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COVID-19: FS' Wildland Fire Response Plans — Engagement 08025-0001-41, August 14, 2020

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Office of Inspector General, U.S. Department of Agriculture, memorandum dated August 14, 2020, engagement number 08025-0001-41, on COVID-19: FS' Wildland Fire Response Plans, addressed to Vicki Christiansen, Chief of the Forest Service, from Gil H. Harden, Assistant Inspector General for Audit. It provides OIG's comments on the Wildland Fire Response Plans (WFRPs) developed to more safely and effectively combat wildland fires during the pandemic. Among its observations, it states that none of the WFRPs required personnel assigned to a fire to be tested for COVID-19, and none contained a contingency plan for an outbreak in the fire camp. It also states that the memorandum was not intended as an audit or inspection product.

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Covid19 Fs Wildland Fire Response Plans
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Covid19 Fs Wildland Fire Response Plans

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“COVID-19: FS' Wildland Fire Response Plans — Engagement 08025-0001-41, August 14, 2020.” Original at usdaoig.oversight.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/covid19-fs-wildland-fire-response-plans/, SHA-256 025454cea7fc62294fd1a89e14ced76ef49a38def4503de388b922a0c8847bde.

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     United States Department of Agriculture




COVID-19: FS' Wildland Fire
Response Plans




Engagement 08025-0001-41
August 2020
                                               OFFICE OF INSPECTOR GENERAL
                               United States Department of Agriculture
                                       Office of Inspector General
                                         Washington, D.C. 20250



DATE:            August 14, 2020

ENGAGEMENT
NUMBER: 08025-0001-41

TO:              Vicki Christiansen
                 Chief
                 Forest Service

ATTN:            Antoine Dixon
                 Chief Financial Officer
                 Forest Service

FROM:            Gil H. Harden
                 Assistant Inspector General for Audit

SUBJECT:         COVID-19: FS’ Wildland Fire Response Plans


The purpose of this memorandum is to provide the Office of Inspector General’s (OIG) comments
on the Wildland Fire Response Plans (WFRP) that were developed in order to more safely and
effectively combat wildland fires during the coronavirus (COVID-19) pandemic. 1 The WFRPs
were developed under the direction of the National Multi-Agency Coordinating Group, which
includes the Forest Service (FS), as well as other Federal, State, and local wildland fire agencies.
The impacts of the COVID-19 pandemic will likely cause wildland firefighting challenges across
the wildland fire community, potentially causing the 2020 wildfire season to be one of the most
dangerous in years.

We recognize that the WFRPs are subject to change based on the experiences and best practices
that are shared within the firefighting community as the fire season continues in light of the
COVID-19 pandemic. We also recognize that the plans were not intended to be overly
prescriptive and that no one wildland fire agency, including FS, can dictate changes to the
WFRPs. However, we identified certain processes and procedures that, if uniformly followed
throughout all of the geographic areas, could enhance not only FS’ ability to more safely and
effectively combat wildland fires during the COVID-19 pandemic, but also other Federal, State,
and local wildland fire agencies utilizing the WFRPs.

1
 This memorandum was not intended as an audit or inspection product and was not developed in accordance with
generally accepted government auditing and inspections standards. Due to the pending wildfire season, we felt the
message required a quick response and, therefore, this message contains suggestions based on analysis of publicly
available information.
Vicki Christiansen                                                                                               2

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) provided more than
$70 million in funding to FS to assist with relief efforts for various programs identified within
the agency. 2 Included in the funding was $7 million for Wildland Fire Management to prevent,
prepare for, and respond to COVID-19, including for personal protective equipment and baseline
health testing for first responders. The CARES Act also included funding for OIG to provide
oversight of agencies and specific programs that received funding under the CARES Act.

As part of our oversight of FS’ CARES Act activities, we reviewed the WFRPs for the following
10 geographic areas: (1) Northwest; (2) Northern California; (3) Southern California; (4) Alaska;
(5) Great Basin; (6) Northern Rockies; (7) Rocky Mountains; (8) Southwest; (9) Southern; and
(10) Eastern. The reviewed WFRPs were completed in May 2020 and are currently accessible to
the public on the following website: https://www.nifc.gov/fireInfo/covid-19.htm.

