Fire Management Requirements
This section presents requirements that must be met for all Conservancy wildland fire management activities. Requirements apply to wildfires and controlled burns and can only be exempted by the Fire Management Coordinator. All exemptions of requirements must be requested and granted in writing. See also Fire Management Guidelines for standards for Prescribed Burn operations.
If you have an unusual situation which does not conform to any of the typical fire management scenarios in which TNC becomes involved, contact the Fire Management Coordinator for individual consideration of the circumstances.
Modifications to training requirements, following similar NWCG measures, are found in the Personnel section of this manual. Additional PPE is required in Requirement #5 below. All Fire Management activities are currently (2020-2021) subject to screening and review by business units using the COVID-19 Checklist for Fire Management Activities. And the burn boss or lead of TNC personnel must complete daily the Fire COVID-19 Go No-Go Checklist.
All wildfires, regardless of origin, must be reported to the appropriate fire control agency. Responsibility for a wildfire must be turned over to fire control authorities, unless a mutual aid or other cooperative agreements have been established in writing.
A wildfire is defined as a fire, regardless of ignition source, which is unplanned, has escaped control, or is not authorized under state law or local ordinances. Your Review of Laws and Regulations should list appropriate fire control authorities and explain the authorization process. Under no circumstances should TNC make the decision to allow a wildfire to run its course.
On large remote landscapes, naturally ignited fire may be an important means of accomplishing resource management goals. There may be instances where naturally ignited fires can be managed for benefit on TNC lands, as long as they are burning within a pre-approved fire use or prescribed fire plan. These fires are subject to all TNC guidelines and requirements. This is most likely to be appropriate when TNC owns land near or within a large federal landholding. State laws governing prescribed burning will determine whether naturally-ignited fires on private land can be managed to meet ecological management goals on our property. In almost all instances, arson-ignited fires can not be managed for resource benefit and must be suppressed.
It is important to recognize TNC's responsibilities on different types of wildfires. Naturally-ignited wildfires are generally considered "acts of God," and the landowner of the property where the fire starts is usually not held responsible for any damage the fire may do to a neighbor's property. However, if the fire is not immediately reported, it may be claimed that failure to report aggravated the damages.
A Review of Laws and Regulations must be completed before any prescribed burns are conducted on Nature Conservancy property or led by Conservancy Representatives on non-Conservancy property.
The purpose of the Review of Laws and Regulations is to investigate and understand all the laws and statutes controlling wildland fire practices in the state and county in which burns are conducted. The Review is meant to ensure that Conservancy Representatives adhere to all applicable laws and regulations when engaged in wildland fire activities. See Fire Planning for specific guidance on this requirement. Documentation that the review has been completed is made through confirmation in the Prescribed Burn Unit Plan.
All prescribed burns, broadcast and non-broadcast, must be conducted according to a written approved plan. Use of daily Incident Action Plan (IAP) is encouraged. The IAP is subordinate to an approved Prescribed Burn Plan, and the IAP may not replace the use of a burn plan.
All burn plans must be signed and dated by the preparer and by the Fire Manager before the burn is conducted. The signature of the Fire Manager signifies his/her approval of the plan. See Burn Plan Review and Approval for more details.
Non-broadcast burning includes activities such as burning brush piles, old structures and spot burning invasives. All non-broadcast burns must meet state and local regulations and burn permit requirements. All non-broadcast burns must have a burn plan with a Consequence Analysis conducted as part of Fire Manager review and approval. Plan formats vary considerably. See the Format of the Non-broadcast Burn Plan for more details. All burns must be preceded by completion of the Non-broadcast Burn Go/No-go Checklist.
Only qualified personnel may participate in wildland fire management for the Conservancy. All wildland fire personnel must maintain written documentation of their training, experience and performance qualifications.
All individuals participating in wildland fire activities for the Conservancy must be at least 18 years of age and meet stated qualification criteria. All personnel must maintain documentation related to their training and experience, including copies of their training certificates, a log of their fire experience, and completed task books.
See Personnel for complete information on qualification standards, training and other administrative issues related to personnel.
All fire management personnel actively involved on a fire must wear fire-protective clothing 1, hard hat, leather gloves, fire/heat resistant boots 2, eye protection, and carry fire shelters. Personnel should be trained in the uses, advantages and drawbacks of their personal safety equipment. A first aid kit must be available on all controlled burns.
Additional COVID-19 PPE requirement
TNC fireline personnel must use facemasks or cloth face coverings made of natural or fire protective fibers. Face coverings must be worn properly at all times on the fireline and when in vehicles with others. Exceptions to wearing face coverings include when traveling alone in a vehicle, eating or drinking, and when working away from possible close-contact with others.
References. See Fire Shelters for exemptions to the use of fire shelters on controlled burns, and Burning After Dark regarding use of headlamps after dark. Chainsaw Operator provides chainsaw-specific PPE requirements. Occupational Safety and Health Administration (OSHA) specifies general requirements for PPE for fire work in the U.S.
