Policy - Risk Management and Hazard Assessment

Format. Adopt as a department policy. Together with the risk register it maintains, this policy is the department’s written risk management plan for the purposes of the fire service health and safety standard (NFPA 1550, 2024, ch. 6); say so in the adoption resolution so an assessor can find it.

Drafting conventions. Shall means mandatory. Should means expected unless a documented reason exists. May means permitted. Placeholders in double curly braces, such as {{Department}}, are completed by the department. Drafting notes sit in callouts and are removed before adoption.

Keep intact. The hierarchy of controls (5.2), the assessment-before-change rule (5.3), the incident risk management principles (5.4), management of change (5.5), and the four house principles. Adapt. The risk matrix and criteria (set in 03 Hazard Profile and Risk Register Method), the review intervals if the department’s call volume warrants shorter ones, and the role titles.

1.1 To require that {{Department}} knows its hazards before they hurt someone, assesses the risk by one method, controls it in hierarchy order, reassesses before anything changes, and manages the risk it cannot remove at incidents by stated principles.

1.2 To meet the hazard identification, assessment, inspection and control duties of the applicable statute, including any hazard identification system the written OHS program must contain (J03 OHS Policy and Program; J04 Hazard Assessment and Workplace Inspections), the planning clauses of the management-system standard (ISO 45001:2018, cl. 6.1.2 and 8.1.2), and the written risk management plan the fire service standard requires (NFPA 1550, 2024, ch. 6).

2.1 Applies to every hazard the department’s members face in routine work (stations, shops, training, administration), non-routine work (every incident type the department responds to), and emergency conditions in the department’s own workplaces (station fire, evacuation, member injury).

2.2 Applies to every module switched on in 01 Program Profile Worksheet and to every Conditional module at the awareness level.

2.3 Applies to every new or changed task, piece of equipment, protective equipment, apparatus, facility, procedure, service level or program, and to every contractor and mutual aid activity under department command.

2.4 Does not replace the community risk assessment and standards of cover the department prepares for planning and accreditation (CPSE, 2019, Category 2); it draws on them and feeds them.

Community risk assessment. The planning document that describes the risks in the community the department protects; distinct from the member-hazard profile, which this policy governs.

Hazard. A source with the potential to cause injury or ill health.

Hazard profile. The department’s structured inventory of hazards by work type, location, task and incident type, built by the method in 03 Hazard Profile and Risk Register Method.

Hierarchy of controls. Elimination, substitution, engineering controls, administrative controls, personal protective equipment, applied in that order (ISO 45001:2018, cl. 8.1.2).

Management of change. The documented process of assessing and controlling the hazards introduced by any change before the change takes effect (ISO 45001:2018, cl. 8.1.3).

Risk. The combination of the likelihood of harm and its severity.

Risk assessment. The process of estimating risk from a hazard, judging whether it is tolerable, and deciding on controls (CSA Z1002:12).

Risk register. The living record of assessed risks, their controls, their owners, their residual risk, and their review dates.

Risk management plan. The written plan the fire service standard requires, covering administration, facilities, training, vehicle operations, protective clothing and equipment, operations at emergency incidents, non-emergency activities, products of combustion and carcinogens, and related activities, with the components of identification, evaluation, prioritization, control and monitoring (NFPA 1550, 2024, ch. 6). This policy plus the risk register is that plan.

Work-as-done. How a task is really performed under the conditions present, as distinct from how a procedure imagines it (Hollnagel, 2014).

1. People are the solution we build around, not the problem to fix. The members who do a task know its hazards best; every hazard assessment starts by asking them.

2. Procedures describe work as done, written with the people who do it. A control that cannot be used under real conditions is not a control; the department writes controls that fit the work.

3. Learning comes before blame, and learning information is never used for discipline. Near misses, good catches and adaptations are the cheapest hazard data the department has, and it protects the people who supply them.

4. Psychological safety is a condition of safety, so speaking up is expected and protected. A member who sees a hazard says so, and the officer acts.