In reviewing these plans, OIG also considered guidance issued by various health organizations,
including the Centers for Disease Control and Prevention (CDC), the Occupational Safety and
Health Administration, and the World Health Organization. 3 Additionally, while frameworks for
reopening facilities may not have a direct correlation because of the nature of fire operations and
first responders, we also considered publicly available information from both the USDA
Reopening Playbook and the USDA COVID-19 Playbook to determine if fundamentals
prescribed in the guidance would enhance the protocols for wildfire response during the
COVID-19 pandemic. 4, 5

The following are our observations and/or suggestions regarding the WFRPs we reviewed:

    1. None of the WFRPs required personnel assigned to a fire to be tested for COVID-19.
       The WFRPs did mention acquiring testing kits when available; however, the plans did not
       provide any detail on how FS planned on acquiring and implementing the tests. To help
       ensure the health and safety of all personnel assigned to a fire and to reduce the risk of an
       outbreak, we believe it prudent that FS test all personnel before they are mobilized on the
       fire and specify in the WFRPs their plans for testing. Testing all personnel prior to a fire
       assignment could provide FS with increased assurance that fire staff are less likely to
       have contracted COVID-19 prior to the fire assignment.

        Lawmakers also recognized the importance of testing fire personnel. On June 9, 2020,
        the Senate Committee on Energy and Natural Resources held a hearing on wildland fire

2
  Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136 (2020).
3
  In reviewing the WFRPs, we did not employ the use of any medical or emergency management specialists, nor are
we those specialists. In reviewing the information in the WFRPS, we relied on the guidance issued by these various
health organizations, as well as the National Wildfire Coordinating Group’s (NWCG) Infectious Disease Guidance
for Wildland Fire Incidents.
4
  Summary USDA Reopening Playbook. The Summary USDA Reopening Playbook is publicly available on the
following website: https://www.usda.gov/sites/default/files/documents/summary-usda-reopening-playbook.pdf.
5
  USDA COVID-19 Playbook, Version 2.0, Supplement to Pandemic Plans, Occupant Emergency Plans &
Continuity of Operations Plan, effective March 19, 2020. The USDA COVID-19 Playbook is publicly available on
the following website: https://www.usda.gov/sites/default/files/documents/COVID19%20Playbook.pdf.
Vicki Christiansen                                                                                            3
         management in the midst of the COVID-19 pandemic. During the hearing, FS testified
         that it was not requiring fire personnel to be tested for COVID-19 prior to being
         mobilized on a fire. Prior to the hearing, Senators Joe Manchin and Tom Udall
         introduced the COVID-19 as a Presumptive Disease in Wildland Firefighters Act to
         protect Federal firefighters in the midst of the COVID-19 pandemic. 6 The Act would
         require all firefighters to be tested for COVID-19 before the beginning of fire season or
         before firefighters perform any work as a firefighter during the fire season.

    2. None of the WFRPs included asking fire personnel assigned to a fire about their recent
       travel. All of the WFRPs included the Wildland Fire COVID-19 Screening Tool, which
       includes questions about fevers, chills, muscle aches, and a new loss of taste and/or smell.
       Asking specific questions to identify where fire personnel traveled before being
       mobilized on the fire, or if the fire personnel was in contact with others who may have
       traveled, is also critically important for fire managers to know because of the increase of
       COVID-19 cases in certain areas of the country and around the world. We suggest
       referring to Attachment B of the USDA COVID-19 Playbook to enhance the WFRP
       protocols. 7

    3.   None of the WFRPs contained a contingency plan should there be an outbreak within the
         fire camp where several fire personnel become infected with COVID-19 that causes a
         significant reduction in the available number of fire personnel needed to combat the fire.
         The plans only recommended that fire managers consider how they would be affected by
         a reduction in available resources. We believe that a contingency plan is critical for
         ensuring that FS is adequately prepared to compensate for the loss of firefighting
         personnel in order to continue its efforts in combating the wildfire, while at the same
         time containing the spread of COVID-19.

    4.   None of the WFRPs contained a contingency plan for aerial resources should they also
         be impacted by a COVID-19 outbreak. Several of the WFRPs only referenced using the
         National Guard’s aerial resources. We believe that a contingency plan for aerial
         resources is also critical for ensuring that FS is adequately prepared to compensate for
         the loss of these resources in order to continue its efforts in effectively combating
         wildfires.

