**Chief Ronald E. Kanterman**

**474 Richard Way**

**North Plainfield, New Jersey 07062**

**WK#732-594-4700 HM#908-753-9709**

**<Ron_kanterman@merck.com> <mfdcar1@comcast.net>**

September 5, 2008

Ms. Hope Janke

Counsel to the Director

Bureau of Justice Assistance

Office of Justice Programs

810 Seventh Street NW

Washington, D.C. 20531

RE: OJP (BJA) Docket #1478

Dear Ms. Janke,

Thank you for the opportunity to comment on the proposed regulations
regarding the Public Safety Officer\'s Benefit. As you know, when an
officer dies in the line of duty, the aftermath is devastating for their
family, department, friends, neighbors, communities and in some cases
the entire nation. We applaud your and the Department of Justice\'s
efforts of the recent past in making this process better then it ever
was. As the manager for the LAST program through the National Fallen FF
Foundation, I have witnessed the improvement first hand however we have
work to do. Please note my comments on specific issues and sections of
the proposed regulation:

**Federal Register July 10, 2008, page 39634:**

**Definition of *line of duty activity or action in* 32.3**

[Comment:]{.underline} As stated in the register, only those who
participate in training exercises considered as a \"secondary function\"
are included in the benefit program. It is paramount that the trainers,
instructors, teachers and their assistants who are doing the actual
training in concert with the students, be included in these regulations.
These officers are subject to similar stresses like the students, e.g.
when you run 24 firefighters through a live burn training exercise, you
may train 4 groups of 6. The trainers, instructors and assistants aside
from going through the exercises, also have to set and re-set the
scenarios while wearing full protective equipment and would then take
the next team through.

[Proposed Change:]{.underline} Include in the new regulations; Families
of instructors, teachers and assistants at all levels of public service
(fire, police, EMS) when conducting official training exercises will
qualify to file for the PSOB in the event of a death or debilitating
injury as a result of their work as trainers, where the circumstances of
the death or injury meets these regulations.

**PSOB Comments Docket #1478 Page 2**

**Federal Register July 10, 2008, pages 39636/39637**

***Heart attack means---***

[Comment:]{.underline} As stated in the register; paraphrased: a heart
attack includes myocardial infarction, and other cardiac-events such as
cessation, interruption, arrest, or other similar disturbance of heart
function. It must be acute and directly and proximately caused by a
pathology of the heart or coronary arteries.

In the recent past, PSOB applications have been rejected where officers
have suffered aneurysms, aortic dissections and other cardio-vascular or
cerebral episodes. Speaking solely for fire fighting, it is one of the
most physically and mentally challenging activities known to man. A
natural phenomenon in the human body is that blood pressure will elevate
and heart rate will increase, often times merely on the way to the call
due to the manufacture of adrenaline and other involuntary bodily
functions. Add to this, the stresses of wearing protective clothing
(40-60lbs), carrying heavy equipment (10-50 lbs), carrying people of all
sizes, tearing down walls and ceilings and using power tools, fire
fighters are often at their maximum physical and mental capacity.

[Proposed Change:]{.underline} Include in the definition of a heart
attack:

Aortic dissection

Aneurysm

Clog of a coronary artery due to plaque or a clot

Spasm of a coronary artery

Heart or respiratory failure due to inhalation, ingestion, absorption or
injection of a, poison, chemical, by-product of fire or smoke or other
hazardous material

Ventricular fibrillation

Myocardial ischemia

Paroxysmal supraventricular tachycardia (PSVT)

Atrial fibrillation

First degree heart block

Second degree heart block (Mobitz I, Mobitz II)

Third degree heart block

Pulmonary embolism

Add to the definition of a stroke:

Embolic stroke

Cerebral hemorrhage

Subarachnoid hemorrhage

**PSOB Comments Docket #1478 Page 3**

**Federal Register July 10, 2008, pages 39637/39638**

**32.12, 32.22, 32.32,32.34 and 32.52 (Amended)**

**Comment:** Specifically #8h-This amendment discusses participating in
training exercises re: \"when actually taking formal part in a mandatory
structured activity within an official training program of his public
agency.\"

This needs further discussion and clarification. Often times, fire
fighters go the local fire academies for additional training, seminars
and similar activities. there are also national conferences each year
where personnel go to train in hands on activities and could be many
miles away from home. In addition, mutual aid groups (geographically
close fire departments from different jurisdictions who help each other
in emergencies) also train together. To limit the definition to \"his
public agency\" is limiting the opportunities for families to qualify
for the PSOB when tragedies happen at training.

Proposed Change: ..............\"within any official training program
with the authorization of an officer or official from that fire, police
or EMS department.\"

This would cover any training anywhere as long as it's
[sanctioned]{.underline} by his or her the public agency.

Please feel free to call if you have any questions or need further
clarification and thanks again for the opportunity or comment.

Yours in Prevention,

Chief Ron Kanterman

National Fallen Firefighters Foundation

LAST Team Program Manager

nfff psob comments 1478 sept 2008