EMSI routinely receives questions seeking an advanced explanation of an emergency management or incident management concept. Recently we received a question regarding a Safety Officer’s “stop work” authority under ICS. This is a thought provoking question and we thought we would share the answer with our followers. If you have a question and want to Ask an Expert, please contact us at firstname.lastname@example.org.
Question: “it looks like the Safety Advisor…has the specific power to ‘stop work’ at an incident. I’m curious to know where this ‘stop work’ power originates from. Is it something outlined in… legislation or something that ICS/fire agencies stipulate as part of ICS/ at the agency/department level?”
Before we answer this question, we want to first explain the intended role of Command Staff Officers. Under ICS, the term “Officer” (e.g., Command Staff Officer) is a specific term for those who are directly delegated areas of responsibility that specifically reside with, or are specifically vested in, the Incident Commander. Once clear direction is provided, the Incident Commander delegates the accomplishment of these tasks to Officers on the Command Staff. Traditionally, these areas of responsibility have been safety, liaison and external coordination, and public information, hence the three original Command Staff positions of Safety Officer, Liaison Officer, and Public Information Officer.
Based on this, it is safe to assume that the Safety Officer derives their “stop work” authority from the Incident Commander. As the individual (or individuals when in Unified Command) delegated authority by an agency/company executive to command and manage the incident, when operating under ICS, safety and “stop work” are inherent and assumed responsibilities of the Incident Commander, further delegated to the Safety Officer. Further discussion of stop work authority can be found in an earlier EMSI blog post at http://www.emsics.com/single-post/2010/12/1/The-Stop-Work-Authority. To clear any doubt, it is recommended that SOFRs seek clarity on this authority during their in-brief to an incident.
Most Safety Officers are judicious in applying the “stop work” authority and will only stop work if it is absolutely critical. Unless it is a very small incident, a “stop work” is not typically an “incident-wide” work stoppage, but instead isolated to a specific task or assignment (think Division or Group, or possibly even only a small component of a Division or Group). Only under the most extreme of circumstances will work be stopped by the Safety Officer (or possibly an Assistant Safety Officer) without first consulting with the supervisor for the task of concern and trying to find a safer alternative.
The Safety Officer must consider the Incident Commander’s intent and priorities, as well as what the Incident Commander approved as part of the Incident Action Plan. Unfortunately, sometimes as responders, we adhere to the adage “risk a lot to save a lot”. Perhaps the Incident Commander was briefed on the risk associated with the activity and approved it anyways. Most Incident Commanders will include any “stop work” directive a critical information reporting requirement and will want to know about it immediately.
Unless the response is governed by a specific law or statute (e.g., OSHA’s Hazardous Waste Operations and Emergency Response standard [1910.120(q)(3)(vii)]), this authority to stop work is not codified anywhere, except in ICS doctrine. As users of ICS, we assume that this authority rests with the Incident Commander and we also assume that if they delegate it to a Safety Officer (or further delegate to Assistant Safety Officers) that those individuals are not only fully trained and qualified in ICS, but they are also health and safety experts with emergency response experience. We wouldn’t want a safety professional without ICS experience performing this function, nor would we necessarily want an industrial health and safety expert with no emergency response experience, and thus a low or unrealistic expectation for risk in the response environment. There are always tradeoffs required during any incident response that must be decided by the Incident Commander/Unified Command, but hopefully, these decisions are made in consultation with the Safety Officer to ensure we do more good than harm.