Arson Investigator's CFI re-
certification program, where applicants receive additional credit towards their re-certification for tested
training versus non-tested training. In addition, with free tested training provided by CFITrainer.net and
other entities, this requirement costs nothing and has minimal impact on staffing requirements (i.e.
investigators are not out of service due to training as they can take this at their leisure). It is
noteworthy that the proposed language does not set up minimum hours or specific training topic(s)
required, just that it be annual and tested.
The requirement that the training be annual is justified by NFPA 1033 requirement in Section 4.1.7.2
which states, "The fire investigator shall remain current by attending formal education courses,
workshops, in-person, or online seminars and/or through professional; publications, journals, and
treatises." The term "current" in this section is not defined, but it certainly would include annually. In
addition, Section 4.1.7.3 in NFPA 1033 actually quantifies a number of hours of in-person training over
a time period by stating, "The fire investigator shall complete and document a minimum of 40 hours of
continuing education training every five years by attending formal education courses, workshops, and
seminars."
This annual requirement is not without precedent. For example, the Bureau of Alcohol, Tobacco,
Firearms and Explosives (ATF) for years has required its Certified Fire Investigators to complete,
annually, at least 40 hours of Out-Bureau training related to fire science, fire investigation, or fire
forensics. This is beyond the in-house training provided by ATF to its Certified Fire Investigators.
The annual training requirement will provide broader education to fire investigators and ensure that
they are "current" and up to date. This is particularly important when it comes to health and safety
training. For those fire investigators with a HazMat Technician credential, or those who have to have
Asbestos Awareness training, there is already and annual training requirement.
The proposed language also speaks to the spirit of this document. NFPA 1321 should be used by
FIU's to advocate for required resources, personnel and funding from its parent organization. This
includes securing the funding and time off for fire investigators to attend much-needed annual and
tested training.

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7.3.2
The FIUs shall should have a policy to provide funding, support, and opportunities for
continuing professional development.
best left up to the AHJ or FIU oversight

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7.3.2
The FIUs shall , or its parent organization, shall have a policy to provide funding, support, and
opportunities for continuing professional development.


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241 of 273 1/6/2022, 11:23 AM

Revise Chapter 8 as follows:
8.3 Wri�en Reports.
8.3.1*
FIUs shall develop a report policy that ensures the that report s reflect s all the aspects of the
scien�fic method inves�ga�on in accordance with NFPA 1033 and the FIUs SOPs .
8.3.2*
The FIU shall develop a policy that ensures that fire inves�ga�ve reports are authored
by a qualified fire inves�gator s .
8.3.3 The wri�en report shall reflect the applica�on of the Scien�fic Method. The report shall
describe all per�nent data collected and how it was analyzed. It shall iden�fy the hypotheses
developed from the data, how the hypotheses were tested, and why hypotheses were rejected or
accepted. The report shall contain the inves�gator’s opinions and conclusions in a clear,
delineated sec�on. The report shall also state the basis or bases for each opinion and conclusion.
8.3.4 Reports prepared for use in federal civil li�ga�on shall conform to the requirements of Federal
Rules of Evidence (FRE) Rule 26. Reports prepared for use in other forums (state courts, media�on,
arbitra�on, criminal trials) shall conform to their specific requirements.
8.3.5 If a wri�en report is not prepared then the case documents shall be sufficiently detailed so that a
report can be prepared at a later date. Case documents shall outline the background and all
per�nent informa�on needed to prepare a report at a later date, including the iden�fica�on of
necessary photographs and the reason why a report was not wri�en.
8.3.6 Supplemental Reports: If new data or informa�on is developed that causes opinions to change or
evolve, the end user shall be no�fied in a �mely manner. The reason for the change or supplement shall
be documented and, if necessary, a supplemental report shall be prepared.
8.3.7 Repor�ng to other agencies
8.3.7.1 Public sector FIUs shall coordinate with the fire department to ensure that fire department
incident reports (e.g.NFIRS reports) have been accurately filled out or amended.
8.3.7.2 In the event that the FIU determines that the cause of the fire was incendiary, those results
shall be communicated to the appropriate law enforcement agency.
8.3.7.3 In the event that the FIU iden�fies a con�nuing hazard with a product or a service, the
appropriate en�ty (e.g Consumer Product Safety Commission, Na�onal Highway Traffic Safety
Administra�on, or Na�onal Transporta�on Safety Board) shall be no�fied.
8.4 Quality Assurance/Quality Control FIU Work Product Reviews
8.4.1* Administra�ve Reviews.
The FIU shall develop a policy for administra�ve reviews of FIU work product .
8.4.1.1 The policy shall insure that administra�ve reviews shall be conducted to determine whether all
242 of 273 1/6/2022, 11:23 AM

