FA-128, A Handbook on Women in Firefighting, January 1993*

FA-128/ January 1993 
A Handbook on Women in Firefighting The Changing Face of the Fire Service 

Federal Emergency Management Agency United States Fire Administration 

The Changing Face of the Fire Service: A Handbook on Women in Firefighting 

Prepared by: 
Women in the Fire Service 
P. O. Box 5446 
Madison, WI 53705 
608/ 233-4768 

Researchers/ Writers: 
Dee S. Armstrong 
Brenda Berkman 
Terese M. Floren 
Linda F. Willing 

Disclaimer 

This publication was prepared for the Federal Emergency Management Agency's U. 
S. Fire Administration under contract No. EMW-1-4761. Any points of view or 
opinions expressed in this document do not necessarily reflect the official 
position or policies of the Federal Emergency Management Agency or the U. S. 
Fire Administration. 

In August of 1979, the U. S. Fire Administration (USFA) convened a "Women in the 
Fire Service" seminar in College Park, Maryland. This seminar brought together a 
group of fire service leaders and others to discuss the relatively new 
phenomenon of women --perhaps 300 nationwide --employed as firefighters. Today, 
women in firefighting positions have increased to approximately 3,000. 

As a result of the symposium, the USFA in 1980 published a document called 
The Role of Women in the Fire Service. The publication summarized the issues 
discussed at the seminar, presented the participants' recommendations and 
personal insights into many aspects of women's work in the fire service, and 
described existing initiatives and resources in the area. 

Also in 1980, two manuals were developed as a result of seminar participants' 
recommendations. The first, a joint project of the USFA and the International 
Association of Fire Fighters, was a resource directory identifying fire 
departments that employed women and/ or had experience with recruiting, testing 
and training women firefighters. The second manual, Personnel Management 
Handbook: Managing the Entry of Women and Minorities, focused on legal issues, 
management commitment, recruitment strategies, and the development of entry-
level physical fitness standards. 

The fire service has experienced many changes in the twelve years since the 
publication of these documents. Some important issues have been resolved, and 
new ones have moved into the limelight. The number of women working as career 
firefighters and officers has increased tenfold; some fire departments' 
suppression forces are now ten percent female or even higher. Several fire 
departments have employed women firefighters for almost two decades, and many 
have promoted women upwards through the ranks to district chief and battalion 
chief positions. Other departments, even large ones, have yet to hire their 
first women firefighters. 

The challenge in the development of this document has been to provide a resource 
useful to all fire service personnel. This new handbook, The Changing Face of 
the Fire Service, updates the information contained in all three of the earlier 
documents and reflects a decade of experience and progress. 

I encourage you to read the handbook from start to finish. The topics reflect 
important issues of our day. The handbook will serve as a valuable resource to 
anyone seeking guidance in areas affecting the integration of women into fire 
suppression positions. 

We all benefit from a fire service that is inclusive of women at all levels. 
USFA is committed to promoting an environment where women and men can work 
harmoniously and productively together to protect our communities. I believe the 
information contained in this handbook is an important step in achieving that 
goal. 

Olin L. Greene 
U. S. Fire Administrator 

Introduction. ....................... 4 
Women firefighters in the 1990's ............... 6 
Tradition, change and women firefighters ....... 9 
Recruitment ....................... 10 
Entry-level physical testing ................. 27 
Firefighter training .................... 38 
Policy development .................... 42 
Reproductive issues ................. 43 
Child care ..................... 48 
Firefighter marriages and anti-nepotism policies ..... 49 
Firefighter hair standards ............... 50 
Station facilities ................... 53 
Sexual harassment. .................... 56 
Cultural diversity training ................. 67 
Ongoing support ..................... 71 
Protective clothing fit and safety .............. 74 
Bibliography ....................... 81 
Appendix 1: Summary of EEO law ............. 84 
Appendix 2: An FEP agency finding (on a fire 
department entry-level physical test) .......... 87 
Appendix 3: Resources .................. 91 

--3--

Why a manual on women firefighters? 

Fire may know no gender, but people do, and it is the fire chief's job to manage 
people much more often than he or she manages fire. Women and minorities are 
forming an increasing part of the workforce and the labor pool. Fire service 
managers in the 1990's have an opportunity to attract the best of that pool by 
creating a work environment that welcomes the participation of all. Facilitating 
teamwork in a culturally diverse fire department may be the biggest challenge 
currently facing fire chiefs. Those who are not prepared to manage a diverse 
workforce may find that the workforce is managing them instead. 

It's not enough just to say, "We'll hire anyone who meets our standards." How 
are those standards set? Can they be justified? What happens to someone who 
"meets the standards" but faces a barrier of hostility and opposition from co-
workers? What support systems are available for workers who are not part of the 
dominant group? Simply having policies in place that appear to be neutral, or 
are applied equally to everyone, does not necessarily create equal opportunity. 
Altering the identity of people in a fundamentally unaltered workplace can leave 
the door open to friction, miscommunication, 
and a host of inequities that can result in poor performance and a loss of 
teamwork. 

Despite repeated claims that "We don't want to reinvent the wheel," fire service 
leaders continue to ignore the critical lessons learned in other fire 
departments over the years. The ideas and resources in this handbook have been 
drawn from the experiences of fire departments across the country 
over nearly two decades of women's involvement in career-level fire suppression. 
They are offered to all those in the fire service, career and volunteer alike, 
who wish to see a smooth transition to a gender-integrated 
workforce, and to be a progressive and pro-active part of thechanging face of 
the fire service. This book is particularly created for, and dedicated to, fire 
service managers. The chances for that smooth transition ride on their 
commitment and hard work. 

--4--

How to use this handbook 

The purpose of this document is to help the fire service manager cope with the 
firefighting workforce as it changes from an all-male environment to one that 
includeswomen. The handbookoffers guidance and suggestions from people who have 
experience and expertise in the areas that affect women's integration into fire 
suppression ranks. It takes a wide perspective, and, as is appropriate with 
personnel issues in general, offers choicesand options more often than single 
"right" answers. The authors hope they have created a guide that, in calling on 
a wide range of resources, can be useful to a wide range of needs, whether that 
means one woman firefighter wanting to know where she can find a pair of gloves 
that fits, or a fire department management team seeking an overview on gender 
integration issues. 

The Changing Face of the Fire Service attempts to answer the most frequently 
asked questions about women in firefighting. It focuses specifically on the 
issues of recruitment, entry-level physical testing, firefighter training, 
maternity and reproductive safety, hair-length standards, fire station 
facilities, sexual harassment, cultural diversity training, ongoing support, and 
protective gear and uniforms. Each issue is explored from both legal and 
practical standpoints. In the area of policy development, sample language has 
been included in some cases. Where it was felt that existing policies would 
quickly become outdated, guidelines for policy development have been substituted 
for specific language. Sources for obtaining up-to-date samples of policies are 
included in the "Resources" section of the manual. 

The handbook has two specific limitations. Although it has been reviewed by 
several attorneys, it does not consider the requirements of most state or local 
laws and regulations. And, while the information in the manual was up-to-date as 
of mid-1992, many of the legal issues in question are subject to change. The 
handbook is not intended to be a substitute for qualified legal advice, which 
should be sought before implementing policies that have legal implications. 

The Changing Face of the Fire Service was prepared under contract to FEMA by 
Women in the Fire Service. It was made possible only with the assistance of 
dozens of individuals from fire departments and other agencies throughout the 
country who provided information and shared their valuable insights. For this 
assistance, the researchers and writers of this document offer their sincere 
thanks. 

--5 --

As we enter the last decade of the twentieth century, more than 3,000 women 
are at work in career-level fire suppression positions on 650-plus fire 
departments in the United States, with hundreds of counterparts in Canada, 
France, Denmark, the United Kingdom, Australia, and New Zealand. Thousands of 
other women work for fire departments in EMS, fire prevention, arson 
investigation, communications, and public education. Many women firefighters 
have been promoted to the rank of engineer, lieutenant, or captain, and the 
numbers of battalion chiefs, division chiefs, and chiefs of department continue 
to increase. At least twenty women in the U. S. have made their way up through 
the ranks to the level of division chief, battalion chief, or district chief. 
Some large cities and many smaller towns and fire districts have women serving 
on their civilian boards of fire commissioners. 

While women first became career firefighters just two decades ago, they have 
served as volunteer firefighters for more than a century. Among the volunteer 
and paid-on-call fire and EMS forces in the United States are perhaps thirty 
thousand women firefighters, and thousands more EMT's and paramedics. A large 
number are officers, including many chiefs of department. Many of these women 
are dedicated and skilled firefighters and rescue workers with a lifelong 
commitment to their volunteer departments; others, equally skilled, plan to move 
on to career positions in the fire service. 

How many women are volunteer firefighters? 

Exact numbers on volunteer firefighters are hard to obtain, as the population is 
highly mobile, and often no system is in place to track it. Most states do not 
keep accurate or centralized records of firefighters: some do not even know how 
many firefighters there are in the state. Even states that do keep records often 
do not have a system that can draw out race or gender statistics on either 
career or volunteer firefighters. In 1986, however, the National Volunteer Fire 
Council commissioned a study of volunteer firefighters in five states. 1 Of the 
volunteer firefighters surveyed, 3.3% were women. Applying this percentage to 
the country at large provides an estimated number of 42,000 women volunteer 
firefighters. 

A few states offer statistics that are much more specific. In Virginia, the 
Department of Fire Programs publishes an annual profile of minority and women's 
participation in their Fire Services Training. Their 1991 report indicated that 
1,249 of the state's 25,857 fire personnel (assuming all firefighters 
participated in the training system at some point during the year) were women, 
or 4.8% of all firefighter participants in the system. Significantly, that 
number had increased more than 9% from just the preceding year. The report 
indicated that women represented 2.9% of career firefighters and 5.7% of 
volunteers. (These are suppression-only numbers: women in strictly EMS roles 
constituted 38% of participants in the training system.) 

Extrapolating from these numbers provides a second estimate of the national 
picture. The percentage of career firefighters in Virginia who are women is 
slightly more than twice the national average. If we assume this to be true for 
volunteers as well, we can calculate an estimate of 36,300 women volunteer 
firefighters in the U. S., as well as a much greater number of women who are 
volunteer EMT's and paramedics. 

In Vermont, one of the least populous states, 90 women are volunteer 
firefighters (including two lieutenantsand one captain), and three women are 
career firefighters. At the other end of the spectrum is California, which has 
more than 600 women in career fire suppression roles and an unknown but 
certainly much greater number who are seasonal or volunteer firefighters. 

--6--

Numbers and ranks 

The national women firefighters' organization, Women in the Fire Service, 
conducts periodic surveys of women firefighters, focusing on career-level women 
in suppression roles. The most recent one, in 1990, gathered information from 
425 women nationwide, of whom 356 were career firefighters or officers. The 
following profile is taken from the data from that survey.