    5.   None of the WFRPs provided guidance on notifying the Geographic Area Coordination
         Center (GACC) if there is an outbreak, along with any adjustments that would need to be
         made to firefighting operations, such as the demobilization and reassignment of

6
  COVID–19 as a Presumptive Disease in Wildland Firefighters Act, 116th Cong. § 2 (2020) (unpublished U.S.
Senate bill).
7
  The following is one of the screening questions asked in Attachment B of the USDA COVID-19 Playbook: In the
last 14 days, have you or someone living in your household, or someone with you have been in close or frequent
contact with, or someone you are caring for returned from, or made a travel connection through a CDC Level 3 or
Level 2 country, or State Department Level 3 or Level 4 country, for example China, Korea, Japan, the European
Union, Iran?
Vicki Christiansen                                                                                                        4
          firefighting personnel working on a fire. Most of the WFRPs did provide a link to
          NWCG’s Infectious Disease Guidance for Wildland Fire Incidents, which contained the
          protocol for notifying the GACC of the outbreak. However, given the importance of the
          guidance, the WFRPs should more fully address it in the plan, as well as include it as an
          appendix, so that it is more readily available when needed on a fire incident.

    6.    None of the WFRPs adequately addressed what FS would do if it encountered personal
          protective equipment (PPE) shortages during a wildfire. Although the WFRPs did not
          specify how they would handle PPE shortages, some of the WFRPs did suggest, as a best
          business practice, that personnel working on a fire bring their own PPE to supplement
          that provided at the fire incident. The Summary USDA Reopening Playbook states that
          mission areas and agencies (such as FS) should plan on providing face covering or
          masks to all “onsite” employees throughout the facility reopening process. Considering
          the importance of PPE in protecting FS personnel from COVID-19 while working under
          any condition and in any location, all of the WFRPs should fully address how they will
          effectively deal with potential PPE shortages.

    7.    None of the WFRPs required the medical units assigned to the fire to ensure they had
          sufficient supplies of infectious disease barrier kits. 8 These kits are instrumental to the
          medical units and other support staff in screening and treating symptomatic fire
          personnel and sanitizing areas that may have been affected by COVID-19. Most of the
          WFRPs did provide a link to NWCG’s Infectious Disease Guidance for Wildland Fire
          Incidents, which stated the need for the incident medical unit leaders to determine the
          minimum number of kits needed for a fire. However, given the importance of the
          guidance, the WFRPs should more fully address it in the plan, as well as include it as an
          appendix, so that it is more readily available when needed on a fire incident.

    8.    None of the WFRPs specifically addressed the protocols for quarantining and isolating
          symptomatic fire personnel. Most of the WFRPs did provide a link to NWCG’s
          Infectious Disease Guidance for Wildland Fire Incidents, which does provide detailed
          protocols on how to quarantine and isolate symptomatic fire personnel. However, given
          the importance of the guidance, the WFRPs should more fully address it in the plan, as
          well as include it as an appendix, so that it is more readily available when needed on a
          fire incident.

    9.    While all of the WFRPs mentioned contact tracing as a best business practice, none of
          the WFRPs contained sufficient detail regarding how contact tracing would be
          administered for those symptomatic fire personnel placed in quarantine or isolation.
          According to CDC, contact tracing is a core control measure to prevent further
          transmission of the disease. 9 More specific information is needed for administering
          contact tracing at a fire incident. Examples of questions that could be adapted for WFRP

8
  Infectious disease barrier kits are designed for medical units to have on hand in order to assist in the treatment of
symptomatic fire personnel. The kits contain protective clothing, gloves, glasses, shoe and boot covers, and a four
to six gallon biohazard bag,
9
  Contract Tracing – CDC’s Role and Approach.
Vicki Christiansen                                                                                    5
         purposes can be found in Attachment A of the USDA COVID-19 Playbook. 10 At a
         minimum, answers to questions such as these could allow for immediate actions to reduce
         spread within the fire camp.

     10. Several of the WFRPs did not require separate medical stations for COVID-19. Some of
         the WFRPs made reference to having more than one medical station, but several of the
         WFRPs did not require the fire camp to have separate COVID-19 related medical
         stations. CDC guidance states that medical facilities consider designating a separate area
         such as an ancillary building or temporary structure or nearby location as an evaluation
         area where patients with symptoms of COVID-19 can seek evaluation and care.

     11. None of the WFRPs designated an overall coordinator within the incident command
         structure to address COVID-19 related issues. Most plans delegated this responsibility
         to the various incident management team units (for example, Medical, Facilities, Fire
         Information and Safety). As outlined in the USDA COVID-19 Playbook, a Pandemic
         Coordinator helps ensure that all COVID-19 related issues are adequately, timely, and
         consistently addressed. Designating an overall coordinator could greatly enhance
         addressing COVID-19 related issues during a fire incident.