of the steps outlined in an organiza�on's quality management system have been followed and whether
all of the appropriate documenta�on is present in the file.
8.4.1.2 An administra�ve review shall be conducted before any final report is released to an end
user. An administra�ve review shall include a check for typographical or gramma�cal errors.
8.4.2* Technical Reviews.
The FIU shall develop a policy for technical reviews that ensure the report reflects all the
aspects of the scien�fic method inves�ga�on in accordance with NFPA 1033.
8.4.2. 1 The technical review is an evalua�on of the sufficiency of a case record with regard to the
tests that were conducted, the observa�ons and conclusions contained in the report and to ensure
that there is sufficient basis for the scien�fic conclusions.
8.4.2.2 The scope of the technical review shall ensure the following, at a minimum:
1. Results, opinions, and interpreta�ons are accurate, properly qualified and supported by
the case records.
2. Conformance with applicable policies and procedures
3. Wri�en reports contain all required informa�on
4. Results are scien�fically valid
8.4.2. 3 A person performing the technical review shall be qualified as a fire inves�gator and
technically competent in the areas specific to the scenario. The person performing the technical
review shall not be an author of the report.
8.4.2.4 The technical review procedures shall include provisions for a resolu�on of disagreements.
8.4.2.5 The FIU shall develop a policy to review expert witness tes�mony.
Documentation is the primary work product of the FIU. It requires rigorous requirements and policies.
The new and revised text provides needed detail and rigor in the preparation and review of the FIU
work product. This is central to achieving quality investigations.
Submitter Full
Philip Crombie
Name:
Organization:
Affiliation:
Subcommittee
Street Address:
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Zip:
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8.1* Introduction.
FIUs shall document have a policy for documenting fire scenes and be capable of reporting
investigative findings in accordance with the scientific method .
The purpose of the FIU standard is to require FIUs to have policies and procedures in place, rather
than dictating what specifically the FIU is to do.

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8.1* Introduction.
FIUs shall document fire scenes and be capable of reporting investigative findings as guided by
NFPA 921 Guide for Fire and Explosion Investigations .
NFPA 921 is the recognized and accepted document for fire investigations.

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8.2.1*
FIUs shall provide the tools have a policy for the tools necessary to document a fire scene in
accordance with NFPA 1033.
The purpose of the FIU standard is to require that FIUs have appropriate policies and procedures in
place, rather than dictating the actions of the FIU.

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8.3.1*
FIUs shall develop a report policy that ensures the report reflects all the aspects application of
the scientific method in accordance with NFPA 1033.
The scientific method is used multiple times throughout a fire investigation. I don't think it is the
intention of the Technical Committee to have a report that breaks down each section of the scientific
method, but rather a report that illustrates and communicates the ways in which the scientific method
was applied to each conclusion the investigator makes.

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8.3.1*
FIUs shall develop a report policy that ensures the origin and cause report reflects all the
aspects of the scientific method in accordance with NFPA 1033.
The problem with the existing language is that it uses the definition, presumably, of "Report" as found
in Section 3.3.9 which states "The act of providing an account of facts relating to past events or the
acts of an organization or its individuals." In many instances, reports are generated where the focus
may be on only one small part of the investigation (i.e. an interview) and addressing "all aspects of the
scientific method" would be inappropriate. This is particularly true in the private sector where often
times a client request only a brief synopsis of investigative activities and findings. The appropriate
place to address "all aspects of the scientific method" is in a designated "Origin and Cause Report".
The added language makes this distinction and provides for a more reasonable mandate.
Adding this language in this proposal would necessitate the addition of the definition of an "Origin and
Cause Report" in section 3.

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8.3.1*
FIUs shall develop a report policy that ensures the written report reflects all the aspects of the
scientific method in accordance with NFPA 1033 of findings appropriately reflect all relevant
facts and information developed during the course of an investigation and all opinions or
findings in a clear, consise and logical format and serve the purpose of the client or end user of
the report .
Strictly requiring that the report outline the use of the scientific method misses the mark. It is important
to require the reporting of all relevant facts and information as well as all findings. The
recommendation to have the report reflect the use of the scientific method should be placed in the
annex.