5. Eliminate first. The department does not accept a hazard that can be removed, and does not substitute a protective equipment requirement for a control higher in the hierarchy where that control is practicable.

6. One method, everywhere. Every hazard in the department is assessed by the same method and on the same scale, so that risks can be compared and priorities set across programs.

7. Assess before you change. No new task, equipment, procedure, service or facility goes into use before its hazards are assessed and the controls are in place and trained.

8. Risk is managed at incidents, not accepted. Members take a calculated risk to protect savable lives, a smaller risk to protect savable property, and no risk to protect what is already lost (NFPA 1550, 2024, ch. 10; IAFC, 2010).

9. Psychosocial hazards are hazards. They are identified, assessed and controlled by the same method (CSA Z1003-13).

5.1.1 The department shall maintain a hazard profile and a risk register covering routine, non-routine and emergency work, by the method in 03 Hazard Profile and Risk Register Method (CSA Z1002:12; ISO 45001:2018, cl. 6.1.2). Accountable: {{Division Chief, Safety}}.

5.1.2 Each program’s hazards shall be assessed by that program’s Program Improvement Team or named officer, starting from a learning-team description of work-as-done, and recorded in the register with the program manager as the risk owner. Accountable: program managers.

5.1.3 The register shall record, for each risk: the hazard; the task, location or incident type; who is exposed; the likelihood and severity scores and the resulting rating; the existing controls by hierarchy level; the residual risk; further controls required, each with an owner, a priority on the department’s one scale from P1 (Imminent) to P4 (Improvement), and the due date that priority sets in the Corrective Action Register; the review date; and the evidence (incident, near-miss and exposure data, standards, learning-team findings). Accountable: {{Health and Safety Officer}}.

5.1.4 The register shall be reviewed at least annually with each program’s appraisal; after any Tier 2 or Tier 3 learning review; after any change under 5.5; when the Profile Worksheet changes; and when new evidence (an investigation report from another jurisdiction, a research finding, a regulator bulletin) bears on a hazard the department faces. Accountable: program managers; {{Division Chief, Safety}} for the schedule.

5.1.5 The register’s highest-rated risks, and the status of their controls, shall be a standing input to the management review and an item in the annual report to council. Accountable: {{Fire Chief}}.

5.1.6 Hazards reported by members through the reporting system, by the JOHSC through inspections, and by the audit shall be entered in the register and the Corrective Action Register within five working days. Accountable: {{Health and Safety Officer}}.

5.2.1 Controls shall be selected in the order elimination, substitution, engineering, administrative, personal protective equipment (ISO 45001:2018, cl. 8.1.2; CSA Z1002:12). Where a control lower in the hierarchy is chosen while a higher one is practicable, the reason shall be recorded in the register. Accountable: program managers.

5.2.2 Personal protective equipment shall never be the only control for a hazard that can be reduced at a higher level, and shall be selected, issued, maintained and used under Protective Clothing and Equipment Program and Respiratory Protection Program. Accountable: program managers.

5.2.3 Where the department declares a service (for example technical rescue, water rescue, wildland deployment), it shall first put in place the training, equipment, staffing and procedures the hazard assessment requires, and shall not deploy members to a task they are not trained and equipped for. Where a Conditional module applies, the department shall have at minimum a written stand-off and awareness-level procedure. Accountable: {{Deputy Chief}}; each incident commander at the scene.

5.3.1 Before any new task, service, procedure, piece of equipment, apparatus, facility, protective equipment item or program is put into use, the owning program shall complete a risk assessment by the method in 5.1 and record it in the register. Accountable: program managers.

5.3.2 The assessment shall include a learning-team session with the members who will do the work, a review of standards and law through 02 Standards and Law Master Map, a review of the evidence (investigation reports, research, field trial results), and the JOHSC standing consultant’s input. Accountable: team leads.

5.3.3 Where the item is safety-sensitive, the recommendation shall go to formal JOHSC consultation before adoption, with the assessment attached. The applicable regulation may also require the committee to be consulted whenever a written policy, procedure or plan is established or reviewed (J05 Joint Committee and Health and Safety Representative; J06 Written Procedures and Committee Consultation). Accountable: program managers.