Fire departments that employ women range in size from small combination 
departments with only a few full-time firefighters, to New York City with its 
nearly 12,000 line personnel. Percentages of women on those fire departments 
range from minuscule (one or two women out of several hundred firefighters) to 
one department whose only paid person in suppression is a woman lieutenant. As 
of 1992, the suppression forces of several severable fire departments were over 
or approaching ten percent women: Madison, Wisconsin (31 women out of 260 total 
firefighters); Montgomery County, Maryland (92 of 900); San Diego (76 of 900). 
Some smaller departments had even higher percentages: Boulder, Colorado (14 of 
72); Davis, California (5 of 40); and Littleton, Colorado (10 of 80). The 
California Department of Forestry and Fire Protection, which has 3,412 full-time 
personnel who perform both wildland and structural firefighting, employs some 
229 women, the largest number of any single employer. At least 84% of women 
firefighters on departments represented in the survey had been hired without 
recourse to court orders or consent decrees. 

Women are not only firefighters, but officers as well. Among the career ranks in 
the U. S., there are at least 119 women driver/ engineers (on departments where 
that is a promoted position), four sergeants, 72 lieutenants, 54 captains, and 
21 battalion or division chiefs. Several women are assistant chiefs. At least 
three women are chiefs of paid or combination fire departments. In addition, 
some departments with officer ranks in their EMS division have women who are 
senior paramedics, paramedic lieutenants, or battalion chiefs in charge of EMS. 

Who are women firefighters? 

Women in the career fire service come from a wide range of occupational 
backgrounds, both traditional and non-traditional. Many were teachers or worked 
in health care (as nurses, EMT's or paramedics); others were in the military, 
worked as secretaries, or were full-time mothers prior to becoming firefighters. 
Still other women firefighters come from fields as diverse as carpentry, 
landscaping, auto parts, and photography. Most women who are career firefighters 
have college degrees, either two-year or four-year, and several hold masters' or 
doctoral degrees.* 

An estimated eleven percent of women career firefighters are African-American. 
Another four percent are Hispanic, one percent Asian, Native American, or other 
women of color, and 84% are Caucasian. Forty-one percent are married, 20% are 
unmarried but in committed relationships with a partner; 39% are single. Thirty-
four percent of women firefighters are mothers. Women firefighters at the career 
level range in age from 21 to their early 50's; women volunteer and cadet 
firefighters may be as young as 14 or as old as 70. 

--7--

These statistics demonstrate one thing most clearly: there is no "typical" woman 
firefighter. Women in the fire service exhibit at least as much collective 
diversity as fire service men, in terms of age, ethnicity, size, work history, 
and personal backgrounds. A woman firefighter may be a 23-year-old, 5'4", 120-
pound former factory worker who's married and has two children, or a 41-year-
old, 5'11", 185-pound former concert violinist who lives alone and climbs 
mountains in her off-duty time. What these women have in common is their 
dedication to their work as firefighters, and the intensity of their commitment 
to the fire service. 

--8 --

Many people feel that inequality based on sex is natural, functional, and in 
large measure unalterable. Explanations for inequality that would be 
unacceptable in the context of race pass without substantial objection in the 
context of gender: for example, the discredited notion that a woman's hormones 
would interfere with her ability to be President. Perhaps as a result of these 
miscon-ceptions, many employers have rejected efforts to promote gender equality 
because they seemed to be economically unworkable. This attitude has produced 
long-term costs that are less visible but dramatic: lost talent, heightened 
turnover, and diminished productivity, to name but a few. 

Some employers have been reluctant to accommodate employee differences or to 
reformulate jobs in ways that would allow previously excluded people to perform 
as well as workers who have been accepted under current standards. (An example 
would be the purchase of vehicles equipped with power steering, to reduce the 
amount of upper body strength that drivers need.) This reluctance forms a 
continuing barrier to equal employment opportunity. Women and minorities, once 
admitted to an occupation, are expected to accommodate themselves to existing 
institutional norms; those norms are not expected to change. Providing special 
treatment for previously excluded groups is criticized. However, "special 
treatment" is a highly subjective term. 

The difference between the way "accommodation" provisions in the Americans with 
Disabilities Act and "special treatment" for women workers are regarded shows 
this subjectivity very clearly. We applaud moves that make reasonable 
accommodation for people with disabilities. A slight modification of access can 
allow a person in a wheelchair to do a job they had been prevented from doing 
even though they were fully capable of its demands. We have come to recognize 
that accommodation implies differences, not inferiority. 

This extends to differences that are not considered disabilities. Fire 
instructors allow left-handed firefighters to tie knots left-handed even though 
that isn't the way most people do it; a difference in "handedness" is an 
acceptable variation. All firefighters applaud advances in technology that allow 
them to do their jobs more easily: lighter-weight SCBA bottles, pull-out steps 
or hydraulic racks for mounting ladders on vehicles, wheeled carts for smoke 
ejectors, pulleys that provide mechanical advantage on ladder halyards. However, 
the standards for determining when a variation among people is not acceptable, 
or when a technological advance means that the job is being "made easier" in 
some unacceptable way, are set from the highly subjective perspective of the 
dominant group. 

When is a firefighter "too short to do the job," and when has a ladder simply 
been placed too high on the vehicle? Techniques and technology that make the job 
easier are usually hailed as advances. But women's presence on the job often 
makes such advances suspect: the job is being "made easier" in some illegitimate 
way so that "unqualified" women can be hired. The change becomes an unacceptable 
form of "special treatment," even though the result is that the job is made 
safer and easier for everyone. The fact is that any change that makes the job 
less physically demanding will both save firefighters' health, safety, and 
lives, and make the job just a little more possible for someone who wasn't 
capable of it before. 

Members of a dominant group within any institution tend to view those who are 
not members of that group with skepticism. One way this dynamic affects women 
firefighters is in a strong insistence that they prove themselves by doing 
everything the hard way. Differences in technique are deemed unacceptable. But 
the "special treatment" that is criticized in the fire service is defined from a 
male reference point. If the workplace had been designed for and dominated by 
women for over a century, what accommodations to male cultural norms would we 
now regard as "special treatment?" 

It is not enough just to allow members of traditionally excluded groups to apply 
for firefighter positions. We must re-think the direction of the fire 
service. What is "equality of opportunity?" It is not a guarantee, but it must 
be more than a mere possibility. Changes in firefighter stereotypes will come 
slowly. But change must come if the fire service is to deliver optimum service 
to the community. We all have the opportunity to be part of the future by 
examining our hiring practices, our organizational policies and our own 
assumptions from a fresh and critical perspective. 

Notes: 

1 Perkins, Kenneth B., "Volunteer Fire Fighters in the United States: A 
Sociological Profile of America's Bravest," National Volunteer Fire Council, 
1987. 
2 Willing, Linda F., "Origins: Who We Are and Where We Came From," WFS 
Quarterly, pp. 4-8. 

--9--

The true measure of the success of a recruiting drive aimed at women is found... 
in the number of women who are on the job two or three years later as skilled 
and productive firefighters. 

Recruitment is usually the focal point of a fire department's efforts to 
increase the number of women firefighters on the job. In the traditional view, 
it consists of the effort that is spent, shortly before an application period 
opens or an entry-level test is given, to get candidates to apply for job 
openings. This section of the handbook outlines the basic elements of such 
recruitment programs and presents some insights from programs that are already 
in place in various parts of the U. S. 

A more comprehensive view of recruitment, however, shows that much more is 
involved in increasing the number of women on the job. This section, therefore, 
also attempts to expand current approaches to recruitment in two important 
directions: (1) by emphasizing the importance of laying the necessary groundwork 
within the department before ever seeking applications from women candidates; 
and (2) by recognizing the recruitment impact of many fire department 
activities. 

The skills and dedication of the people working on recruitment, the creativity 
that goes into designing the program, and the support -financial, logistical, 
and verbal -given to the effort by top management, all play important parts in 
the success of your department's recruitment effort. However, the entire 
operation can be negated or undermined from within the department. Your 
recruiters' message will be that your fire department wants women firefighters. 
If other aspects of your department give out a conflicting message, or if the 
department is unprepared for the change to a two-gender workforce, much of your 
recruitment effort will go for nothing. 

An example will help illustrate this. Suppose that, as a result of recruitment, 
hundreds of women apply for firefighting positions and show up to take the test. 
Does that mean your recruitment efforts have been successful? Of course, the 
answer is, "Not necessarily." Yet many fire departments and recruiters emphasize 
sheer numbers of women applicants as an indicator of effective recruiting. 
Giving greater consideration to what you're really trying to accomplish will 
show this to be short-sighted. The true measure of the success of a recruiting 
drive aimed at women is found much farther down the road, in the number of women 
who are on the job two or three years later as skilled and productive 
firefighters. 

That involves factors that aren't the job of the recruiters -which is just the 
point. The out-front recruitment effort is just the tip of the iceberg. Its 
long-range success hinges as much, or more, on work that must be done elsewhere 
in the department. If the recruiter's job is to make it known that the 
department sincerely wants women to work there as firefighters, it is the fire 
chief's job to make sure that's true. 

--10--

A pre-recruitment checklist 

This checklist covers some of the basic preparatory steps that fire department 
managers can take to make the recruitment of women firefighters more effective, 
and to insure the retention of those women who are recruited. 

The application and testing processes: 

For volunteer fire departments that do not give an entry-level test, has the 
application process -including both formal and informal elements -been reviewed 
to insure that it is welcoming of, and accessible to, women? 

For departments that give an entry-level test, has the testing procedure been 
established in full detail? 

Will candidates be informed about the components of the process, the elements of 
the physical test, how the tests will be administered, how each component will 
be scored, what constitutes a passing score, and how the final ranking on the 
eligible list (or determination of who is hired) will be made? 

If your entry-level physical test is one that women pass at a significantly 
lower rate than men, has it been locally validated, based on a job analysis 
conducted by an outside expert? 

Can the scoring system used on the test be justified as accurately predicting 
job performance? Do those who score lower on the test make less competent 
firefighters, after they have been trained, than those who scored higher? 

Has the pass/ fail point been set by testing a random sample of firefighters 
already on the job? 

Have trainable items on the test been kept to a minimum? 

Have those who will be administering the test been instructed on what variations 
in technique on the test events will be permitted? Will a variety of safe and 
effective techniques for completing the events be permitted and demonstrated? 

If candidates will wear items of protective gear during the test, are these 
available in sizes to fit all candidates? 

If test practice sessions will be held, are instructors or assistants for the 
practice sessions familiar with techniques that may be more effective for women 
and/ or shorter individuals? Has there been good coordination between these 
instructors and the people who will administer the test, so that all permissible 
techniques are demonstrated, and accurate information about times, items and 
evolutions used on the test, and the sequence of events, will be given out? 

[See section on entry-level physical testing for more information.] 

Policy development and review 

Have an anti-harassment policy and complaint procedure been implemented and 
publicized? Do personnel understand the procedure for filing sexual harassment 
complaints, and do they trust the effectiveness and confidentiality of the 
process? 

Has cultural diversity and/ or anti-harassment training been conducted for all 
personnel and been incorporated into the recruit school curriculum? 

Does the department have policies in place regarding maternity and fire 
department marriages? 

Have policies regarding hair length and personal grooming been reviewed? 

[See sections on sexual harassment, cultural diversity training, and policy 
deve1opment.] 

--11--

A pre-recruitment checklist, continued 

Recruit training 

Does the training staff have a positive attitude towards training women, and are 
they knowledgeable about cultural barriers that may exist for women coming onto 
the job? Are all instructors available after hours for additional assistance if 
requested? 

Have interested women been detailed to the training academy as instructors or 
assistants? 