     12. Most of the WFRPs did not specifically require sanitization stations within the fire
         camps. The plans only stated that they consider additional sanitary facilities to
         accommodate personnel cleanliness. The Summary USDA Reopening Playbook states
         that mission areas and agencies (such as FS) will take into account a facility’s plans to
         ensure sufficient social hygiene practices are in place to protect employees and
         contractors by adhering to CDC Guidance on proper hygiene. As with USDA facilities,
         to avoid transmission of COVID-19, the WFRPs should require that the appropriate
         number of sanitary stations be established within the fire camps based on their size and
         the number of personnel working in the fire camps.

     13. While all of the WFRPs mentioned social distancing of six feet, none of the WFRPs
         recommended holding necessary meetings outside. CDC determined that large
         gatherings in enclosed areas increase the risk of transmission of COVID-19. Holding
         meetings outside to the extent possible while still maintaining social distancing of six
         feet and wearing face coverings could significantly reduce the risk of transmission.

We trust that this information is helpful to you as FS enters the 2020 wildfire season. We
appreciate the opportunity to review and comment on the WFRPs and have attached, in its
entirety, the agency’s response to the memorandum. This memorandum contains publicly
available information and will be posted in its entirety to our website (http://www.usda.gov/oig).




10
  Attachment A of the USDA COVID-19 Playbook, Interview of an Employee or Visitor at USDA Who Tests
Positive for COVID-19.
Logo     Department                      Organization Information                     Organization Address Information
         Forest Service                  Washington Office                            1400 Independence Avenue, SW
                                                                                      Washington, D.C. 20250




       File Code:     1430                                          Date:     August 4, 2020
       Route To:

         Subject:     Forest Service Response to OIG Review of Wildland Fire Response Plans

              To:     Gil H. Harden, Assistant Inspector General for Audit, Office of Inspector
                      General



       Thank you for the opportunity to review and comment on the memorandum containing Office of
       Inspector General’s (OIG’s) comments on the Wildland Fire Response Plans, which the
       U.S. Department of Agriculture’s Forest Service participated in developing. The Wildland Fire
       Response Plans were initiated under the direction of the National Multi-Agency Coordinating
       Group to more safely and effectively combat wildland fires during the coronavirus (COVID-19)
       pandemic. Subject matter experts organized into three national area command teams and one
       geographic area incident management team and developed the plans over a several week period.

       This year, more than ever, requires constant assessment, learning and adaptation in the wildland
       fire environment. The Forest Service is a learning organization and to that end we are updating
       processes and protocols in real time as new information and best practices emerge. We are
       listening to firefighters on the ground, fire leaders in our agency, and our partner agencies. We
       conduct focus groups each week; use rapid After Action Reviews; and share Lessons Learned.
       We intend to continue making adjustments as needed throughout the remainder of the fire year.
       This OIG review will help us do that, and the Forest Service supports the recommendations and
       appreciates the time and effort that went into the OIG memorandum.

       The ten interagency Geographic Area Coordinating Groups have adopted their respective
       Wildland Fire Response Plans. They have directed incident management teams to utilize the
       plans as we move through an ever evolving and complicated fire year and pandemic situation. It
       should be noted that Wildland Fire Response Plans are not Forest Service documents, but rather
       are the result of a tasking by the National Multi-Agency Coordinating Group. This group is
       comprised of seven voting members:

          •   Five represent the federal wildland fire agencies;
          •   One represents the National Association of State Foresters; and
          •   One represents the Federal Emergency Management Agency and the U.S. Fire
              Administration.




                                America’s Working Forests – Caring Every Day in Every Way          Printed on Recycled Paper
Gil H. Harden, Assistant Inspector General for Audit, Office of Inspector General                 2


The Forest Service has one of seven votes in this forum. Updates to the Wildland Fire Response
Plans as a whole require extensive coordination with these partners. We recommend clarifying
the first paragraph of the memo to make the authorship of the plans clear.

The Wildland Fire Response Plans were drafted during March, April, and May of 2020, and were
based on the best available information at the time. Global understanding of COVID-19
management has changed significantly since the plans were drafted. As an interagency
community, we have quickly evolved in how we provide guidance to the field in an effort to be
more nimble and responsive to new information.