5.3.4 Equipment, PPE and apparatus enter service only through the Equipment Standards, Apparatus and PPE team gate in 06 Program Improvement Teams section 7. Accountable: Equipment Standards program manager.

5.4.1 The incident commander shall manage risk at every incident by the department’s stated principles: a calculated and controlled risk to protect savable lives; a smaller, controlled risk to protect savable property; no risk to members to protect lives or property that are already lost (NFPA 1550, 2024, ch. 10; IAFC, 2010). Accountable: each incident commander.

5.4.2 Every incident commander shall perform and record a size-up and risk assessment, including a 360-degree view or a stated reason it could not be done, before committing members to an interior or hazardous position, and shall reassess at every benchmark and whenever conditions change. Inadequate risk assessment is one of the five contributing factors the fire service has distilled from NIOSH’s investigations of structural firefighter deaths (Fire Engineering, 2023; NIOSH, n.d.-b). Accountable: each incident commander.

5.4.3 The department shall operate an incident management system with personnel accountability, two-in/two-out, rapid intervention, air management, hazard control zones, rehabilitation and an incident safety officer assigned by stated triggers, as set out in Emergency Operations Safety Program (NFPA 1550, 2024, ch. 10, 17 to 21; CPSE, 2019, criteria 11A.8, 11A.11, 11A.12). Accountable: {{Deputy Chief}} through the program manager.

5.4.4 The incident safety officer has the authority to alter, suspend or terminate any activity that presents an imminent hazard; the incident commander is informed immediately. Accountable: the incident safety officer.

5.4.5 Risk decisions at incidents shall be reviewed afterward for the quality of the decision with the information available, not for the outcome, through the learning system in Incident Investigation and Learning Program. Accountable: {{Division Chief, Safety}}.

5.4.6 Where the effective response force for the strategy chosen is not on scene, the default is defensive until it is (CPSE, 2019, criterion 2C.4). Accountable: each incident commander.

5.5.1 Any change to a task, procedure, service level, staffing model, apparatus, equipment, PPE, facility, substance, supplier, contractor, software that affects operations, or organizational structure shall go through the management of change process before it takes effect (ISO 45001:2018, cl. 8.1.3; ICAO, 2016, Annex 19). Accountable: the change initiator’s program manager.

5.5.2 The process shall use Form - Management of Change Checklist and shall cover: what is changing and why; who is affected; the hazards the change introduces, removes or alters; the risk assessment and controls; the procedures and training that must change; the JOHSC consultation where safety-sensitive; the communication to members; the date the change takes effect; and the review date to confirm the change works as done. Accountable: program managers.

5.5.3 Temporary changes (a trial, an apparatus out of service, a station closure, a seasonal deployment) shall go through the same process with an end date. Accountable: program managers.

5.5.4 Emerging hazards (for example lithium-ion batteries, energy storage systems, electric vehicles, solar arrays, hydrogen, new building methods, new substances) shall be scanned for at least annually by the hazardous materials and emergency operations programs, and a procedure and training issued within a target the register sets, so that new hazards do not outrun doctrine (NFFF, 2025b). Accountable: the relevant program managers.

5.6.1 Every Tier 2 and Tier 3 learning review, every regulator order, and every near miss with serious potential shall trigger a review of the register entries it touches. Accountable: {{Division Chief, Safety}}.

5.6.2 Lessons from other jurisdictions’ investigation reports shall be reviewed quarterly by the safety division and brought to the relevant team where they bear on a hazard the department faces. Accountable: {{Health and Safety Officer}}.

Only the differences from 01 Roles and Responsibilities are stated here.

6.1 Senior officer responsible for health and safety. Owns the method, the register’s integrity and the schedule; reports the top risks.