Has the training curriculum been examined to see if it implicitly expects new 
recruits to have particular skills or backgrounds? Are there ways to impart this 
information or attitudes, or these skills, to those who don't possess them? 

Has the training staff been clearly instructed on how to handle difficulties 
faced by new recruits: how to document any problems, how to assist in the 
learning process? 

Are performance criteria for training clear and will they be clearly explained 
and/ or distributed to all recruits so they know what is expected of them? Are 
recruits taught skills (hands-on, not just observation) before being evaluated 
on them, and will recruits be informed at what point evaluations will take 
place? Do training dynamics give recruits a stake in each other's success and 
promote cooperation and teamwork? 

[See section on training.] 

Gear and facilities 

Are uniforms available in women's cuts and sizes? 

Will properly fitting protective gear be available to all firefighter recruits 
from the time it is first needed in training? 

Does the training center offer adequate, private facilities for both sexes: not 
just restrooms, but changing areas and showers? 

Are all fire stations adequate in their facilities for a workforce that includes 
people of both sexes? If not, has a plan or timetable been implemented to make 
them adequate? 

Will women be permitted to work at any station, regardless of whether the 
station has "facilities for women?" 

[See sections on facilities and uniforms /protective gear.] 

What is clear from this checklist is that most of the issues that arise when a 
fire department becomes gender-integrated should be considered before 
recruitment ever begins. A fire department that has little management commitment 
to hiring women, an unvalidated speed-to-completion entry-level physical test, 
haphazard training, hair-length standards designed for men, and a" We'l1 deal 
with it when it happens" approach to maternity leave, is showing that it truly 
does not care what happens to any women who might be hired. As one fire chief 
said, "It was hard to get women to come on the job, because the men didn't want 
them." Potential recruits are unlikely to be motivated to join a department on 
which they are unwelcome. In addition, women firefighters who have been asked to 
be involved in the recruitment effort may be reluctant to do so, since they know 
the problems that any women coming on the job will face. It will be difficult, 
both practically and ethically, to recruit women into such a work environment. 

--12--

A fire department's real recruiting effort, like its publiceducation work, goes 
on all year round. Volunteer fire departments, many of which are in constant 
need of new members, already know this. Whether consciously or otherwise, a fire 
department recruits new members and gives out information about itself all the 
time. Being aware of the recruitment potential of everything the department does 
will be both efficient and productive. 

The women and the people of color currently on the department should be included 
in all of the department's public activities. Firefighters "self-recruit" -that 
is, attract more people just like them -because of their visibility. If the only 
firefighters who are visible are white men, that's largely who will be 
recruited. Make sure that every time the department is in the public eye, and 
especially when it is being televised, the diversity of your department is 
visible. 

Maintain a consistent commitment to non-sexist attitudes and language. Using and 
encouraging gender-neutral language is an important statement. For example, does 
your local newspaper still refer to firefighters -of either sex-as "firemen?" A 
letter to the editor from the fire chief will not only help get the practice 
stopped, but will in itself demonstrate your department's commitment to fairness 
and diversity. 

In addition to maximizing the department's public appearances to benefit 
recruitment, specific steps, such as those described below, can be taken to 
encourage potential candidates to consider, and prepare for, firefighter jobs. 
These are all long-term efforts that will only produce results over the course 
of years. If you do not undertake them now, however, your department will 
continue to be in the position of having to depend on short-term recruitment to 
attract women who have never before considered becoming firefighters. The more 
information about the job you can provide to possible future employees, the 
easier it will be to locate and attract good, qualified personnel. 

Vocational counselors 

Develop and maintain a good relationship with high school guidance counselors 
and with career-placement personnel and vocational counselors at the colleges 
and universities in your area. These people can be where you can not: in contact 
with young people who are making career decisions. Are the counselors in your 
colleges and high schools currently encouraging young women to consider fire 
service careers? It's most likely that they are not. Make sure they are aware of 
your department's interest in hiring women firefighters, and provide supplies of 
literature, videotapes, and other information for them. Invite them to 
orientation sessions, or consider holding special sessions for counselors to 
discuss the ways you and they can work together. 

Introductory programs 

These efforts can be a productive way to recruit new firefighters who, by the 
time they complete the program, will be familiar with your department's 
operations and may possess basic firefighter training as well. Such programs 
include Explorer posts (open to young men and women 14-21 years of age), high-
school or vocational school "fire cadet" programs, ride-alongs for community 
members, resident student programs (where students bunk in the stations and, 
after completing basic firefighter training, ride along on calls). All of these 
can be effective recruiting tools. They will be effective at recruiting women 
only if you make sure they are inclusive of women, and that women are 
specifically sought as participants. 

Extended contact with potential candidates 

Many elements of a recruiting program can easily be kept operating at all times. 
Periodic open houses, practice test sessions, and orientation sessions for 
potential candidates can motivate candidates far in advance of test dates, 
allowing more time for them to develop their strengths and skills or to seek 
relevant education. 

The fire department, or the personnel department, should accept job interest 
cards at all times, even when a test is not planned. To keep the data base 
current these could have a one-or two-year expiration date, at which time a card 
would be sent out to verify the individual's continued interest. A verification 
card could also be sent out if a hiring process opens up and the person does not 
apply; those who do should automatically be kept on the list for another year or 
two years. 

These are all long-term efforts that will only produce results over the course 
of years. If you do not undertake them now, however, your department will 
continue to be in the position of having to depend on short-term recruitment to 
attract women who have never before considered becoming firefighters. 

--13--

Some fire departments do a general publicity and recruitment drive when their 
test is announced, or -for volunteer departments -when more firefighters are 
needed. The purpose of the drive is to get job information 
to as many potential applicants as possible. Many departments, however, have 
found that large numbers of well-qualified white male applicants will apply for 
firefighter positions even if the openings are not publicized at all. This can 
be because of a strong family-and-friends tradition within the department, or 
more generally because white men as a group are well aware that the fire service 
is a career option for them. The department decides then to focus its limited 
resources of time and money on a recruitment effort that targets those groups 
that are underrepresented in the workforce or applicant pool. No one is 
discouraged from applying for the job, but the tendency for the existing 
workforce to "self-recruit" is counterbalanced by publicity aimed at those who 
might not otherwise apply. 

Setting up a recruitment program involves planning, commitment, creativity, and 
may require the coordinated work of a number of people from different 
departments. A recruiting drive can be as basic as one person with a slide show 
working for three weeks, or as complex as a fully staffed division operating 
over the course of a year. The exact details of the effort will vary 
considerably depending on several factors, including: 

The size and resources of the particular fire department; 
The goals of the recruitment program; 
The amount of time available for recruiting; 
The make-up of the community and the nature of the labor pool; and 
The creativity and enthusiasm of the people involved in designing and delivering 
the program. 

Whatever its dimensions, a well-designed and carefully organized recruitment 
program will always bring greater success than one that is haphazard or based on 
misconceptions. Certain key elements will be present, 
in one form or another, in any effective and successful recruitment drive. These 
elements, all of which are discussed in detail on the following pages, include: 

Management support; 
Careful recruitment team selection; 
Realistic schedule design; 
Recruitment materials aimed at the target group; 
Publicity within the community; 
Effective use of the media; and 
Orientation sessions and open houses. 

Management support 

The top individuals in the fire department must be firmly behind the recruitment 
and integration of women into the department. All aspects of the recruiting 
effort must reflect management's sincerecommitment not only to bring women 
firefighters onto the department but to support a diverse fire service 
workforce. Management can support recruitment in the following crucial ways: 

Obtaining the funding necessary to make the program a success, either by making 
it a priority within the department's budget, seeking additional city funds 
(such as from the personnel department or any agencies concerned with equal 
employment opportunity), or obtaining donations from sources in the community; 

Making other departmental resources available to maximize the allocated money 
(reassigning fire personnel and support staff, vehicles, office space), and 
borrowing or getting access to other city resources (prior applicant lists for 
non-traditional jobs from the personnel department, photographic and darkroom 
work from the police department, audiovisual equipment and expertise, etc.) 

Working with other city departments as needed to obtain adequate lead time (the 
time between the announcement of the test date and the actual date, during which 
most short-term recruitment will be done) and to settle any other jurisdictional 
or political problems. For example, restrictions on how applications are given 
out can make it more difficult for women to obtain them. One fire department 
required applicants to come to its headquarters in person to pick up the 
necessary forms; the headquarters building was in a high-crime area, and 
numerous assaults on women had taken place in nearby parking garages. Making the 
forms easier to get will make it more likely that women will apply. Since this 
is often an inter-jurisdictional matter (that is, not one that the fire 
department itself controls), management's influence can be crucial in making the 
necessary changes. 

Demonstrating leadership by representing the program positively to elected 
officials in order to obtain their support, and by making public statements, 
particularly in the media, in support of the recruitment effort and of hiring 
women and minorities. 

--14 --

Consider carefully before you emphasize numbers as a measure of the success of 
your recruitment effort, either publicly or within thedepartment. If 
potentialcandidates and incumbent firefighters perceive (correctly or 
incorrectly) that management just wants to hire women to get numbers to fill a 
hiring goal, the sincerity and effectiveness of your recruitment will be 
severely undermined. The message that "We want to hire ten women" implies two 
things, and both of them are negative: (1) that you will hire ten women just to 
hire women, even if not all of them are qualified, and (2) that if more than ten 
qualified women apply, you will not hire all of them. It also can make your 
recruitment drive appear to have been a failure if you "only" end up hiring nine 
women. Instead, consider making a positive "goals statement" that emphasizes 
your commitment to diversify your firefighting workforce and to support its 
diversity in meaningful ways. For example, one fire department said in its 
advertisements: 

We are looking for professionals who want to be part of a progressive, 
innovative fire department. Our goal is to have a workforce that reflects the 
diversity of our community. Women and people of color are especially encouraged 
to apply. 

Recruitment team selection 

Select members of your recruitment team who have the qualities that will make 
them effective at their job. Too often, recruiters are chosen for reasons that 
make sense from a limited perspective but are irrelevant or unproductive for the 
purposes of recruitment, such as: 

S/he has "always been in charge" of recruiting; 
S/he is injured or pregnant and needs a light-duty assignment, or for some other 
reason seeks a 40-hour schedule; or 
S/ he belongs to the group that is being targeted for recruitment (e. g., people 
of color, women, paramedics, college graduates.) 

All of these practices can create problems. People who have "always" done 
recruitment will usually continue to produce the kind of candidates they have 
produced in the past. If these are not the people you're looking for, it could 
be time to make a staffing change. A firefighter who has been removed from the 
line due to injury or some other reason is usually chosen for the department's 
convenience, notbecause of the individual' s qualifications to be a good 
recruiter. (If such people should happen to possess the skills you need, 
however, they certainly should not be overlooked.) And although it is less 
obvious, the same is true of firefighters or officers who belong to the targeted 
group. 

Women currently on the job who have an interest in recruitment should be used in 
recruiting drives. The critical point at which to do so, however, is at 
orientation sessions and other public-contact points where women who are 
potential candidates will want to hear from, and ask questions of, women who are 
currently on the job. But a good speaker or advocate is not necessarily a good 
program manager. Often, women firefighters who are assigned to coordinate 
recruiting programs have few credentials for the job and, in some cases, little 
interest in it. By all means, take advantage of the abilities and interest of 
those women who do want to be involved; they're highly valuable to you. Don't, 
however, assume that someone will be a good recruit-program coordinator just 
because she's a woman and a firefighter. 

