Policy - Occupational Medical, Fitness and Wellness

Format. Adopt as a policy approved by the fire chief or council, as a standard operating guideline, or as a directive; keep the numbering, because the program, the forms and the audit checklist refer to it.

Drafting conventions. Shall is mandatory; should is expected unless a documented reason exists; may is permitted. Placeholders in double curly braces, such as {{Department}}, are completed by the department. Drafting notes appear in callouts and are removed before adoption.

Keep intact: the essential job task anchor (5.2), the fitness-for-duty and accommodation test (5.4), the custodian rule (5.9), the non-punitive fitness program (5.5), the fatigue self-declaration (5.6), and the learning firewall (4(d) and 5.11). Adapt: tiers and intervals, the physician arrangement, the fatigue limits, and the roles mapping.

1.1 To commit the department to keeping every member medically and physically able to do the work safely across a career, to protecting members’ health information, and to managing fatigue as a hazard.

1.2 To set out who is accountable for each commitment and to point to the program and procedures that carry it out.

2.1 This policy applies to every operational member of the department, career, volunteer and paid-on-call, and to candidates for operational roles.

2.2 Non-operational staff are covered by sections 5.6 (fatigue), 5.7 (return to work), 5.8 (wellness) and 5.9 (health information), and by any medical requirement attached to their duties.

2.3 Incident and training rehabilitation, hearing conservation, occupational cancer screening and psychological health are governed by their own programs and, where applicable, their own policies, and are referenced here.

2.4 Nothing in this policy limits a member’s rights under the applicable human rights, workers’ compensation or occupational health and safety legislation, or under the collective agreement.

Terms in bold are used as defined here and in 06 Glossary and Acronyms.

• Accommodation: a change to duties, equipment, schedule or role that lets a member with a restriction do the work safely, up to the point of undue hardship.
• Bona fide occupational requirement (BFOR): a standard rationally connected to the job, adopted in good faith, and reasonably necessary because the member cannot be accommodated without undue hardship (British Columbia (Public Service Employee Relations Commission) v. BCGSEU, 1999).
• Essential job tasks: the written list of tasks an operational role must be able to perform, approved under 5.2.
• Fatigue: a state of reduced mental or physical capacity resulting from sleep loss, extended wakefulness, workload or circadian disruption.
• Fire department physician: the physician or clinic lead designated under 5.1.
• Fitness-for-duty determination: the physician’s categorized conclusion about a member’s ability to perform the essential job tasks.
• Health information: any information about a member’s physical or mental health, including results, diagnoses and fitness assessment scores.
• Learning firewall: the commitment that information gathered for learning is not used for discipline.
• Member: any career, volunteer or paid-on-call firefighter or officer, and any other person the department engages in operational work.
• Psychological safety: the shared belief in a team that it is safe to speak up, ask, admit error and challenge (Edmondson, 1999)DOI.

1. People are the solution we build around, not the problem to fix. Members arrive wanting to be fit and well for the work; this policy gives them the physician, the time, the equipment and the privacy to be so.

2. Procedures describe work as done, written with the people who do it. The medical, fitness, fatigue and return-to-work procedures are designed with learning teams of members who have been through them.

3. Learning comes before blame, and learning information is never used for discipline. A hidden symptom, a missed medical or a shift worked past the limit is a signal about the system; the response is to find out why.

4. Psychological safety is a condition of safety, so speaking up is expected and protected. A member who says “I am not fit for this today” has done their job; the officer’s job is to act on it.

5. One standard, applied fairly. Medical and fitness standards are anchored to the essential job tasks, validated, applied individually, and never used adversely without the BFOR test and the duty to accommodate.

6. The department holds the determination, never the chart. Health information stays with the custodian.

7. Volunteers are members. The standard is the same; the method is scaled to make it achievable.

5.1.1 The department shall designate a fire department physician under a written agreement that sets scope, confidentiality, turnaround and cost, and shall orient the physician to the essential job tasks, the exposure profile and the work. Accountable: {{Fire Chief}}.

5.1.2 The physician shall evaluate members against the essential job tasks and the criteria of NFPA 1580 (2025) and shall report to the department only a fitness-for-duty determination.

5.2.1 The department shall adopt and publish a written list of essential job tasks for each operational role, derived from NFPA 1580 and the department’s operations, and shall include it in job descriptions and postings. Accountable: {{Fire Chief}}.

5.2.2 No medical or fitness standard shall be applied adversely to any member unless it is traceable to an essential job task.

5.3.1 Every candidate for an operational role shall complete a medical evaluation and a validated physical ability test before appointment.