6.2 Program managers. Own the risks in their program; complete assessments before change; keep register entries current.

6.3 Team leads and members. Run the learning-team sessions; draft the assessments; feed near-miss and adaptation data.

6.4 Incident commanders. Apply 5.4 at every incident; record the size-up and risk assessment.

6.5 Incident safety officer. Monitors and intervenes under 5.4.4; feeds observations to the register.

6.6 Equipment Standards team. Gate for equipment, PPE and apparatus changes.

6.7 JOHSC. Standing consultant to each assessment; formal consultation on safety-sensitive changes; reviews the register annually.

6.8 Members. Report hazards and near misses; take part in learning teams.

03 Hazard Profile and Risk Register Method; Emergency Operations Safety Program; Incident Investigation and Learning Program; Workplace Inspections Program; Hazardous Materials, CBRN and Energy Hazards Program; every program module, which carries its own hazard assessment; Form - Management of Change Checklist; Corrective Action Register.

8.1 Records: the hazard profile; the risk register with its version history; each risk assessment and its learning-team summary (no names); management of change records; incident size-up and risk assessment records (in the incident report); JOHSC consultation records.

8.2 All records are written for disclosure under municipal freedom-of-information law and identify people by role. Learning-team write-ups name no individuals. Governed by Policy - Records, Privacy and Health Information.

8.3 Retention: the register and its versions for the life of the program; individual assessments for at least any period the applicable law sets and while the hazard exists (J09 Records Retention; see 05 Document Control and Records).

• The applicable OHS statute and regulations, which differ by province and territory: the duty to identify and assess hazards and to inspect the workplace on a schedule, and any hazard identification system the written OHS program must contain (J03 OHS Policy and Program; J04 Hazard Assessment and Workplace Inspections); the employer’s general duty to take every reasonable precaution, to make hazards known and to train, which carries the hazards no regulation names (J02 Duties of Employers, Supervisors, Workers and Contractors); written procedures kept adequate and updated when conditions change, and the duty to consult the committee on them (J05 Joint Committee and Health and Safety Representative; J06 Written Procedures and Committee Consultation); equipment inspection by the user and by a competent person, and its records (J15 Equipment Inspection, Ladders and Aerial Devices); any workplace violence risk assessment (J26 Workplace Violence); and whether any law prescribes firefighter training or certification, failing which the training standard the department declares is the one its general duty is measured against (J34 Fire Services Legislation and Firefighter Certification). The Jurisdiction requirements table at the end of this policy lists what to confirm for your province or territory.
• Hazard identification and assessment of risks, hierarchy of controls, management of change, procurement and contractors (ISO 45001:2018, cl. 6.1.2, 8.1.2, 8.1.3, 8.1.4; CSA Z45001:19).
• The Canadian method for hazard identification, elimination, risk assessment and control (CSA Z1002:12).
• The written risk management plan and its scope and components; risk management during emergency operations; the incident safety officer (NFPA 1550, 2024, ch. 6, 10, 5).
• Risk management as a safety management system component, scaled to the organization (ICAO, 2016, Annex 19).
• The rules of engagement for structural firefighting (IAFC, 2010).
• The CPSE/CFAI accreditation path: documented steps to reduce risk and address hazards (CPSE, 2019, criterion 11A.3); policies for reporting, evaluating and communicating hazards (11A.2); risk management practices in emergency operations (11A.8); incident safety officer deployment (11A.11); personnel accountability (11A.12); critical task analysis and effective response force (Category 2, 2C.4).

12.1 Reviewed 12 months after adoption, then every three years; after any Tier 3 learning review; after any change to the statute or to the fire service standard; and on JOHSC request.

12.2 The register itself is reviewed on the schedule in 5.1.4 and is not waiting for the policy review.

Put the consultation in writing. Record disagreement, adopt what can be adopted, revisit at 12 months.

Closing disclaimer. This model policy is general information prepared by The Human Factor for licensed use by {{Department}}. It is not legal advice. Confirm every statutory reference with counsel before adoption.

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.

National Institute for Occupational Safety and Health [NIOSH]. (n.d.-b). Fire Fighter Fatality Investigation and Prevention Program [Program website and investigation reports]. Centers for Disease Control and Prevention. https://www.cdc.gov/niosh/firefighters/fffipp/index.html