Identify the skills you will need on the recruiting team before you select its 
members. Interest in, and commitment to, the recruiting drive, are 
prerequisites: no one should be chosen who does not want to be involved. Useful 
skills and traits include: 

Education and experience in marketing and public relations; 
Graphic arts skills; 
Writing skills; 
Public speaking skills; 
Interpersonal skills for speaking with individual candidates; 
Computer literacy: word processing, data-base management, and desktop 
publishing; 
Bilingual ability, if your community is ethnically diverse; and 
Ties with target groups. 

No individual will possess all of these traits. Diversity on the team is 
important for that reason, as well as to provide the flexibility and the range 
of creativity that will permit a variety of approaches. The recruitment 
coordinator and other top recruiters must also have good organizational skills 
and be able to work well together in a concerted effort. 

The people involved in the recruitment program may come from various areas both 
within and outside the department. They may include firefighters, non-
suppression fire department personnel, support staff from the department or 
loaned from elsewhere in the city or county, community volunteers, and members 
of other local fire departments (if your own department has no women, or if you 
are participating in joint recruitment). Smaller departments may also need to 
borrow the clerical or computer services of other city departments. 

Whatever the size of your department, tap the resources you already possess. A 
recruitment program is very similar to a public education effort, and your 
public education staff should be a gold mine of assistance. They know how to 
scale a "motivational" message to a target audience and present that message in 
a way the audience will understand and respond to. Similarly, your public 
information officer has skills and contacts that can be very useful in designing 
and distributing press releases and in assuring media coverage of recruitment 
events. 

--15--

An Incident Command approach to recruitment team function 

This outline identifies the tasks or functions that must be included in a 
recruitment program. As with an emergency incident command system, the important 
part is not the title or rank of an individual in any particular role, but that 
the function is assigned to someone who will be responsible for its 
accomplishment. 

Upper management representative: 

-Oversees the recruitment effort and pre-training program 
-Authorizes necessary expenditures 
-Reports on the programs to chief of department, city manager, council, etc. 
-Attends Steering Committee meetings to get the committee's input 

Recruitment Coordinator: 

-Develops and implements the overall recruitment plan 
-Under direction of upper management, develops recruiting/ pre-training staff. 
-Coordinates overall program: materials development, scheduling, roles of staff 
members 
-Maintains records of all recruitment activities, including candidate data base 
-Provides progress reports to upper management 
-Sits on Steering Committee 

Human Resources Manager: 

-Provides orientation and sensitivity training to recruitment/pre-training staff 
-Works with media coordinator in developing outreach materials 
-Sits on Steering Committee 

Media Coordinator: 

-Develops all advertising, press releases, PSA's, flyers, brochures, and posters 
to be used in the recruitment effort 
-Schedules press interviews, coverage of events, advertising placement 
-Coordinates production and distribution of outreach materials 
-Works with support staff during photographing/ videotaping for the recruitment 
and pre-training efforts 
-Sits on Steering Committee 

The Steering Committee includes a representative of upper management, the 
Recruitment Coordinator, the Human Resources Manager, the Media Coordinator, and 
the 40-hour recruitment/ pre-training staff members. It also includes 
representatives from community organizations used for recruitment and pre-
training classes. The Committee meets weekly to coordinate all recruitment and 
pre-training activities and resources. 

Pre-training Coordinators: 

-Should have background in exercise physiology and/ or physical test 
preparation, particularly dealing with women candidates 
-Develop and implement written and physical pre-training programs for candidates 
-Work with community organizations to schedule and conduct pre-training classes 

Recruiters: 

-Include at least one representative (preferably two) from each group that is 
being targeted in the recruitment effort, and others as needed 
-Staff the intake office 
-Contact community groups to schedule orientations and drop off materials 
-Attend orientations, special events, and pre-training sessions 
-Perform canvassing and retention 
-Provide data entry and record-keeping as needed 

Support Services: 

-Attend to supplies and housekeeping needs 
-Coordinate vehicles for recruitment purposes 
-Coordinate audiovisual equipment needs 
-Design and care for portable recruitment booth 
-Do all departmental paperwork: log work time, send in payroll records, log 
vehicle mileage, gas and maintenance, etc. 

[Thanks to the San Francisco Fire Department for providing the model on which 
this outline is based.] 

Community volunteers can be used to distribute literature and to make contacts 
with various community groups. Small departments with limited budgets may be 
able to find volunteers within the community who will donate their professional 
skills to design a brochure. Local businesses may be willing to donate all or 
part of the cost of printing literature and posters for the recruitment drive. 
Cable access television channels may provide video production equipment and 
editing facilities. Fitness centers and gyms may be willing to offer discount 
memberships to firefighter applicants who are preparing for the testing process. 

Realistic schedule design 

The coordinator of your recruitment effort will be responsible for its general 
design. This means determining which fire department and community resources are 
to be used, what kind of media publicity will be required, what the priority 
markets are, and what is to be done when. The first step is to make a checklist 
of all of the tasks to be completed. This will include items such as: 

Develop the budget for the recruitment program, based on total allotted funds 
and any donated resources; 
Identify useful community resources, make preliminary contact with key 
individuals in each group, and get information on when regular meetings or 
special events are coming up; 
Identify career fairs and similar events that are scheduled during the 
recruitment period 
Write and reproduce brochures, test information, and other literature; 
Design and print posters and other items requiring graphic art or photography; 
Contact the media: write television and radio public service announcements 
(PSA's), write newspaper advertisements and press releases; arrange for 
newspaper articles and television news coverage; 
Produce videotapes for orientation sessions and test familiarization; 
Schedule orientation sessions; 
Set up "open house" dates at fire stations; 
Set up physical test practice sessions and written test study sessions; and 
Get the logistical support you will need: vehicles, office space and supplies, 
phone lines, answering machine, chairs, audio-visual equipment, security for 
office use at night, etc. 

Next, arrange the tasks into a schedule, time-line, or action plan. This should 
include when each task must be done, who will do it, how long it will take, what 
resources will be needed to carry it out, etc. Allow time for 

Recruitment efforts must be given adequate time in order to be effective, 
particularly when the recruitment is aimed at women. 

unforeseen delays: don't schedule a major event for the day after needed 
materials are due from the printer. If bad weather might force cancellation of a 
specific event, schedule an alternate date in advance. 

Recruitment efforts must be given adequate time in order to be effective. This 
is particularly true when the recruitment is aimed at women. Deciding to become 
a firefighter is not an easy decision for many women. Issues of self-image and 
self-confidence, a partner or spouse who may not be supportive or understanding, 
the demands of family responsibilities, and the risk involved in leaving a job 
to start something new and uncertain, all frequently arise and can not always be 
resolved quickly. Women may also need time in which to prepare for the physical 
test and the physical demands of the job. 

If you are limited by decisions made in other departments -for example, 
Personnel or Civil Service sets the test date, and will only give you a few 
weeks' notice -many of the above items can be developed in advance and kept on 
hold until the date is known. For example, you can write a budget, contact 
community resource people, select your program staff and coordinator, establish 
a time line to be put into operation once the date is known, and draft your 
written materials (leaving the date and other undetermined factors blank). You 
can also make a videotape that explains and demonstrates the testing process, if 
the test will not be changed before it is administered. Contact friendly 
reporters with the local papers and television stations to let them know the 
type of events you'll be offering them a chance to cover once recruitment is 
underway. Fire departments that can not obtain adequate lead time for an 
effective recruitment drive must also rely heavily on the ongoing, year-round 
types of recruitment discussed on page 13. 

Recruitment materials aimed at the target group 

In designing and writing recruitment materials, remember that you are trying to 
appeal to a different group of candidates from those who have traditionally 
applied for the job. Specifically recruiting women to become firefighters is not 
just a matter of going to places where there are lots of women -even lots of 
women who are likely candidates -and handing out the usual information about 
application deadlines and test dates. The content and image of your recruiting 
message must be different and must address cultural preconceptions that women 
have about themselves and the job. A 

--17 --

brochure or insert specifically aimed at women candidates can be highly 
effective at delivering your message. 

Your primary piece of recruitment literature should be a brochure that presents 
information about three things: the job of firefighting, your fire department, 
and the upcoming testing process. The design should be simple enough that your 
budget can afford to have hundreds or thousands of copies printed and your 
recruiters will be able to distribute them widely. Some departments have these 
produced professionally and find the results well worth the investment. However, 
it is quite possible to put out a high-quality product in-house if no funds are 
available for outside assistance. A compromise is to have a single sheet or 
folded flyer produced professionally, that contains information that will not 
change (about the job and the department), and add or insert into this material 
produced by the department. Because the cover sheet or exterior of the flyer can 
be used for several years, you will not have to reinvest in its production, and 
you can take advantage of volume discounts in the original printing. Your own 
added material, which contains information about the next test, current salary 
and benefits, etc., keeps the literature up to date. If the outside of the 
brochure leaves space for an address and postage, mailing the information to 
interested candidates will be much easier. 

It is important that the text of the brochure explains all aspects of the 
firefighter's job, including both its demands and its rewards. Women tend to be 
attracted to firefighting for the same reasons men are: the challenge 
of a physically demanding job, the rewards of performing a service to the 
community, and good pay and benefits. All of these should be emphasized. 

In writing your brochure, keep in mind how little the average non-firefighter 
knows about firefighting and about the other work that firefighters perform. 
Women in particular may have preconceptions about the job that are inaccurate 
and can either keep them from applying or can lead to problems later on, if the 
job turns out to be different from what they expected. Do not understate the 
risks involved in the job, but don't overemphasize them, either. Make it clear 
that all recruits will be fully trained by the department before ever being put 
into an emergency situation, and that safety is always a priority. Discuss 
recruit training: how long it lasts, what the schedule is, what is taught. If 
your station facilities are designed to accommodate a two-gender workforce, be 
sure to mention (or show photos of) that. 

The recruitment brochure should use gender-neutral language. This not only means 
saying "he or she" instead of "he," but also substituting terms like "staffing" 
for "manning," and saying "women," not "females." Little things count, and they 
contribute in big ways to the impression you make. The overall message should 
not be that women can manage to perform the job of firefighter and somehow fit 
into a "man's" job, but that women can 

Recruiting women as volunteer firefighters 

Volunteer fire departments vary even more widely than career departments in 
their acceptance of women firefighters. At their best, they welcome anyone who 
has the abilities and dedication required to be a firefighter. Many women have 
received strong support from the men on their volunteer fire departments, and 
many volunteer departments have women lieutenants, captains, and even chiefs. At 
the other end of the spectrum are volunteer fire departments that adhere rigidly 
to a "white men only" tradition, excluding others either by specific prohibition 
or by the force of custom. People of color and women who do manage to join 
departments of this sort often face multiple barriers such as isolation, lack of 
training, and overt forms of harassment. 

The legality of maintaining a sex-segregated volunteer fire department is a 
question that must be answered on a case-by-case or state-by-state basis. Some 
states, such as New Jersey, consider volunteer firefighters to be employees for 
the purposes of Title VII, which means that sex discrimination against a 
volunteer firefighter or applicant is illegal. In other states, this is not the 
case. [See Appendix 1 for more informatiom.] The issue is irrelevant, however, 
to a discussion on recruiting women firefighters, since departments that wish to 
exclude women are unlikely to spend time actively recruiting them. Women's 
participation in volunteer fire departments goes back more than a century, and 
for many (if not most) volunteer departments that have seen their numbers 
dwindle over the last twenty years, the question is not, "How can we keep women 
out?" but "How can we get more to join?" 