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8.3.1*
FIUs shall develop a report policy that ensures the report reflects all the aspects of the scientific
method in accordance with NFPA 1033.
Private clients do not always want a "full" report but rather want a summary report of findings. This
summary report is both technical and complete but it is not exhaustive of all scientific methodologies
such as a Rule 26 report. This standard should allow for that.

Affiliation: Private Fire Investigatoins
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8.3.1*
FIUs shall develop a report policy that ensures the report reflects all the aspects of the scientific
method in accordance with NFPA 1033 and NFPA 921 .
NFPA 921 Chapter 4 covers that, once again it seems the committee is purposefully ignoring NFPA
921 and inferring that this document is to be a replacement for the 921 "guide". If so, the development
and formation of this document should be abandoned post haste.

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8.3.2 *
The FIU shall develop a policy that ensures that fire investigative reports are authored by a
qualified fire investigator.
This policy is redundant. IF an FIU is required to ensure that its personnel meet the requirements of
NFPA 1033 then they will be in position to write appropriate origin and cause reports. This section is
not needed to ensure adherence to competency-based investigations.

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8.3.2*
The FIU shall develop a policy that ensures that fire investigative reports are authored by a
qualified fire investigator who meets the minimum qualifications found in NFPA 1033 .
NFPA 1033 is the qualification STANDARD.

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Sections 8.4.1, 8.4.2

8.4.1* Administrative Reviews.
The FIU shall develop a policy for administrative reviews. For FIUs consisting of a single
investigator, this can be a self review.
The FIU shall develop a policy for technical reviews that ensure the report reflects all the
aspects of the scientific method in accordance with NFPA 1033. For FIUs consisting of a single
investigator, this can be a self review.
This section does not account for an FIU consisting of a single investigator (i.e. a one person private
company). This situation should be accounted for as the section currently implies that a second person
be required to conduct the evaluations.

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Sections 8.4.1, 8.4.2

8.4.1 * Administrative Reviews.
The FIU shall
develop a policy for administrative reviews.
8.4.2 * Technical Reviews.
aspects of the scientific method in accordance with NFPA 1033.
follow the industry standars established by NFPA 921 and 1033 that outline administrative and
technical reviews.
already established with previous standards such as 921. Just need to follow it and do it, do not need
to have another standard that tells us to create a policy to follow another established standard.

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Peer Reviewed Documents

The FIU shall have a policy that ensures peer reviewed documents are the primary source of
references in reports.
The FIU shall have a policy that ensures references in reports that are not peer reviewed are
labeled as such.
This encourages the use of references in fire investigation reports, specifically to peer reviewed
documents. It also allows for references that may not be peer reviewed, but acknowledges the
limitations of that information and the need for additional research.

Organization: Donan
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aspects of the scientific method in accordance with NFPA 1033. reviewer has the technical
capabilites and expertise to critically review the report of findings. The techical reviewer
shall specifiy what their scope of review included, specifically noting any limitations or
restrictions that had potential to adversly affect the review process.
It is more important to ensure that the technical review is in fact a technical review by someone
appropriately qualified. Outlining the use of the scientific method misses the mark as the information
and quality of opinions is what is subject to review.

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aspects of the scientific method in accordance with NFPA 1033 . and NFPA 921
NFPA 921 which deals with methodology in detail should be included.

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8.5 * Audit.
The FIU shall develop a policy regarding retrospective reviews of reports to ensure that the
expressed policy is implemented.
I don't believe that a retrospective audit is necessary for an FIU to be effective. If sections 8.4.1 and
8.4.2 of this standard are adhered to, the reports would have been technically reviewed soon after they
were authored. A "retrospective audit" is thus unnecessary and cumbersome. I'm not sure why this is
included in the standards. I do understand that there have been periods in the past where a review
was vital and successful but mandating that all FIUs conduct these "retrospective audits" is overly
burdensome.

