Policy Structure

The MCFRS Infection Control and Hazard Exposure Reduction Manuals were created by Fire Chief General Order 20-03 

The material provided below as current as of 1 May 2026. Please refer to the official Department document repository to ensure access to the latest version. 

• 1 Dec 2011: MCFRS Policy 26-06 AMII Respiratory Protection Policy 

• 21 May 2011: FCGO 14-11 Respiratory Protection /Cancer Prevention

• 17 Jun 2016:  FCGO 16-07  Respiratory Protection / Cancer Risk Reduction Rescinds FCGO 14-11

• 4 Jul 2016 :  MEMO: Established Atmospheric Conditions & Meter Readings FCGO 16-07

• : FCGO 20-03 MCFRS Infection Control and Hazard Exposure Reduction Manuals 

MCFRS Policy 26-06AMll Respiratory Protection Policy requires the use of  Respiratory Protection Equipment (RPE) in atmospheres that are Immediately Dangerous to Life and Health (IDLH) and in "hazardous and/or toxic atmospheres”. A hazardous and toxic atmosphere is defined by Policy 26-06AMll as "... an environment that may present or contain respiratory hazards during MCFRS activities, including, but not limited to, those related to overhaul, hazardous materials, EMS, and cause & origin operations”. 

• FCGO 14-11 mandated respiratory protection throughout the entire overhaul process. 

• FCGO 16-07 back off of created a graduated level of respiratory protection to account for the heat stress and orthopedic injury potential. 

  • The 4 July 2016 Memo established the atmospheric condition boundaries. 

• FCGO 20-03 The MCFRS Infection Control and Hazard Exposure Reduction Manuals refined current thinking and took out the atmospheric conditions. 

Understanding Policy Variance

Exploring the Differences Between

• MCFRS Policy 25-06 Public Safety Training Academy Operations During Inclement Weather &

• FCGO 16-07 Respiratory Protection/ Cancer Risk Reduction

• DFRS Policy 811 Operations During Inclement Weather

The astute reader will immediately identify differences between the various policies that use temperature, humiture, or other weather related values to make decisions about the intensity or nature of work to be done. This discussion hopes to put those differences into context. 

One way to evaluate a policy is to consider the following attributes:

• Purpose/Intent-what is the problem and/or hazard that the policy sought to address?

• Context- What are the assumptions of the policy? Who was it written for?

• Limitations & Latitude-Are there inherent limitations, either in context or administratively? How much latitude does the policy allow.

Remember no policy is 100% perfect and no policy can predict the future. Policy writers generally are trying to solve a particular problem or set of problems or reduce the chance of problems based on the contextual reality in place at the time the policy was generated. 

In some cases there is a triggering event that highlights the need for a new policy. In other cases personnel (regardless of rank really) push through an idea that makes sense to codify across the organization. The way we do that is with policy. 

There is a difference between DFRS policy, MCFRS policy, and FCGOs, but treatment of those differences is beyond the scope of this discussion. That said all policies have limits and those limits are drawn by a few factors, not the least of which are the scope of knowledge of the writer(s) and their ability to imagine possible future states of existence. 

Three Weather Policies

DFRS Policy 811 Operations During Inclement Weather

First of all the DFRS policy is the older of the documents, written almost 25 years ago. At lot has changed in 25 years with regards to what is known about heat stress. That said the policy is still within just a few degrees of current thought/practice so congratulations to the writers of that one. 

Purpose: "To govern actions of Bureau of Operations personnel during periods of extreme cold or heat."

Context: This policy was written in 1994, just six years after Montgomery County assumed control of the paid firefighter staff. You will notice a bunch of policies developed at this time period as an essentially new fire department worked to get its arms around and generally codify the behaviors of what used to be 19 different sets of rules. 

Limitations/Latitude: The limitation of this policy is that it required the Duty Chief to interact notice that a problem was likely, reach out for data, and have ECC communicate that data. But it provided the Duty Chief with the latitude to make adjustments based on their judgment and operational needs. 