Most of the issues discussed in this section of the manual apply in some form to 
volunteer departments. The scale, economics, and some of the details differ, but 
the work and traditions of firefighting are the same. For example: 

Volunteer fire departments often do not have entry-level physical or written 
tests. However, it is wise to assess the entry process that candidates must go 
through to become volunteers. Does it contain elements that make it easier for 
women to be excluded, such as a provision that all applicants must be voted on 
by existing members? 

Policies and education against sexual harassment are just as important in 
volunteer departments as they are in career departments; perhaps even more so in 
states which do not offer employment-discrimination protection to volunteer 
firefighters. 

Short-term child care during emergency calls will often be a significant issue 
for women volunteer firefighters and firefighter couples. Creative solutions can 
both take care of the problem and demonstrate your department's support for 
women. 

Volunteer fire departments will usually need to rely more on donated resources 
in order to put together a recruitment effort. The positive side of this is that 
people in smaller communities served by volunteer departments are much more 
likely to donate their time and expertise than they would to a large, career-
level city department. 

Most volunteer fire departments are constantly seeking new members. Giving 
attention to the above issues, and adapting the suggestions presented throughout 
this section to your department's specific needs, should make it more likely 
that your department will be able to attract and retain more women firefighters 
in the future. 

and do enjoy productive fire service careers. Photos or drawings in the brochure 
should include people of both sexes and a variety of ages, sizes, and ethnic 
backgrounds. Your literature should include the customary information on pay, 
hours and benefits, pension system, number of stations the department has, 
average call load, and so forth. It should also provide clear explanations of 
the following items: 

Details of the application, testing and hiring processes, including age limits 
for hiring, eyesight requirements, medical examination, and drug screening; 

How and where to get application forms; 

Whether applications will be available by mail or can be picked up by one person 
for another; 

What to bring if applications must be picked up in person (for example, to prove 
identity, citizenship, or city residency); 

Whether turning in an application early can confer any advantage, such as in the 
case of a scoring tie, or if a limited number of applications will be given out; 
and 

Whether applications must be filled out on the spot, or may be returned by mail. 

Information on the testing process should clearly state which test will be given 
first, and when and how 

--19 --

applicants will be notified whether they have passed and if they are to go on to 
the next step in the process. If handbooks or other study materials will be 
distributed for the written test, include information on where and how to obtain 
them. 

Explain in detail what is included on the physical test and how it will be 
administered and scored. List the dates and places of test practice sessions, or 
provide a phone number to call for this information. If child care will be 
available at practice sessions or at the test itself, publicize that. Provide 
information on other resources that may be available, either through the fire 
department or elsewhere, such as through the union, other firefighters' groups, 
and the community. These resources might include the following: 

A videotape about the physical test that explains all of its components and 
demonstrates techniques that may be used to accomplish them; 

Weight-training classes or gym memberships; 

Current firefighters who will serve as mentors to 
candidates; 

"Open house" dates or other opportunities for station visits; 

Test-taking study sessions, support groups, and/ or assistance in finding a 
weight-training partner. 

All recruitment literature, whether it is contracted out to a private company or 
produced by one firefighter with a desktop publishing program on a home 
computer, must be neat and professional in appearance. Literature that looks 
sloppy, contains misspellings and grammatical or typographical errors, and 
generally appears to have been hastily done and given low priority, makes a 
negative statement about both your department and your commitment to recruiting 
women. Current computer and printer technology make it possible to produce 
attractive, professional materials at very little expense. Take advantage of 
this. Have someone from outside proofread the material, not only for errors but 
to see if it will make sense to someone who is unfamiliar with the fire service. 
If you're using an outside agency, check their text for correct use of 
terminology. Most non-firefighters don't know that a fire engine is not a fire 
truck, and even the fire service itself doesn't agree on what a "rescue unit" 
is. 

Posters. Fire departments that have asked applicants how they learned about job 
openings have often found that posters are a low-percentage effort. (The 
winners? Newspapers, direct mailing of literature to potential candidates, and 
knowing someone on the department who told them about the job.) Posters are 
usually produced outside the department, due to the technical demands of the 
process; in any case, if you plan to go to the expense of producing and 
distributing posters, they should be of a professional quality. The typical 
poster consists of a color or black-and-white photo and a caption such as "Can 
you fill these shoes?" (with a photo of fire boots), "We're looking for a few 
good women," or "It takes all kinds to make a fire department." 

Posters may be effective recruiting tools if they are well designed to appeal to 
your target group, and if they are placed in the right locations. They may work 
better in smaller towns than in big cities where there is more competition for 
people's visual attention. They may possibly be more effective for long-range 
recruitment, if they are posted in places where they can remain for some time 
and more people will see them. As a courtesy to the businesses or other agencies 
where you are placing the posters, send someone around to collect them once the 
information is no longer valid. Posters that are placed where they can be easily 
vandalized or graffitied-over should be checked periodically for replacement or 
removal. 

Videotapes. Videotape technology has created a revolution in information-sharing 
that the fire service has only begun to exploit. It is relatively inexpensive to 
produce videotapes and make them available to support your recruitment drive. 

One tape should deal with your entry-level physical test, demonstrating each 
element of the test both separately and as it fits into the testing process. Use 
women and smaller men among those demonstrating the test items and evolutions, 
particularly those events that are most affected by height and leverage. Make 
sure that your test will not change after the videotape is made: the tape must 
be accurate and give as much helpful information as possible. The tape should be 
available to loan out. If your department does not wish to handle the paperwork 
aspects of this, you may be able to negotiate an arrangement with local video 
rental stores. 

You may also wish to develop a videotape for use at orientation sessions and 
other informational events (booths at Career Fairs, etc.) This tape should talk 
about the job, and about being a woman firefighter, from the woman's 
perspective. It might include footage from actual fires, training sessions, 
"life in the station" scenes, and interviews with women firefighters on the job 
and at home. Be sure to include a number of women in order to show a diversity 
of backgrounds, sizes, ages, and personalities. 

You may be able to negotiate with local video rental stores to piggyback a copy 
of your videotape onto specific movies as they are rented. You would provide a 
number of copies of your tape, to be rubber-banded to the boxes containing the 
movie tapes. Although a major motion picture about firefighting won't come along 
every time you want to recruit, this option gives you an opportunity to target 
very specifically the groups you wish to reach, through the films they are most 
likely to rent. 

--20--

Publicity within the community 

Following are examples of locations or organizations where you may find it most 
effective to publicize job openings, place posters and /or leave flyers, and 
speak to interested groups or to individual women. 

Colleges and universities* 

High schools, if your minimum hiring age is eighteen Athletic clubs, teams, and 
events: 

-Universities, colleges, and community colleges 

-Women's softball, basketball, and volleyball leagues 

-Runs and triathlons 

-Area women's powerlifting and body-building 
competitions 

-Self-defense training schools 

Gyms and fitness centers 
Career fairs 
Explorer posts 
Military bases and discharge centers 
Factories and union offices 
Local women's advocacy groups, Women's Commissions, YWCA, 4-H, Girl Scouts, 
American Association of University Women, etc. 

Local minority-employment and tradeswomen's networks 

Church and other groups in ethnic communities Other departments within your city 
or county government: water, parks and recreation, sanitation, etc. 

Area agencies that offer fire recruit training Local volunteer fire departments, 
and smaller career departments, particularly if your department does not have a 
residency requirement 

Non-suppression employees of the fire department, and family members and friends 
of current firefighters and police officers, are two more key sources of 
potential recruits. These individuals are already familiar with 
the rewards and demands of the job, and often with the functioning of the 
department. Use your incumbent personnel as recruiters not only with the public 
but with people they know personally. 

Effective use of the media 

The media are the least expensive and most useful resource of your recruitment 
effort. At very little cost to you, they deliver your message into the homes of 
thousands of community residents. Not only should you use them for classified 
ads and public service announcements, but they will often be more than willing 
to cover your recruitment events as news or feature stories. Smaller-town 
newspapers are especially useful for this: they usually are in greater need of 
material, and subscribers often read the paper in great detail. 

A number of fire departments have gotten the media to cover their recruitment 
drives by inviting a woman reporter to go through the physical test, or to spend 
a day in the station. This can be a bit of a gamble: if the reporter can't 
complete any of the test events, the job will seem off-limits to women. 
Providing the reporter with some preliminary training on the events, or 
suggesting that the station or paper send a reporter who is physically fit and 
active, may help. It can also be beneficial to have a woman firefighter go 
through the events (successfully!) at the same time the reporter does, 
especially if cameras are present. 

*You may wish to target specific academic areas that you feel will benefit your 
department: not just fire science programs. but social services or education. 
for example. Fire departments that provide wildland fire protection might look 
for candidates with forestry backgrounds. 

--21--

Encourage reporters to promote the idea that being a firefighter is neither easy 
nor impossible for women; point to the number of skilled and successful women 
already on the job in your department and/ or across the country. Reporters will 
usually be grateful for a fact sheet that provides such information about women 
firefighters, to use as background for their stories. Providing this information 
will help prevent the media from portraying women firefighters as unusual, even 
if the women you are recruiting will be the first ones in your department. 

Local cable access channels will usually be glad to show your orientation 
videotape if you provide them with copies. This can also be done in conjunction 
with an interview and/ or call-in show where representatives of 
the fire department discuss firefighting as a career for women and give 
information about the current recruitment effort. 

The broadcast media are required to dedicate a certain amount of free air time 
to public service announcements (PSA's). Fire departments can take advantage of 
these to publicize their recruiting drives. Videotaped television spots should 
include visuals of women firefighters on the job. Radio announcements, and 
television spots that do not have visuals, should use women's voices. The text 
of your PSA's should be consistent with your written handout material; in fact, 
much of the text can come directly from your literature. 

If your department is large, is located in an attractive area, offers 
particularly good pay and benefits, or is able to hire firefighters from 
elsewhere on a lateral-entry basis, consider advertising nationally in fire 
service trade journals or tradeswomen's publications. Keep in mind, though, that 
monthly periodicals often require a lengthy lead time; be prepared to submit 
material to them well in advance. 

Orientation sessions and open houses 

A key element of recruitment involves speaking to groups of potential 
candidates. Hold orientation sessions at times and locations that are convenient 
to your target audience. Providing child care during the session will not only 
make it possible for more women to attend, but will demonstrate your 
department's commitment to hiring women. 

Speakers at the sessions should include firefighters and officers, both women 
and men, of varying ethnic and personal backgrounds. Their material should 
include a basic description of what firefighters do, in down-to-earth and 
unglamorized terms, as well as of the testing and training procedure. Women 
firefighters should talk about their experience on the job: what it's been like, 
why they enjoy it. An officer should be present to reaffirm the fire 
department's commitment to cultural diversity and equal employment opportunity. 
All speakers should be positive about the job, honest about its demands, and 
accessible to candidates' questions. 

Showing your recruitment videotape at the beginning should reduce the amount of 
time needed for questions. You also may wish to have personal protective 
equipment or fire apparatus on hand for candidates to handle or see. 