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8.5* Audit.
The FIU shall develop a policy regarding retrospective reviews of reports to ensure that the
expressed policy is implemented as guided by NFPA 921 Chapter 4 subsection 6 .
Reviews are already clearly covered in 921 4.6

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Public Input No. 33-NFPA 1321-2021 [ Section No. A.5.1 ]
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A.5.1
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There are a variety of resources FIUs need to consider depending on the size, breadth, and
scope of the FIU’s operation.
For example, the following stakeholder resources:
(1) Governmental agencies, including, but not limited to, the following:
(2) District /State attorneys
(3) Mayors
(4) Building officials and code enforcement
(5) Utilities
(6) Public works
(7) Zoning
(8) Task forces (e.g., county, state, federal resources, agencies, and so on
(9) Legal
(10) Fire departments
(11) Police departments /Sheriff/Constable departments
(12) Building and fire code inspectors
(13) Health inspectors
(14) Medical examiners/coroners
(15) Public utility /private utility agencies
(16) Lightning activity reports
(17) Involved insurance companies
(18) Private companies
And the following safety resources:
(1) Support mechanisms for SCBA in hot or warm zones
(2) Resource for health and safety questions/concerns
(3) Hazmat/safety/air monitoring/chemical identification
(4) Biohazard removal
(5) Decontamination
(6) Structural engineering analysis and stabilization
(7) Coordination with local utility/power companies
And the following logistic resources:
(1) Meals, restroom facilities, warming/cooling, parking, media control/press area, investigative
command center, additional investigators or manpower
(2) SOG—staffing levels appropriate to scene size and safety; span of control
(3) Heavy equipment/thawing resources/environmental needs
(4) Lighting
(5) Scene security
(6) Evidence preservation
(7) Memorandum of understanding (MOU)—inter-agency, intra-agency, public, and private
(8) Coordination with local utility and power companies
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(9) Tools and equipment, storage, and sterilization/cleaning
Related entities for jurisdictions.

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Public Input No. 14-NFPA 1321-2021 [ Section No. A.5.2.1 ]
A.5.2.1
The evidence policy should cover the following topics:
(1) Evidence collection procedures
(2) Storage of evidence
(3) Chain of custody
(4) Maintaining a list of appropriate testing facilities for the proper evaluation of the evidence
(5) Documentation
(6) Periodic evidence audit
(7) Evidence security and protection
(8) Proper marking, identification, handling, and storage of hazardous materials in evidence
storage
(9) Laboratory submission procedures
(10) Reporting laboratory results
Hazardous materials include, but are not limited to, the following:
(1) Lithium-ion batteries
(2) Combustible liquids
(3) Flammable liquids and gases
(4) Self-heating materials
(5) Solvents
(6) Chemicals
(7) Biological, blood, and body parts/bodily fluids
The section is incomplete as written and should include a requirement that the policy address
laboratory submission procedures (i.e. is are the items transported in person to the lab or sent via
FedEx, etc.) as well as how laboratory results are reported on once received. This added language
would allow the section to be complete, covering all handling of evidence throughout its "lifetime",
including evidence identification, documentation, collection, storage, testing, and reporting. In fact, in
NFPA 1321 Section 4.1.2.2, it states that, "Each policy or procedure shall include instructions for the
safe performance of tasks, documentation, analysis, interpretation, and reporting."

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Public Input No. 13-NFPA 1321-2021 [ Section No. A.6.3.5 ]
A.6.3.5
The methodology recommended in NPFA 921 should be followed. The following form has
been utilized by Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) Incident Safety
Officers as a reminder to themselves to address hazard assessment issues, and
to communicate their mitigation strategies to other participating investigators.

ATF Incident Safety Officer
ATF_ISO_Hazard_Checklist_V3_002_.docx
Checklist
The section directs investigators to follow NFPA 921 guidelines. The section is better served by
providing an example as well, since the topic of hazard assessment and mitigation is wide ranging.
The attached form solves this problem by providing an example for fire investigators and illustrates the
many issues that need to be considered and addressed.

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Public Input No. 226-NFPA 1321-2022 [ Sections A.6.5.1.2, A.6.5.1.3 ]
Sections A.6.5.1.2, A.6.5.1.3

A.6.5.1.2
Policies on vehicle use include, but are not limited to, hours of permitted operation,
geographical operation, state of readiness, the safeguarding of the vehicle and its contents,
and operation in times of special circumstance (e.g., severe weather or civil unrest).
A.6.5.1.3
Practices and misuse include, but are not limited to, acts of unsafe operation, operation while
impaired, unauthorized passengers, or operation during unofficial business defined by the
employing body and the consequences of violation.
As previously stated, organizational policies of the parent organization should not be included in the
FIU document. Many times conflicting policies will be present and only make the situation worse.