1 Fire-protective clothing- Nomex style clothing is required for outwear (coveralls, shirts, pants or jackets) that may be exposed to lofted embers or direct flame impingement. Undergarments, including socks and t-shirts, should be similarly flame resistant or made predominantly of natural fibers such as cotton or wool.
2 Fire/heat resistant boots- A number of different boot types may meet this requirement, including heavy duty lace-type work boots with leather or leather/kevlar uppers and soles made of heat-resistant material such as Vibram. In some instances, such as when burning wetlands, fire-resistant rubber boots are permissible when noted in the Prescribed Burn Plan.
All Conservancy personnel actively involved on a wildland fire event (wildfire or prescribed fire, including pile burns) must be screened annually for physical fitness. All personnel must take part in annual fireline safety refresher training.
All personnel, staff and volunteers, must be screened annually for physical fitness using accepted testing methods to be considered "current" in position qualifications. The minimum level of required fitness varies among wildland fire positions as noted in the personnel section of this manual and in Wildland Fire Qualification System Guide PMS 310-1. Generally, fireline positions on wildfires require an arduous level of fitness and some prescribed burn positions require moderate fitness. As exception, Observer, Planner and Public Information Officer do not require fitness testing. The Fire Manager may require an increased level of fitness for any position on specific burns or sites, depending on factors such as topography, fuels or climate. See Physical Fitness Testing for a full discussion of fitness testing procedures.
All Conservancy fire management personnel must attend an annual safety refresher. It is the responsibility of the Fire Manager and Burn Boss to be sure this refresher takes place and all personnel participating in fire management have attended. See Annual Safety Refresher Guidelines for specific instructions.
All fire management related incidents must be reported as soon as possible, typically within 12-24 hours or less, to the Fire Manager, Fire Management Coordinator, program or project director, and assigned TNC attorney. Certain incidents must also be reported to TNC's Insurance Agent. A written report must be filed within four weeks of the incident, unless directed otherwise by the Fire Management Coordinator or TNC attorney.
Incidents to report include:
A review must take place following an injury requiring professional medical attention. The extent of the review is dependent on the seriousness of the events and the partners involved in the burn. It must be sufficient to identify the cause of the injury and whether steps must be taken to correct training or equipment procedures to prevent a similar accident from occurring in the future.
Any workplace injury that involves inpatient hospitalization, an amputation, or eye loss must be reported to OSHA within 24 hours. Also, a work-related fatality must be reported to OSHA within 8 hours. Reports can be made by phone to 1-800-321-OSHA (6742). More details can be found here. This does not replace the Worker's Compensation reporting process or requirement, which should also be done within 24 hours of a workplace injury.
TNC staff can reference Fire Incident Response Protocol (Internal Connect link) for guidance on dealing with Serious Incidents. Examples of Serious Incidents include: an injury resulting in admission to a hospital for something more than observation; suspected fatality; Fire Shelter deployment; property damage or operating loss initially estimated at $50,000 or more (damage value may be difficult to determine at the scene); situations which may receive significant negative attention by the public or media. Guidance has also been developed for TNC staff titled Fire Incident Response and the Role of the Attorney and for TNC Attorneys titled Evaluating and Addressing Liability Associated with Fire Incidents (Internal Connect link).
At the end of each year, each US state program is required to report Fire Management information to the Fire Management Coordinator for insurance reporting and tracking purposes.
This information must list each TNC burn by preserve or site, the date(s) of the burn, name of the Burn Boss for TNC-led burns, and other relevant information. Information includes all broadcast and non-broadcast burns conducted on TNC-owned lands, all burns led by TNC or our contractors on the lands of others, and all assists by TNC personnel on the burns of others. Wildfire occurring on TNC-owned lands must also be reported. This information is essential for tracking, planning, and training purposes, and is required by our insurance carrier to determine our insurance premium. Reporting is done here (Internal link) for each calendar year.
When burning on non-TNC land, the Conservancy must obtain in writing permission to enter the property and permission to burn the property.
Before burning on third-party land, our insurance carrier requires that we, at minimum, obtain in writing both permission to enter the property and permission to burn it. This must be accompanied by a map defining the burn area boundaries. This written permission may take the form of a document signed by the landowner, or it may be included in an MOU or other management agreement developed with a government entity. It is often advisable to seek other waivers of liability. See the Administration for Special Situations section of this Manual and the Special Situations, Section A (Internal Connect link) for more information on burning on non-TNC land, and permission to burn forms and waivers on the Legal Resources Fire Management Legal Resource (Internal Connect link) page.
Last updated September 3, 2020.
The Nature Conservancy is a nonprofit, tax-exempt charitable organization (tax identification number 53-0242652) under Section 501(c)(3) of the Internal Revenue Code. Donations are tax-deductible as allowed by law.