Distribute applications to all those who are interested, if your personnel 
system allows you to do so. If not, it may allow you to distribute interest 
cards by which individuals can request that an application be mailed to them. If 
even this is not possible, at least have each attendee fill out a card with his/ 
her name, address, and phone number. The blank cards should be coded in some 
method for entry into your data base, so that later on you 
can evaluate which events were the most productive. 

"Open house" sessions provide a chance for candidates to come into selected fire 
stations, view the apparatus and facilities, and talk with firefighters and 
officers. When scheduling these events, consider the suitability of the 
particular crew for such visits, the convenience of the time and location for 
the target audience, type of apparatus and station responsibilities (SCUBA team, 
Hazmat unit), etc. Recruitment staff should be present, particularly if you 
don't plan to take the station out of service. Some fire departments offer open 
houses on a regularbasis as part of their year-round recruitment effort, as well 
as for community and neighborhood relations. 

Your fire stations should function as recruitment outposts during the entire 
recruitment drive. Copies of recruitment literature and, if possible, 
applications, should be available at all stations. All department 
personnel should be able to answer basic questions about the testing and hiring 
processes. 

In some fire departments, the testing procedure alone takes many weeks; months 
or even years can elapse between the first orientation session and the day a new 
firefighter is actually hired. Fire departments unnecessarily lose many good 
candidates during this time. Throughout the application and hiring process, the 
more contact you can maintain between women candidates and the fire department, 
or among the women who are trying to get on the job, the less likely you are to 
lose them and the more likely they are to maintain their interest and 
motivation. Pre-training programs are one method of maintaining contact. (See 
boxes On pages 23 and 25 for examples.) This time can also be used to help 
candidates prepare for the upcoming testing process. 

Physical test preparation sessions 

Physical test practice and preparation sessions provide another method of 
maintaining contact with applicants. These sessions also accomplish the 
following: 

--22 --

One fire department's pre-training program 

The policy of the Los Angeles City Fire Department since it began hiring women 
in the mid-1980's has been to provide pre-training to help women who need 
physical conditioning and strength development order to pass the department's 
entry-level physical in test. Following are the basic components of their 
program.  

The department's Tutorial Program is eight weeks long. Candidates are not 
screened, and participation is voluntary. The tutorial program allows women 
candidates to develop their strength and cardiovascular fitness through an 
intensive program of specificity training with weights, traditional weight 
training, and aerobic conditioning.  The specificity training course was set up 
under the guidance of kinesiologists and exercise physiologists in 1989, 
modifying the department's original weight-training program. It involves 
exercises duplicating the exact physical requirements of the entry-level test.
 
The program also provides participants with an orientation to the fire 
department and its operations. Training sessions -one and one-half hours a 
night, three nights a week -are held at the fire department's training center; 
the staff consists of one fire captain, two firefighters, and a weight training 
coach. In addition, videotaped instruction by women firefighters on the fitness 
program is provided. Women who can not attend the academy classes have the 
option of going through the program on an independent basis at private health 
clubs or school gyms. 

Candidates are given diagnostic evaluations to monitor their progress and to 
determine their ability to perform the exercises that will be required in the 
next part of the program, preparing them for the physical test. At the end of 
the program, following a successful strength/ conditioning evaluation, medical 
examination, and personal history examination by the Personnel Department, a 
group of candidates is selected to continue into the Pre-Trainee Program.  Three 
weeks before the next phase begins, candidates receive a final evaluation, which 
they must pass in order to proceed. Those who are not selected are permitted to 
repeat the tutorial program.
 
The next stage is the Pre-Trainee Program. Its participants, all women, receive 
trainee firefighter salaries (2/ 3 of beginning firefighter pay). It is an 
[Captain James W. Bird is the designer and administrator eight-week, forty-hour/ 
week program of "specificity of the programs described here. See his article in 
Fire strength/ conditioning" training. Four to five hours a day are spent in 
exercise training; the remainder is devoted to classes and instruction: an 
introduction to the fire department, oral interview skills, and the  safe use of 
tools. At the end of the program, the candidates take the department's entry-
level physical test; those who pass go on to the oral  interview, which 
determines their position on the eligible list. (The requirements of the 
department's  written test are satisfied with successful completion  of the 
academic portion of the Pre-Trainee Program.) Those scoring within an acceptable 
range -comparable to male candidates being considered for  employment-will be 
considered for one of the next training academies. 

A group of ten to twenty men and women then  enter the Trainee Program. 
Participants receive trainee salaries. Academic training includes  listening 
skills, readingcomprehension, note-taking  skills, and other study habits. It 
also includes the  EMT course and certification. Participants receive  a copy of 
the department's drill manual and recruit training manual and are familiarized 
with these  documents. The physical program includes daily  weight training, as 
well as basic ladder and hose operations. Class size typically has been between 
-eight and 25 trainees; however, due to budget constraints no classes were 
conducted during the 1991-92 fiscal year. Subsequent staffing shortages led to a 
modified, accelerated hiring program of much larger classes in 1992-93. The 
program is  staffed by four captains and four firefighters.

The Los Angeles City Fire Department's Training Academy is a ten-week basic 
recruit school teaching fire suppression and rescue activities. Trainees receive 
entry-level firefighter  pay, Staffing consists of four captains and four 
firefighters.

The Tutorial and Pre-Trainee Programs were created in 1983. The success rate of 
the programs in their first six years was 15-25%. Following the  introduction of 
specificity training into the program in 1989, the success rate of the two 
programs increased to an average of 90%. Collectively, as of 1992, the 
department's pre-training programs had  put more than 50 women onto the 
department. 

Engineering, March 1991. for more information.]

--23 --

They allow candidates tomeasure their current fitness levels against what the 
firedepartment will require of them, and to identify any areas of weakness; 

They provide instruction for candidates in the techniques that can most 
effectively be used to accomplish the test items; 

They give candidates experience in handling the equipment used on the test; and 

They give the fire department an opportunity to identify any problems or 
inconsistencies in the design and administration of the test. 

Some fire departments offer both their physical test and practice sessions on a 
regular basis: for example, practice sessions monthly and the test twice a year. 
Most departments, however, test only every one or two years, and hold practice 
sessions during the weeks or months in advance of the test. In either case, the 
practice sessions should be held far enough in advance that a candidate can go 
through a practice to find out her/ his areas of difficulty, and still have time 
afterwards to work on those areas before the test is actually given. In setting 
up practice sessions, consider the following. 

The equipment, tasks, and sequence of events should be the same as on the actual 
test, or as close as possible. The convenience of setting up just part of the 
test for each session may be tempting, but if your test consists of a timed 
sequence of tasks, participants will not be able to get a realistic idea of the 
endurance needed to complete the test in the allotted time if they can not run 
through all of its events. 

Obtain release forms from all participants prior to any hands-on practice or 
training. You may also require that certain types of clothing or footwear be 
worn, or you may wish to provide helmets, gloves or other protective items for 
candidates to wear during practice. If you are providing the equipment, make a 
full range of sizes available to ensure a safe fit for all participants. 

Firefighters and officers who will serve as staff for the practice sessions 
should be carefully selected and trained. They should be supportive and 
encouraging of all candidates, and should offer instruction in all techniques 
that will be acceptable in actual performance of the test. If candidates attempt 
to use techniques or methods that are clearly unsafe, the staff should inform 
them that their method is not acceptable. It is very important to have 
consistency between the personnel giving instruction at the practice sessions 
and those who will administer the test, so that candidates are given reliable 
information. 

Schedule the sessions for different times of day and different days of the week, 
to increase the number of candidates who can attend. If the testing equipment is 
relatively portable and easy to set up, consider holding practice sessions at 
several locations, for the same reason. 

Physical test preparation: other resources 

Drawing on the resources of a local university, some departments have had an 
exercise scientist create a task-specific training program for women that is 
designed around the evolutions on the physical test and the physical 
requirements of the job and the training academy. (If assessing these three 
items -the test, the training, and the job -produces three different sets of 
physical requirements, it may be an indication that re-evaluating your testing 
and training procedures is in order.) Make sure the program is written down in a 
way that can easily be understood by someone who is not familiar with weight-
training terminology or notation. 

Seek community support to supplement what your department can do. Gyms and 
fitness clubs may be willing to offer membership discounts to candidates who are 
preparing to take the firefighter exam; make sure the staff members of these 
gyms receive copies of your training program. Donations from businesses or small 
grants from community funds may be available to sponsor gym memberships or 
tuition for a weight-training course at a community college. 

Even if a fire department can not, or chooses not to, seek financial support for 
such efforts, it can do some basic organizational work that will make it more 
likely that women will maintain their motivation and develop their fitness 
levels. The department can offer physical conditioning classes itself, or it can 
provide a sign-up list that will help women candidates find partners to work out 
with who are motivated by the same goal of becoming a firefighter. 

Other forms of preparation 

Many fire departments, union locals, and support groups offer or make available 
"study skills" and test-taking workshops that help candidates prepare for 
written entry-level tests and for the fire academy. These classes or sessions 
focus on reading retention, problem-solving, and other skills and tips that 
assist candidates in the testing process. Local community colleges often have 
useful resource people in these areas: you may be able to borrow a faculty 
member to conduct workshops, or find ways to fund candidates' tuition in a 
study-skills course. This can be of great benefit to women who are re-entering 
the job market and to those with limited academic backgrounds, particularly if 
the written test is especially competitive. Workshops on interview skills can 
also be helpful in preparing candidates for that portion of the hiring process. 

Once the testing procedure is over and you have identified the candidates who 
will enter the next academy, it may be useful to hold a final orientation 
session, presented by women already on the job to the women 

--24--

A firefighting "pre-academy" 

Captain Jim DeLacey was assigned to run the Oakland (California) Fire 
Department's pre-academy recruit program in 1991. Although the program had been 
in operation for several years it was relatively insubstantial at the time. In 
redesigning it, DeLacey looked also at the department's training academy, where 
he identified a problem. The firefighters who had come out of the last few 
recruit classes were good enough firefighters, but they weren't exhibiting the 
fitness or endurance levels that DeLacey, a former swimming coach, thought they 
should. Drawing on his background in kinesiology, he developed a program that 
would promote physical fitness in both the academy and the pre-academy. 

The pre-academy is open to women who have passed all of the entry-level 
firefighter tests and are waiting to be hired. Its goal is to enhance their 
ability to complete recruit school successfully. Attendance at the sessions is 
not mandatory, but each student is asked to commit on a weekly basis to 
the number of sessions they will attend the following week. 

The 1991 pre-academy was run on weekday evenings for two hours a night, five 
nights a week, for six weeks; an average of four to seven women attended each 
session. The basic fitness program consisted of circuit training, free weights, 
and running. At the end of the first week, candidates' strength in several 
muscle groups was assessed by way of maximum repetitions of bench presses, 
curls, pull-ups, etc. These assessments were repeated at two-week intervals. 
DeLacey found strength improvements greatest in the middle part of the course: 
approximately 20% after the second two weeks, and around 25% overall. The 
greatest improvement was in candidates' running and aerobic capacity: by the end 
of the pre-academy, participants were running up to 5-l/ 2 miles three times a 
week. 