FCGO 16-07 Respiratory Protection/ Cancer Risk Reduction

The next policy to come was the Respiratory Protection/Cancer Risk Reduction Policy. 

Purpose: The primary purpose of this FCGO is,  "to reduce the incidence of cancer among all MCFRS personnel." When will we consider allowing people off of SCBA? The secondary purpose was to reduce the potential for heat stress related coronary events. 

Context: This FCGO was generated in response to a growing body of literature on the impact of heat stress and the impact of fire smoke on the human body. The respiratory protection policy that was previously in place did not allow for coming off of SCBA during the overhaul phase of operations. However, technology had improved, our understanding had improved, and our ability to get "cleaner-faster" had improved. This meant we were in a good place to balance chemical exposure against heat stress. 

Limitations/Latitude: Interestingly the primary limitation of this policy is that is it directly focused on two things: Chemical exposure (both dermal & respiratory) and Heat Stress. It has no implications for the training environment. There is very little latitude afforded by the policy, however, any incident commander during emergency operations has the latitude to deviate from established policies if that deviation is deliberate, defendable and communicated. 

Public Safety Training Academy Operations During Inclement Weather

The next policy to come was the PSTA Inclement Weather Policy. 

Purpose: "To establish a policy and procedure that governs the actions of MCFRS personnel while training during periods of extreme cold or heat." The primary purpose of this policy is to reduce heat stress in the training environment. 

Context: There have been cases of personnel who have died or suffered significant injury/illness because of training induced heat stress. Furthermore, while field operations depends on weather service data (data for large geographic areas) the PSTA has technology on-site to provide near-real time monitoring of local weather conditions. 

Limitations/Latitude: This policy is limited to, "MCFRS personnel, and those from other organizations, participating in Public Safety Training Academy-sponsored training."  

Ok, but why the different numbers?

First off, there are no binding standards or rules around heat stress. Multiple sources provide guidance and both the IAFF and OSHA are equally reputable sources. 

OSHA, "There are currently no specific OSHA standards for occupational heat exposure. However, Under the General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act (OSHA) of 1970, employers are required to provide their employees with a place of employment that "is free from recognizable hazards that are causing or likely to cause death or serious harm to employees."

OSHA Clothing Adjustment Factor

Limited-use vapor-barrier coveralls. Examples: Encapsulating suits, whole-body chemical protective suites, firefighter turn-out gear.- 11(degrees added to the air temperature)

IAFF Clothing Adjustment Factor

If protective clothing (fire or HAZMAT) is worn, an adjustment factor of 10°F (2°C) should be added to the environmental temperature before the Apparent Temperature is calculated.

The PSTA policy is the newest policy. They based their information primarily on OSHA guidance. The writers of the Respiratory Protection FCGO based their work on the IAFF Heat Stress Protocol. Whose right? Well they both are. 

Both sets of policies are generally aligned and the IAFF and OSHA heat stress management programs are generally aligned. The PSTA added an additional safety factor of 9 degrees on top of the OSHA guidance of 11 degrees as it was their right to do to provide additional risk management capacity. OSHA Technical Manual

According to OSHA, "A WBGT meter (see Figure 2. and Figure 3.) is the most accurate tool for adjusting the temperature for heat stress factors including humidity, air movement (i.e., wind), radiant heat, and temperature...." This is exactly the equipment used by the PSTA.  When the PSTA is sponsoring training they are in possession of the most timely AND accurate heat stress information and on top of that they have ensured a buffer against adverse outcomes consistent with existing policy. 

One should also notice that the OSHA policy includes something else which is exposure to direct sunlight (radiant heat energy). So the PSTA policy lines up with an assumption of bright sunlight. In other words, it makes sense for PSTA sponsored events. 

Conclusion

The numbers may be different but each of the policies was written with a different purpose in mind, each has a pretty well defined scope of applicability, and each considers different risk management concerns.