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Pre-Incident Plan Interval: Which Rule Controls

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Pre-Incident Plan Interval: Which Rule Controls

Your station received this excerpt from the department's pre-incident planning SOP:

4.2 Company officers shall review the pre-incident plan of every occupancy classified high-hazard at least annually. 4.3 Occupancies storing more than 500 gallons of flammable liquid shall be reviewed at intervals not exceeding six months. 4.4 Where 4.2 and 4.3 both apply to the same occupancy, the shorter interval governs. 5.1 A newly constructed occupancy shall receive an initial review within 30 days of its certificate of occupancy, and that review satisfies the first annual requirement.

Ridgeline Warehouse received its certificate of occupancy on March 3. It stores 800 gallons of flammable liquid and is classified high-hazard. Your crew's only documented review was completed on April 2. Today is March 1 of the following year.

1. Is the company in compliance today? Identify which sections control and support your answer with dates.

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No - the company is out of compliance.

  1. 4.2 applies: the occupancy is classified high-hazard, so an annual review is required.
  2. 4.3 also applies: 800 gallons exceeds the 500-gallon threshold, so the maximum interval is six months.
  3. 4.4 breaks the tie: both apply, so the shorter interval - six months - controls. The annual requirement is a floor, not the governing deadline.
  4. 5.1 sets the clock: March 3 to April 2 is 30 days, so the April 2 review was timely and counts as the initial review / first annual.
  5. Deadline: six months from April 2 is October 2. Today is March 1, roughly five months past due.

Note the trap: the crew did 'the annual,' and under 4.2 alone they would still have until April 2. Section 4.4 makes that reasoning wrong.

2. A firefighter says, 'We did the annual in April, so we're good until April.' How do you respond, and what do you do this shift?

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Response: acknowledge the reasoning is not careless - it is the 4.2 answer - then show why 4.4 changes it. The flammable-liquid quantity pulls the occupancy into 4.3, and 4.4 says the shorter interval governs. 'Annual' is the minimum everywhere; here the minimum is six months.

Actions this shift:

  • Notify the battalion chief in writing that the plan is overdue, with the dates.
  • Schedule the review before end of shift if staffing allows, or the next business day.
  • Document why the lapse happened (the calendar likely carried only one date).
  • Fix the system, not just the file: enter both a six-month and an annual tickler, and add a field for stored quantity so a change in quantity triggers a reclassification.
  • Re-verify the 800-gallon figure on arrival - the interval depends on a number nobody has checked in a year.

3. In June the tenant reports that flammable-liquid storage has been reduced to 300 gallons; the building remains high-hazard for other reasons. What interval applies going forward, and when is the next review due?

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Interval: 4.3 no longer triggers because 300 gallons is below the 500-gallon threshold. Only 4.2 applies, so the interval returns to annual.

Next due date: the April 2 review is still the most recent qualifying annual review, so under 4.2 the next one is due the following April 2. The October date existed only because of the flammable-liquid condition, and that condition has ended.

Judgment to state explicitly: the SOP is silent on a mid-cycle reduction, so this is an interpretation, not a certainty.

  • Get the reduction in writing from the tenant and verify it with a walk-through rather than accepting the report.
  • Confirm the interpretation with the training/safety office and get an answer in writing.
  • The conservative option is to keep the October review once, then drop to annual. Either way, never let the file show an unexplained gap - document the decision and the reasoning.