The pre-academy also included some basic fireground work. During the first two 
weeks, participants carried hose packs around the drill ground, learned to raise 
and extend a 35-foot wooden ladder, developed simulated chopping skills 
(focusing on body mechanics to produce an effective result) using an eight-pound 
sledge hammer, hoisted and lowered rolls of l-1/ 2" and 3" hose via rope to a 
third-floor window, and learned safe and effective techniques for lifting large, 
bulky objects. After two to three weeks, more fireground tasks were added, 
particularly carrying, "throwing' and raising ground ladders. During this pre-
academy, DeLacey found that many of the women were having a problem with the 
one-person throw of a twenty-foot ladder. His own technique suggestions did not 
solve the problem. The woman firefighter who was assisting him with the course, 
who was also a bodybuilder, was able to demonstrate a technique that the women 
could use effectively. 

Morale was high in the pre-academy, which kept the women committed and developed 
strong ties among the group members. DeLacey's assistant kept in touch with 
those candidates who were not attending sessions, to maintain contact with them 
on a regular basis while they were waiting for the regular academy to begin. The 
entire cost of the pre-academy program to the Oakland Fire Department was one 
captain's and one firefighter's overtime for the evening hours for six weeks. A 
multi-station weight machine has now been purchased that will be used in future 
programs; this particular pre-academy used only the dumbbells and free weights 
that were available at the time. 

DeLacey feels that programs of this type should be run by women if at all 
possible, and that women firefighters or officers must be involved in some 
capacity. The trainees who participated in the program, however, said that the 
complementarity of the captain's and firefighter's personalities, and the 
difference in their approaches to fitness, were very valuable. Other suggested 
improvements included having access to first-due equipment so participants can 
practice on items actually used in the field, instead of older equipment 
scrounged up from storage. Being able to practice pulling starter cords on 
generators and saws, for example, would have been helpful. The women suggested 
that offering sessions at different times of day, and providing access to child 
care, might have made the pre-academy a possibility for more of the women on the 
list. 

The women who completed the 1991 pre-academy were among nine women who entered 
the Oakland Fire Department's 16-week recruit training program later that year, 
all of whom graduated on April 3, 1992, bringing the total number of women in 
the department to 34, or seven percent of the department's line personnel. 

[Thanks to Captain DeLacey and other members of the Oakland Fire Department, 
particularly its academy personnel, for making this informution available.] 

--25 --

who are about to enter training. If your program has been effective up to this 
point, much of the material may be redundant, but this session will provide one 
more opportunity to let the new candidates know "what the job is going to be 
about." It should include information on the role of the recruit, the 
paramilitary structure of the organization, the function of the chain of 
command, and the importance of teamwork. It should also be a time when the women 
can speak freely with each other about the realities and stresses of the job, 
share solutions and coping skills, and in general offer an introduction to 
firehouse life. As most fire departments do not employ large numbers of women, 
new woman recruits are not likely to work with other women once they are 
assigned to a station. Anorientation such as this, beyond providing last-minute 
information and survival tips, can help create a support network that will 
compensate for the lack of female role models in the station. 

Another means of providing direct support between incumbent personnel and 
firefighter candidates or recruits is a mentoring program. Individual 
firefighters or officers, through the department or the union, may volunteer to 
serve as mentors to candidates, trainees, or probationary firefighters. Mentors 
offer support, a point of contact within the department, technique tips, and 
additional needed information. A list of names should be offered to the 
candidates or recruits so that they can choose the firefighter they personally 
are most comfortable contacting. 

At the conclusion of any recruitment effort, you should evaluate 
theeffectiveness of the program. Theapplicants themselvescan provide direct and 
constructive feedback. A space on the application form asking how the person 
heard about the job, and an evaluation form that attendees at orientation 
sessions or viewers of videotapes will fill out, can help you determine where 
your efforts can be improved. 

Save the data base you have developed on potential candidates and use it as part 
of your mailing list for the next recruiting drive. If your eligibility list is 
likely to last for some time, implement a mechanism that lets you maintain 
contact with women who are on the list but haven't yet been hired. This lets 
them know they haven't been forgotten, and increases the chances that they stay 
interested in the job. 

Each member of the recruitment team, and other individuals who have had a 
significant part in the effort, should submit a written report; this should be 
followed by a meeting of all who were involved. A final report with 
recommendations for change and an action plan for implementation of the changes 
should result and be forwarded to the fire chief or appropriate member of top 
management. Follow-up letters of thanks from the recruitment coordinator or fire 
chief to all community members who donated services or money to the recruitment 
effort are not only polite but may make future donations more likely. 

--26 --

When Judith Livers applied to become a firefighter in 1974, the Arlington 
(Virginia) Fire Department required her to pass a physical test even though they 
had never before tested applicants on their physical fitness for the job. 
Nationwide, as more women began to enter career firefighting positions, the fire 
service turned its attention to the physical demands of the job and the measures 
used to test candidates' fitness. As a group, women were often considered 
incapable of performing the physical tasks of firefighting. For example, a 
survey of California fire chiefs in 1976 showed that 61% believed women were not 
physically capable of being firefighters. (Thirty-one percent also said they 
would not hire a woman even if she were physically and mentally able to do the 
job.) ' The possibility of being faced with incompetent women applicants led 
many departments to toughen their entry-level standards or to develop physical 
tests for the first time. Up until a series of court challenges beginning in the 
late 1970's, such tests were often haphazardly designed and administered by 
untrained individuals who had no expertise in testing. 

The issue of firefighter physical testing is a complex, thorny and often 
controversial one that raises questions that have no simple answers. There is no 
perfect solution, no one "best" physical test for firefighter applicants. Within 
the limitations of fire department budgets, it is very likely that no physical 
test could predict job performance with pinpoint accuracy. 

As a further complication, the validity of any test from one jurisdiction to the 
next is not guaranteed, since each employer using a test that has an unequal 
impact on a particular applicant group must validate that test. (The EEOC's 
Uniform Guidelines on Employee Selection Procedures do permit a validated test 
from one jurisdiction to be considered valid elsewhere, but only if the user 
conducts a transportability study demonstrating that the major work behaviors 
are fundamentally similar for the job in the two jurisdictions.) 2 It is 
important to note that "validity" has a specific legal definition in this 
context, and does not simply refer to a general sense that the test is related 
to the job or contains elements that look like things firefighters do. Designing 
and validating entry-level tests is the job of exercise physiologists and other 
experts. The purpose of this section of the manual is to help clarify some of 
the legal, practical, and ethical issues affecting physical test design and 
administration, and to provide guidance to fire service managers in assessing 
the value and impact of an entry-level physical test. 

The federal law that regulates employment tests, under Title VII of the Civil 
Rights Act of 1964,3 is defined in the Uniform Guidelines on Employee Selection 
Procedures issued by the Equal Employment Opportunity Commission (EEOC)." This 
law, and later court decisions interpreting it, provides that an employment 
selection device such as a physical test can be challenged if it has an 
"adverse" or "disparate" impact on a protected group: in other words, if the 
test disqualifies women or racial minorities in disproportionate numbers.* 
According to the EEOC Guidelines, a selection rate for a protected group that is 
less than 80% of the rate for the group with the highest rate will generally be 
regarded as evidence of a test's disparate impact. For example, if 200 men and 
80 women take a test, and 150 men and 40 women pass it, then the pass rate for 
women (50%) is only 67% of that for men (75%) and could indicate disparate 
impact. 

*Criteria for protection under Title VII include race. color, religion, sex and 
national origin. People with disabilities are protected under the Americans with 
Disabilities Act. 

The issue of firefighter physical testing is a complex, thorny and often 
controversial one that raises questions that have no simple answers. 

--27 --

Although "adverse" and "disparate" impact are not explicitly defined in Title 
VII or any subsequent legislation, the Supreme Court in 1989 tightened the 
statistical standards for disparate-impact cases. 5 The plaintiffs in the case 
had argued that disparate impact should be determined by comparing the total 
number of minorities in the geographical labor market with the number in skilled 
jobs at the employer's cannery. The 
Court decided that the proper comparison was between the racial composition of 
qualified persons in the labor market and the persons holding the jobs at issue. 
In a job such as firefighting, where the entry-level educational requirements 
are relatively low, "qualified" might include everyone with a high-school 
education. On the other hand, it could be more narrowly defined by a court's 
ideas about what proportion of women in the population would be physically 
capable of doing the job. This determination could significantly affect the 
opinion of the EEOC or a court about how acceptable the percentage of women 
passing an entry-level test is. 

If those challenging a test can show that it has a disparate impact, it then 
becomes the employer's responsibility to conduct a study that will validate the 
test. This means that the employer must show that the test accurately predicts 
which applicants will perform the job better. 6 The person or group challenging 
the test may also show that other tests which would also serve the employer's 
hiring interests would have less of an adverse impact on the protected group. 
There are three types of validity, or ways of showing that a test is legal: 
criterion, content, and construct. Criterion validity is proven when the test 
accurately predictsor is significantly correlated with the actual work 
proficiency of employees. Content validity is proven when the content of the 
test duplicates or is representative of actual job duties. Construct validity 
identifies the mental and psychological traits required for successful job 
performance. 7 

In defending challenges to entry-level physical tests, fire departments rely on 
criterion and content validity. Construct validity has been regarded as 
inapplicable by definition to job duties requiring physical abilities. Validity 
studies are usually conducted by industrial psychologists or other experts in 
the field. The actual validation of a test, based on the study, is done in court 
or by a fact-finder. 

Types of tests 

Approaches to entry-level physical screening by fire departments fall into four 
general categories. These are: 

Proxy tests 
Job-simulation tests 
General fitness assessments 
No entry-level physical test 

Some fire departments' tests combine elements of the first three types of 
screening. All four options have advantages and disadvantages in terms of their 
effectiveness and their impact on women candidates. These will be discussed 
below. 

Proxy tests. Many early challenges to physical testing involved tests that used 
supposedly "pure" measurements that were alleged to have criterion validity. 
Tests of this type rely on distance runs to measure stamina, devices to measure 
grip strength, balance beams to measure equilibrium, eight-foot walls to measure 
the ability to scale obstacles, etc. The advantages to proxy tests are that they 
minimize "trainable" tasks (tasks that require practice in order to gain 
expertise) and tend to give less of an advantage to candidates who have prior 
experience working with firefighting equipment. 

When these "substitute" or "proxy" tests have been challenged, however, fire 
departments often have not been able to show that the tasks actually measure 
what they are intended to measure, or have not been able to justify the scoring 
systems used to evaluate the tasks. For instance, some tests used a dynamometer 
to measure grip strength. Because the device did not adjust for hand size, it 
did not accurately measure the grip strength of applicants with smaller hands. 
When the scoring system for a distance run was examined, in some cases employers 
could not explain how they determined what would be an acceptable passing score 
except by caprice or guess." As a result, these tests designed to measure 
abilities required by the job have been viewed with skepticism by many fact-
finders and courts.* 

Job simulation tests. Many fire departments use tests that require candidates to 
perform simulated fireground tasks such as carrying tools and equipment, 
chopping, simulated forcible entry or pulling ceilings, or advancing hose lines 
while wearing protective gear. Defending these job simulation tests as having 
content validity, employers have argued that the test evolutions closely 
replicate the tasks firefighters actually perform on the job. Fire departments 
have found the public, unions, courts, and even candidates themselves less 
willing to dispute a test that, on its surface, resembles what people generally 
believe firefighters are required 
to do. 