In addition to the Wildland Fire Response Plans, several guidance documents have been
distributed by the Fire Management Board, which is an interagency governance body. These
documents include:

    •   Adjustments to Wildland Fire Preparedness Activities for the 2020 Fire Year in response
        to COVID-19;
    •   Interim Guidance for Prevention of Coronavirus Disease (COVID-19) During Wildland
        Fire; and
    •   Guidance on Laboratory Testing for Coronavirus Disease Operations.

Although these documents are not official Forest Service policy, they do provide a platform for
standard operating procedures which are followed at interagency incidents. All of these
documents can be found on the Fire Management Board webpage at the following link:
https://www.nwcg.gov/partners/fmb#collapseM.

As the Centers for Disease Control and Prevention (CDC) updates their guidance for critical
infrastructure workers and the general public, the Forest Service will work with the interagency
community and update appropriate screening, social distancing, and personal protective
equipment protocols. The Chief of the Forest Service issued a letter in June 2020 that provided a
framework and strategy for fire response in a COVID-19 environment. The Chief’s letter
emphasized the importance of learning and adaptation, as well as a commitment and a priority to
the safety for fire responders and the public while carrying out our wildfire mission
responsibilities.

On a more site-specific level, interagency incident management teams have adopted practices
aligned with the Wildland Fire Response Plan documents to conduct wildland fire suppression
activities in the safest and most effective means possible. These practices are responsive to
OIG’s Observations/Suggestions, particularly numbers 5, 10, 12 and 13. Examples include:

    •   Identification of a COVID-19 support medical unit within our Incident Management
        Teams (IMTs);
Gil H. Harden, Assistant Inspector General for Audit, Office of Inspector General                    3


    •   Increasing the number of available sanitation stations on incidents;
    •   Daily upward reporting of significant COVID-19 related issues by IMTs as part of the
        situation report process; and
    •   Holding meetings outside to the greatest degree possible.

These practices continue to evolve as more is learned about COVID19, coupled with knowledge
gained by each team to improve effectiveness. An effective lessons learned effort is being
conducted each week to share findings amongst incident management teams which is supporting
very timely collective learning and adaptation of practices.

The Fire Management Board also established the COVID-19 Wildland Fire Medical and Public
Health Advisory Team. Their purpose is to address medical and health-related issues specific to
the interagency administration of mission critical wildland fire management functions in a
COVID-19 modified operating posture. The COVID-19 Wildland Fire Medical and Public
Health Advisory Team is tasked with providing:

    •   Medical and public health expertise;
    •   Advice, coordination, and collaboration with external subject matter experts; and
    •   Development of protocols and practices for all aspects of COVID-19 planning,
        prevention, and mitigation for wildland fire operations.

The Forest Service maintains alignment with the CDC and recognizes the importance of testing
as a mitigation strategy to slow the spread of COVID-19. As such, the Chief issued a letter on
July 2, 2020, that provides direction for all firefighters to be tested if they are either symptomatic
or have had meaningful exposure to the disease and describes how Forest Service employees
may obtain and pay for testing. The letter also details how to procure alternative housing, when
necessary, for those who test positive for COVID-19 or are awaiting test results, and defines
their duty status during this time. These efforts will not only support the health and safety of our
firefighters to ensure sustained operational capability, but also apply to all Forest Service
employees. We will continue to evaluate and update our testing protocols as global
understanding of COVID-19 and testing availability, reliability, and timeliness of results evolve.

The Forest Service understands the importance of the wildland fire response mission. As a
recognized world leader in wildland fire, we have and continue to innovate and adapt to the
challenge of operating in a new COVID-19 environment. The Forest Service is not alone in this
mission and works in close collaboration with other Federal, State, and Local entities; which
depend on one another to provide firefighting resources to respond to wildfires across all
jurisdictions. The interagency governance structure of the national and geographic area
coordination centers continually manages the availability of both ground and aerial resources to
ensure we are able to safely, appropriately, and aggressively respond to wildfires.
Gil H. Harden, Assistant Inspector General for Audit, Office of Inspector General             4



We are happy to provide additional information as requested to demonstrate our progress in
managing COVID-19 impacts to wildland fire response efforts. Please contact
Antoine L. Dixon, Chief Financial Officer, at (202) 205-0429 or antoine.dixon@usda.gov with
any questions.

Sincerely,




VICTORIA CHRISTIANSEN /S/
Chief
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