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Public Input No. 195-NFPA 1321-2022 [ Section No. A.7.1.4.2 ]
A.7.1.4.2
It is important that the fire investigator’s techniques are periodically reviewed for competence to
recommended practices and for proficiency . This can include shadowing on scenes, review of
case files, presentation of cases, and discussions, or testing. but also must include
competency testing and proficiency testing, where "competency testing" is an evaluation of a
person’s knowledge and ability to perform work before authoriza�on to do so independently, and
"proficiency tes�ng" is e valua�on of par�cipant performance against pre-established criteria by means
of interlaboratory comparisons.
Proficiency testing must also include case file review, tes�mony reviews and performance reviews.
The FIU must set minimum �ming requirements for proficiency tes�ng, which should be done at a
minimum every calendar year. The proficiency tes�ng must involve scenarios that are reflec�ve of the
full difficulty of the examiner's actual casework.

Comments_on_NFPA_1321.docx
see comments on 7.4.1

Submitter Full Name: Andrea Roth

Organization: UC Berkeley School of Law
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Comments on NFPA 1321
January 4, 2022
From: Andrea Roth, Professor of Law, UC Berkeley (also chair of OSAC Legal Task Group, but
submitting these comments on an individual basis, not on behalf of LTG or OSAC
The proposed changes to the text reflect the fact that the forensic community distinguishes
between proficiency and competency testing, and generally calls for both.

• Competency testing: Evaluation of a person’s knowledge and ability to perform work
before authorization to do so independently.
• Proficiency testing: Evaluation of participant performance against pre-established
criteria by means of interlaboratory comparisons.
The standard should both define competency and require testing, including “proficiency
testing,” as part of an FIU. It should also make clear that such testing needs to be done in
minimum time intervals (e.g. once a year) and needs to reflect the range of casework that the
examiner will encounter (i.e., the test can’t be unrealistically easy in a way that doesn’t
accurately reflect the full range of difficult cases). Proficiency testing should also include case
file review, testimony reviews and performance reviews.
To be concrete, we suggest making NFPA 1321 consistent with the related standard being
considered by ASTM, “Standard Practice for Forensic Science Practitioner Training, Continuing
Education, and Professional Development Programs,” that has a helpful definition of
competency and sets forth appropriate requirements for establishing both. It defines
“competency” 2.1.2 as a “demonstration that a forensic science practitioner has acquired and
demonstrated specialized knowledge, skills, and abilities (KSAs) in the standard practices
necessary to conduct examinations in a discipline or category of testing prior to performing
independent casework.” It further requires “competency testing” for FSSPs (5.2.2.9)
Public Input No. 220-NFPA 1321-2022 [ New Section after B.1 ]

Insert the following new annex material:
Annex C: SOGs / SOPs Structure
Standard Opera�ng Procedures (SOPs) and Standard Opera�ng Guidelines (SOGs) should follow a
standard structure.
Title: The �tle should be concise but complete enough to iden�fy the subject at hand.
Introduc�on: An introduc�on is generally not necessary but may be added if the FIU determines that an
explanatory statement is necessary for the proper understanding of the SOP or SOG.
Scope: Include in the scope informa�on rela�ng to the purpose of the SOP or SOG.
Reference Documents: Any �me an SOP or SOG refers to another document, list those documents in the
reference document sec�on. Do not list documents unless they are specifically referred to in the SOP or
SOG.
Defini�ons: A defini�on sec�on may be necessary for terms of art that may be misconstrued if not
clearly defined in the document.
Safety: Iden�fy safety hazards that may be encountered during the procedure described in the SOP or
SOG and describe methods to mi�gate or eliminate the safety hazard.
Procedure: Include in proper sequence detailed direc�ons for performing the opera�on. Describe in
detail the successive steps for the procedure, grouping related opera�ons in logical divisions. Use sub-
headings if they will help the organiza�on of the material. Make the procedure concise, to the point, and
easily understandable.
Deployment: Describes the circumstances in which this procedure may be required.
Documenta�on: Describe in detail any data that is expected to be generated from the procedure. If
standard forms are available, this is the sec�on where they should be iden�fied.
Record Keeping: Describe the FIUs policy for record keeping and reten�on for the documenta�on that
arises out of the use of the procedure.
Report: State in the report sec�on the detailed informa�on expected as a result of the procedure.
Amendments: A unique iden�fier, revision number, approver, and an approved date should also be
included.
Addi�onal informa�on may be found at www.process.st/sop-templates and the OSAC Fire and
Explosion Inves�ga�on webpage, h�ps://www.nist.gov/osac/fire-explosion-inves�ga�on-
subcommi�ee
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The draft text describes SOPS and SOGs but does not address minimum requirements. This annex
outlines the information that should be included. It will aid those with responsibility for developing
SOPs/SOGs.
Submitter Full
Philip Crombie
Name:
Organization:
Affiliation:
Subcommittee
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272 of 273 1/6/2022, 11:23 AM