5.3.2 Every career member and every interior or SCBA-qualified member shall have an annual medical evaluation; other volunteers shall be evaluated on the tiered schedule in the program, and every volunteer shall have an entry evaluation before operational assignment. Accountable: {{Deputy Chief}}.

5.3.3 No member shall be assigned to wear SCBA or any other respirator without medical clearance (CSA Z94.4-18).

5.3.4 The annual evaluation shall include cardiac risk stratification and an exercise stress test where the member’s age or risk profile indicates it (NFPA 1580, 2025).

5.3.5 Medical evaluations shall be provided at department cost, on duty for career members and at times volunteers can attend.

5.4.1 The physician shall determine fitness in one of the categories in the program; the department, not the physician, shall decide assignment and accommodation.

5.4.2 Before any member is removed from a role on a medical or fitness ground, the department shall apply the three-step BFOR test, shall consider individual assessment, modified duties, alternative roles and a time-limited improvement plan, and shall document the hardship analysis for any option rejected. Accountable: {{Deputy Chief}} with corporate human resources.

5.4.3 A member may be accompanied by a union or association representative at every step, and may ask the fire chief to review the decision; the grievance and human rights processes are unaffected.

5.4.4 A volunteer who is not cleared for a role shall be assigned to roles for which they are cleared, as an accommodation and not a penalty.

5.5.1 The department shall provide a health-related fitness program with an annual assessment, an individual exercise prescription, certified peer fitness trainers and station equipment, on duty for career members and credited for volunteers. Accountable: {{Deputy Chief}}.

5.5.2 The fitness program shall be non-punitive: no assessment result shall be the basis for discipline or removal from duty, and individual results shall be held by the peer fitness trainer and the member, not the department.

5.5.3 Participation in the assessment should be mandatory from {{Stage 2 date}}, by agreement with the union and the association.

5.6.1 The department shall manage fatigue as a hazard through the limits and rules in Policy - Fatigue and Hours of Work and the program, including a maximum continuous duty period, minimum rest, post-incident rest, and sleep-disorder screening in the medical.

5.6.2 Any member may declare fatigue to their officer at any time; the officer shall reassign the member; no penalty shall follow. Accountable: every company officer.

5.7.1 The department shall operate a work disability management program aligned to CSA Z1011:20, with a named coordinator, first contact within three working days of a lost-time injury, a modified-duties list, and a written graduated plan, for physical and psychological injury alike. Accountable: {{Deputy Chief}} with corporate human resources.

5.8.1 The department shall offer the immunizations in the program schedule at department cost, shall assess vision and hearing in every medical, shall operate the Hearing Conservation Program, and shall provide health education and cessation and nutrition support.

5.9.1 Health information shall be held by the physician, clinic, assistance provider or peer fitness trainer as custodian. The department shall hold only fitness-for-duty determinations, restrictions, status flags, tracker dates, accommodation and return-to-work files held by human resources, and aggregate statistics at cell sizes of 10 or more. Accountable: {{Division Chief, Safety}}.

5.9.2 A written information-sharing protocol shall name what crosses from the custodian to the department: the determination and restrictions; imminent risk to the extent the law permits; and what the member consents to in writing.

5.9.3 Members shall have access to their own department records within 10 working days.

5.10.1 Rehabilitation shall be established at every incident and training evolution that meets the triggers in Firefighter Rehabilitation Program, with medical monitoring on entry and release, and no member shall self-release.

5.11.1 Every member is expected to speak up about their own or a colleague’s fitness for a task, and is protected from reprisal for doing so.

5.11.2 Information gathered in learning teams, after-action reviews, fatigue declarations and program evaluation shall not be used for discipline. Conduct concerns shall be handled by a separate process run by different people.

5.11.3 Any member’s concern about this policy or the program shall receive an answer within 10 working days through the route in the program.

Only the differences from 01 Roles and Responsibilities.

6.1 Fire chief: approves the essential job tasks and the physician agreement; owns the stigma around fitness and fatigue by example.

6.2 Deputy chief: accountable for completion rates, accommodation decisions, the fitness program, fatigue limits and return to work.

6.3 Program manager, Health, Wellness and Rehab team: runs the program, the tracker, the appraisal and the budget worksheet.

6.4 Fire department physician: evaluations, determinations, respirator clearance, return-to-work determinations, clinical advice to the team.

6.5 Health and safety officer: verifies the tracker and the custody of records; samples quarterly; maintains the information-sharing protocol.

6.6 Company officers: release members for evaluations; act on fatigue declarations and fitness concerns; first-level return-to-work contact.

