November 18, 2010

On November 10, 2010, the Office of the Fire Marshal (OFM) released its Operational Planning: an Official Guide to Matching Resource and Risk [PFSG 04—08-10] to Ontario Fire Chiefs.

It is not a regulation, but a tool. The document is introduced as an evaluative tool to assist fire departments to gauge resource requirements for suppression for a range of risk types, not just single family residential, within a municipality. It was developed to assist fire departments in assessing and analyzing fire risk in their community by looking at current capabilities in terms of staff resources, finding gaps, working out options, and then developing recommendations and presenting them to municipal councils.

AMO and its members have consistently stated support for the need for our municipal fire departments to be appropriately trained, equipped and ready to provide the high level of service our communities expect and deserve. AMO agrees that municipal councils, through their fire departments, need to understand the potential risks in their communities and how these risks can be reasonably mitigated using the comprehensive spectrum of fire prevention, education, outreach, enforcement, suppression and protection strategies and methods.

That being said, AMO believes this evaluation tool, by itself, is only part of risk management analysis and planning that municipal councils and fire departments should be undertaking with respect to fire risk management planning for their communities. Our key concern is this document is largely focused only on resource deployment. Separation of resource deployment (staffing) from all other fire suppression methods ignores the OFM’s own previous advice on optimizing emergency response in 2005 which stated that “the delivery of fire ground suppression activities is a sub-model of the Comprehensive Fire Safety Effective Model.”

The Comprehensive Fire Safety Effectiveness Model has seven components which are:
  • Fire Risk;
  • Fire Prevention Program Effectiveness;
  • Public Attitude;
  • Detection Capabilities;
  • Built-in Suppression Capabilities; and
  • Intervention Time; and Fire Ground Effectiveness.
Any guideline or evaluation tool to improve fire safety should look at all, not just one component in isolation but rather in a comprehensive, integrated manner. Also the seven components follow a logical sequence meaning that they should be considered in order. Following the OFM’s line of reasoning, it is questionable why the OFM has now released a paper which focuses solely on resource deployment, and ignores the other important factors in fire suppression. Contained within the OFM’s release of this document, they state that they are currently developing a preliminary framework of a guideline about fire safety standards, enforcement and public education, intended to be a companion piece to PFSG 04—08-10. However no timeline for this companion piece is mentioned.

AMO would strongly suggest that municipal councils, if presented with recommendations stemming from this evaluation tool only, should be mindful that fire services need to be considered in a comprehensive and integrated manner, as PFSG 04—08-10 only provides an analytical tool for part of the picture. Other components of the Comprehensive Fire Safety Effectiveness Model, such as fire safety standards, enforcement, public education and outreach, must also be considered by councils to ensure effective and efficient fire services.

Our concerns as outlined above have been shared with the Office of the Fire Marshal, the Ministry of Community Safety and Correctional Services (MCSCS), and the Ministry of Municipal Affairs and Housing (MMAH) on a number of occasions. We are disappointed that the questions and concerns AMO raised with the OFM with respect to the first draft of this document, have gone unanswered and that there have been no significant revisions in this final version that reflect the valid concerns of Ontario’s municipalities.

AMO will continue to advocate for a collaborative consultation process between the OFM and municipalities, and is hopeful that during the development of the announced companion document, that the municipal perspective and knowledge be an integral part