Public Input No. 238-NFPA 1321-2022 [ New Section after B.2 ]
Additional Reference Material

International Association of Arson Investigators, Inc.
The current edition of Fire Investigator Health and Safety Best Practices
This reference document is particularly applicable to the safety chapter of this new standard, and is the
most comprehensive document on the subject of fire investigator health and safety.
Submitter Full Name: Jeff Pauley

Affiliation: IAAI Health & Safety Committee chairman
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Committee: FIC-AAA
273 of 273 1/6/2022, 11:23 AM

NFPA 1321, Fire Investigation Unit (FIU) Should Be Changed To Fire and Explosion Investigation Unit

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Public Input No. 104-NFPA 1321-2021 [ Global Input ]

Statement of Problem and Substantiation for Public Input

Submitter Information Verification

Submitter Full Name: Paul Ayres

1 of 273 1/6/2022, 11:23 AM

Public Input No. 197-NFPA 1321-2022 [ Global Input ]

Statement of Problem and Substantiation for Public Input

Submitter Information Verification

Submitter Full Name: Robert Schaal

2 of 273 1/6/2022, 11:23 AM

Public Input No. 227-NFPA 1321-2022 [ Global Input ]

Statement of Problem and Substantiation for Public Input

Submitter Information Verification

Submitter Full Name: Joey Lankford

3 of 273 1/6/2022, 11:23 AM

Public Input No. 249-NFPA 1321-2022 [ Global Input ]

Statement of Problem and Substantiation for Public Input

Submitter Information Verification

Submitter Full Name: Richard Jones

4 of 273 1/6/2022, 11:23 AM

Public Input No. 35-NFPA 1321-2021 [ Global Input ]

Statement of Problem and Substantiation for Public Input

Submitter Information Verification

Submitter Full Name: Stephen Rinaldi

5 of 273 1/6/2022, 11:23 AM

Public Input No. 67-NFPA 1321-2021 [ Global Input ]

Statement of Problem and Substantiation for Public Input

Submitter Information Verification

6 of 273 1/6/2022, 11:23 AM

Public Input No. 158-NFPA 1321-2022 [ Chapter 1 [Title Only] ]

Statement of Problem and Substantiation for Public Input

Submitter Information Verification

Submitter Full Name: James Platt

7 of 273 1/6/2022, 11:23 AM

Public Input No. 41-NFPA 1321-2021 [ Section No. 1.1 ]

Statement of Problem and Substantiation for Public Input

Submitter Information Verification

Submitter Full Name: Samuel Campbell

8 of 273 1/6/2022, 11:23 AM

Public Input No. 42-NFPA 1321-2021 [ New Section after 1.1.1 ]

TITLE OF NEW CONTENT

Statement of Problem and Substantiation for Public Input

Related Public Inputs for This Document

Related Input Relationship

Submitter Information Verification

Submitter Full Name: Daniel Heenan

9 of 273 1/6/2022, 11:23 AM

Organization: Clark County Fire Department

10 of 273 1/6/2022, 11:23 AM

Public Input No. 153-NFPA 1321-2022 [ Section No. 1.1.1 ]

Statement of Problem and Substantiation for Public Input

Submitter Information Verification

Submitter Full Name: Matt Benfer

11 of 273 1/6/2022, 11:23 AM

Public Input No. 205-NFPA 1321-2022 [ Section No. 1.1.1 ]

Statement of Problem and Substantiation for Public Input

Submitter Information Verification

12 of 273 1/6/2022, 11:23 AM

Public Input No. 84-NFPA 1321-2021 [ Section No. 1.1.2 ]

Statement of Problem and Substantiation for Public Input

Submitter Information Verification

Submitter Full Name: Paul Haas