6.7 Members: attend evaluations; take part in fitness; declare fatigue and unfitness; keep immunizations current.

6.8 Peer fitness trainers: assessments and prescriptions in confidence.

6.9 Corporate human resources: accommodation and return-to-work administration; custody of case files; compensation claims.

6.10 JOHSC: consulted on the program and every change; receives the aggregate report twice a year.

6.11 Union and volunteer association: consulted on the program; represent members in accommodation; partners in the fitness and wellness programs.

• Medical, Fitness and Wellness Program (with its toolkit: content table, clearance categories, essential job tasks, fitness protocol, accommodation workflow, return-to-work workflow, fatigue rules, vaccination schedule, confidentiality rules)
• Firefighter Rehabilitation Program and SWP - Rehabilitation at Incidents and Training
• Hearing Conservation Program
• Occupational Cancer Prevention, Exposure Tracking and Screening Program (medical surveillance link)
• Policy - Fatigue and Hours of Work
• Policy - Records, Privacy and Health Information
• Form - Annual Medical and Fitness Completion Tracker

8.1 Records the department holds: the tracker; determinations; restrictions; status flags; accommodation and return-to-work files (human resources); the physician agreement; aggregate reports.

8.2 Records the department does not hold: results, diagnoses, fitness scores, screen results.

8.3 Retention: duration of service plus 30 years for determinations and trackers (OSHA, n.d.-a, 29 C.F.R. § 1910.1020) as the benchmark; custodian records per the custodian’s rule.

8.4 Every record is written expecting access-to-information disclosure under the applicable municipal legislation (J10 Privacy and Health Information): roles, not names, in anything that leaves the file; health information is never in an operational file.

9.1 Quarterly: the program’s indicators to the senior leadership team and the JOHSC.

9.2 Twice a year: the aggregate wellness report to the JOHSC; annually to all members.

9.3 Annually: the program appraisal to the fire chief’s management review and, through the annual health and safety report, to council.

9.4 Immediately: any cardiac event on duty or within 24 hours, to the fire chief and the JOHSC co-chairs.

• The applicable occupational health and safety statute and regulations: employer duties and the written OHS program (J03 OHS Policy and Program); occupational exposure limits, which some jurisdictions adopt by reference to the ACGIH TLVs (ACGIH, n.d.) (J22 Exposure Limits, Heat and Cold Stress); and respiratory protection, including medical clearance (J14 Respiratory Protection, Fit Testing and Breathing Air).
• NFPA 1580 (2025): medical program, fitness, rehabilitation, infection control; NFPA 1550 (2024, ch. 13).
• CSA Z94.4-18: medical clearance for respirator use.
• CSA Z1011:20: work disability management; CSA Z1008:21: impairment.
• The Wellness-Fitness Initiative (IAFF & IAFC, 2018).
• The applicable human rights legislation and its duty to accommodate (J33 Return to Work, Accommodation and Hours of Work), and the BFOR test (British Columbia (Public Service Employee Relations Commission) v. BCGSEU, 1999).
• The applicable workers’ compensation legislation, including presumptions for heart injury, cancers and PTSD, the coverage of volunteers, and return-to-work duties (J11 Volunteer Firefighters; J32 Workers' Compensation and Firefighter Presumptions; J33 Return to Work, Accommodation and Hours of Work).
• The applicable personal health information and municipal privacy legislation (J10 Privacy and Health Information).

12.1 This policy is reviewed 12 months after adoption and then every three years; after any cardiac death or serious medical event on duty; after any change in the law or the standards; and at the JOHSC’s request.

12.2 Approved: {{Fire Chief}} (role), date. JOHSC consulted: date. Union and association consulted: date.

Consult early, in writing, and record the outcome. What they will ask, and honest answers:

Put the agreements in a letter of understanding; where you disagree, record it, adopt what you can, and review at 12 months. Volunteers and non-union staff need their own voice in the consultation.

Closing disclaimer. This model policy is general information prepared by The Human Factor for adaptation by the adopting department. It is not legal advice. The department remains responsible for compliance with the law that applies to it. Confirm every citation with counsel before adoption.

End of model policy.

This chapter relies on the following legal requirements, which differ by province and territory. Check your jurisdiction’s section on each topic page before adopting it.

British Columbia (Public Service Employee Relations Commission) v. BCGSEU, [1999] 3 S.C.R. 3 (Supreme Court of Canada).

American Conference of Governmental Industrial Hygienists [ACGIH]. (n.d.). Threshold limit values for chemical substances and physical agents and biological exposure indices (current edition).

Occupational Safety and Health Administration [OSHA]. (n.d.-a). Access to employee exposure and medical records (29 C.F.R. § 1910.1020). U.S. Department of Labor. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1020