The command and management structures of the National Incident Management System are intended to be modular and scalable based on the size and complexity of incident. The Incident Command System is designed to be:

• Suitable for operations within a single jurisdiction or single agency, a single jurisdiction with multi-agency involvement, or multiple jurisdictions with multi-agency involvement;
• Applicable and acceptable to users throughout the country;
• Readily adaptable to new technology;
• Adaptable to any emergency or incident to which domestic incident management agencies would be expected to respond; and
• Scalable in organizational structure relative to the size and complexity of the incident.

Some safety officers, however, have expressed concern about a potential limitation in the ICS portion of NIMS. The challenge they perceive is the fact that ICS, although allowing the general staff to be expanded through the use of branches, divisions and groups, allows only the use of “assistants” for expansion of the command staff. Though this is a solution that’s generally effective when safety issues at an incident are directly connected to operational concerns, what happens when the concerns are not primarily operational or the operations are stable?

ICS limits the use of the command staff (liaison, information and safety) to one position and one only. There is a very important reason for the limitation: The command staff serves as a direct extension of the command function, and it’s important to keep command and control focused on a specific set of objectives overseen by a specific group of positions within the system. The information and safety roles especially, however, can have demands that require significant resources and specific authority to be effective. The concept of a “safety sandwich” is a means of accommodating these needs without violating either the letter or the spirit of the ICS, while meeting the need to expand the safety function.

An assistant is the title of a person assigned to assist the safety officer (or any other command staff position) in cases where the incident commander or the safety officer deems additional safety personnel necessary. A branch director is a person properly qualified to oversee divisions and/or groups and work under the supervision of an operations section chief. A branch is permitted to be either geographic or functional in nature.

Creating a “safety sandwich” requires the initiation of a functional branch whose responsibility is safety. A safety branch allows the operations chief the opportunity to address safety in a variety of ways with additional resources. The safety officer remains in overall charge of safety and is able to function in the same way he or she would without the branch (that being establishing strategic direction for safety at the scene while command remains in overall charge if the incident). A scenario illustrating the benefit of such an arrangement would be an incident where the mitigation of hazards such as fires and hazardous chemical releases is replaced by the concern for air monitoring, radiological assessment, arrangement of hygiene facilities or activities involved in some form of official safety-based investigation.

The suggestion that an incident might require additional safety resources is a stretch for some to consider outside of the operations environment. When operations is the focus, the safety officer definitely should consider the more conventional use of assistant safety officers assigned to tactical level managers and branch directors. Though this places more resources in the operations section, there’s also a possibility that a lone assistant safety officer may be drawn into the tactical activities of a division, group or geographic branch. A branch established with a specific focus on safety might have an easier time applying its efforts to safety issues and resisting the allure of tactical issues better addressed by tactical management. Though the branch reports to the operations section, the incident safety officer has the ability to monitor safety activities directly at any time.

The suggestion of a “safety sandwich” in the ICS has yet to be tested, validated or otherwise evaluated. It may seem a bit unorthodox, but it doesn’t violate ICS parameters. While the use of a safety section or assignment of technical safety officers has raised concerns with many ICS purists, the use of a safety branch may be an approach to address a valid concern within the confines of NIMS. If one believes that the most important responsibility of the command function is the safety of those engaged in response related activities, then the IC needs to be creative in how the safety function is structured and implemented.

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I. David Daniels is fire chief of the Fulton County (Ga.) Fire Department, a metro department surrounding the city of Atlanta. He holds a master's degree in human resources management. He is a member of the NFPA’s Fire Service Occupational Safety and Health and the Professional Qualifications for Incident Management Functional Positions committees.