Job simulation tests, like proxy tests, also have their shortcomings. They often 
include skills that a trained person will perform better than an untrained one, 
or tasks that require practice in order to gain expertise. This makes an 
objective assessment of the candidate's raw ability almost impossible. (The 
EEOCGuidelines caution against the use of trainable items on entry-level 
selection devices.)" ' These tests also often use scoring systems that require 
the candidate to perform the test at an "all-out" pace rather than a pace 
actually used on the fireground. Such scoring systems identify the fastest 
candidate, but 

*The Americans with Disabilities Act. however, provides for simulated (or 
actual) task demonstration in order to establish ability within the context of 
that Act." 

--28 --

Public relations and changing the entry-level test 

Most fire departments review their entry-level test periodically to make it more 
job-related, safer for the candidates, and/ or less expensive to administer. If 
you change your test design around the same time that you announce your intent 
to recruit women firefighters, your current firefighters and the public may 
become suspicious of the most recent changes in the test. They may decide that 
the test is being "watered down" to "let" women on the department. Ironically, 
this is especially likely when a lawsuit or other challenge has pointed out the 
deficiencies of the old test. 

Clear communication within the department is the first step in dealing with this 
problem. If your workforce is educated about the changes and accepting of them, 
the public will usually follow. An aggressive, positive publicity campaign in 
the media can also help prevent the recruitment and testing process from being 
poisoned by rumor and misconception. In departments that are unionized, a media 
campaign will be most effective if it is a joint effort between fire department 
management and the firefighters' union. Unless the situation has already become 
highly polarized, a joint task force or other coalition should make a 
cooperative effort possible. 

The public in general has little knowledge of the actual physical demands of 
firefighting. Fed by media images, people often believe that the harder the 
testing process is, the better for everyone. Letters to the editor about fire 
department physical tests usually reflect little awareness of the necessity for 
valid, job-relevant tests, and represent a genera1 perception that We don't want 
a 'fair' test; we want the best firefighters." Some examples: 

The fire department's efforts to keep its standards high should be applauded by 
all, not belittled... by someone who had to file a lawsuit to get standards 
lowered to get a job. 

Only the most able-bodied should be allowed to become firefighters. (It used to 
be) that if one could not pass the test, one had to seek less strenuous 
employment. 

In educating your community about entry-level tests, consider the following 
approaches: 

-Point out that the test has changed almost every time it's been given (if this 
is the case). 
-Emphasize any aspects of the new test that measure abilities that the old one 
didn't, such as aerobic or flexibility components. Offer statistics about 
firefighter injuries and heart ailments to document the need for such testing. 
Stress that the new test is therefore not necessarily easier; in fact, it is 
more comprehensive than the old one. 
-Explain the reasons for removing any specific items from the test: for example, 
the event was removed because it's not done on the job, or not done by one 
person, or the ability to perform that task is better tested by a new item. 
-Note that there are several thousand women working successfully as firefighters 
and officers on departments of all sizes throughout the U. S. and Canada. 
-Emphasize management's commitment to hiring qualified, competent firefighters, 
and to giving a test that doesn't exclude anyone who can do the job. Avoid 
saying that you're only complying with federal law in revising your test: you 
risk sounding like you wouldn't make the changes if you didn't have to. 

this determination is meaningless in the absence of data to demonstrate that 
faster candidates actually make better firefighters. (Scoring systems are 
discussed later.) Lastly, the events on a job-simulation test may not actually 
measure what they are intended to measure. 

General fitness assessments.

Some fire departments, instead of testing for the ability to perform simulated 
job tasks or proxy events, have adopted tests that assess the overall physical 
fitness of the individual applicant. The philosophy behind this type of test was 
expressed by one manager as, "We think our firefighters should have a level of 
fitness that falls in the top forty percent of the population." (The 40% figure 
was set by that particular department.) The assessment may include such events 
as a single-repetition bench press with a maximum weight, a sit-and-reach 
flexibility check, push-ups, sit-ups, and dumbbell curls. Scoring for some 
events may be scaled to the candidate's age, body weight, and gender, to 
correlate with general fitness standards for each group. This would mean that a 
23-year-old male candidate weighing 210 pounds might be required to bench press 
140 pounds, while a 34-year-old woman weighing 150 pounds would be required to 
do only 60 pounds. On the other hand, in flexibility measures, women may be 
required to out-perform men in order to receive a passing score. 

General fitness assessments are not widely used as entry-level tests; where they 
are, in most cases, elements from proxy or job-simulation tests are also 
incorporated into the testing process. The primary advantages to this 

--29--

type of test are that it provides a comprehensive view of the candidate's 
overall physical fitness, and that it does not rely on trainable tasks for its 
measurements. These tests often will not have a disparate impact on women. Where 
this is the case, Title VII does not require the employer to demonstrate the 
test's validity or relevance to the job. (A test must be demonstrably job-
related, however, if it tends to screen out individuals or groups protected 
under the Americans with Disabilities Act 11 or other civil rights statutes.) 

Criticisms of general fitness assessments as entry-level tests usually focus on 
the scaling of pass/ fail points to the candidate's age, gender, and weight. 
While this may be the accurate way to determine how a candidate's fitness level 
compares to that of others in his/ her category, it runs counter to the 
"performance" approach that measures the candidate by the demands of the job. 
Demonstrating the criterion validity of such a test, should that become 
necessary, would appear to be difficult. Even if the scores are not scaled, 
general fitness assessments are still subject to the same criticisms as proxy 
tests in terms of the difficulty of linking pass/ fail points to actual job 
demands. 

No entry-level physical test. Some smaller fire departments have never used 
physical performance tests as part of their entry-level process, relying instead 
on training and the probationary period to weed out those who can not perform 
the job. At least one large department in the early 1990's abandoned its entry-
level physical test in favor of the screening provided by the training process. 

Having no physical component (other than a medical examination) to a firefighter 
hiring process seems a radical notion. After all, the job requires a certain 
amount of strength and fitness, even if the exact levels of each are difficult 
to determine. The idea, however, has its advantages. It does not disqualify 
applicants on the basis of a test that may or may not be valid. It permits 
recruits to be trained before their abilities and performance are assessed. And 
it eliminates much of the expense involved in test development and validation. 

It also offers several disadvantages. It runs the risk of putting candidates 
into firefighter training who do not have the basic fitnessnecessary to go 
through the training program. This places a burden on the training staff, and is 
unfair to the candidate who may have quit another job in the sincere belief that 
s/ he had a good chance to become a firefighter. Moving to a "no-test" option 
may also generate controversy and disharmony within the department. 

Having no entry-level physical test does not allow a fire department to escape 
the responsibility of sorting out qualified from unqualified job applicants. The 
responsibility is simply merged into the training process, This may only create 
new problems. It makes the importance of excellent training and highly qualified 
instructors all the greater. It also increases the need for a stringent medical 
physical (within the limits of Americans with Disabilities Act), particularly 
one that assesses the cardiovascular system and the potential for back injury. 
An option that can make this approach more workable is to offer candidates a 
voluntary fitness or physical performance assessment, informing them of the 
level of performance they will have to reach by the end of training. 

One major fire department has adopted a system that modifies this approach. It 
uses a job-simulation test with a time limit for job applicants that is several 
minutes longer than the department's performance standard. By the end of recruit 
training, and annually for the rest of their careers, firefightersmust perform 
up to the standard. 

In developing an entry-level physical test, being able to demonstrate its 
criterion or content validity is only part of the goal. Simply complying with 
federal law, even if it were always clearly defined, would not necessarily 
produce a fair or usable test. The EEOC Guidelines, and the industrial-
psychologist testing methodology on which they are based, offer a narrow view of 
discrimination that can not eliminate all the harms caused by past inequities in 
employment practices. 

Why do the Guidelines fail toeliminate bias in testing? After all, they require 
test development to involve a scientific element, so that a test can not be 
based on people's subjective opinions about what the job requires. This is a 
good concept, but what often happens in actual practice is that the "scientific" 
approach gets distorted or is inadequate. This can happen in many ways. 

Failures of the survey process. In order to determine your department's entry-
level physical performance standard for firefighters, you must assess what it is 
that firefighters actually do and how they do it. This is called 
a job task analysis. It should provide a picture of the job of firefighter, and 
since job tasks are not always obvious, the analysis must break duties down into 
their simplest components.* The analysis has an objective component consisting 
of a list of tasks and how often they are performed, as well as a subjective 
view of how critical each task is. The test developer gathers information about 
the job from people on the job ("incumbents"). The more accurate this 
information is, the better the job analysis will be. 

*The job analysis provides the basis for the validation study. The analysis must 
be "a thorough survey of the relative importance of the various skills involved 
in the job in question and the degree of competency required in regard to each 
skill. It is conducted by interviewing workers, supervisors and administrators; 
consulting training manuals; and closely observing... actual performance." 12 

--30 --

However, the surveys used to determine the critical skills required by the job 
may not work the way they were designed to. People already on the job, and the 
evaluators themselves, bring their own biases to the evaluation process; the 
surveys generally are not designed to eliminate the inaccuracies that these 
biases produce. It is natural for a dominant, incumbent group to rate the traits 
they themselves hold in relative abundance as critical to the job, and to 
underrate the importance of traits they do not possess. Similarly, surveys 
written by evaluators who have preconceptions about the job will often reflect 
those preconceptions, in subtle or obvious ways, affecting the resulting data. 
What should be scientific neutrality ends up being exactly the kind of intuition 
and traditional belief that the Guidelines intended to avoid, because the values 
are being determined by the dominant group and not established impartially. 13 

Inaccurate determination of a test's value in predicting job performance. Sex 
discrimination on the job can make an entry-level test that discriminates 
against women nonetheless appear to have criterion validity. If women score 
lower than men on a screening test and then suffer on the job from sexual 
harassment, denial of training opportunities, and other behavior that diminishes 
their productivity or has a negative impact on their performance evaluations, a 
validation study will seem to show that poor performance by women on the entry-
level test "predicted" their poor performance on the job.* Unequal treatment can 
thus perpetuate itself and become a self-fulfilling prophecy, as well as giving 
men an advantage on the entry-level test. 

Confusing common abilities with needed ones. The fact that incumbents pass or do 
well on an entry-level test does not necessarily mean that the test measures 
abilities the job requires. A test that measures common traits (ones that many 
people on the job hold) instead of needed skills (ones that the job demands) may 
appear on its surface to be valid. For example, if an old, flawed selection 
device had selected a psychotic workforce, a profile of incumbents could be used 
to validate a new selection device that would result in the selection of future 
generations of psychotic firefighters. Fire department tests may be testing for 
irrelevant traits: traits possessed by the majority of firefighters because the 
firefighters happen to be male, not because the traits are critical to task 
performance . 

The challenge of impartiality 

Finding an impartial evaluator in a society permeated by sexism is a problem 
that must be recognized by anyone trying to develop a gender-neutral exam. 
Studies show that, on the whole, not only does traditional "women's work" not 
command comparable rewards to men's, but when men and women perform identical 
tasks, the tasks performed by women are rated lower. Students give less 
favorable evaluations to identical work when told the work is done by a woman. 
Nor does the fact that the evaluator is a woman or member of a minority group 
eliminate the ingrained bias against women's contributions and abilities. In 
order to "get along" in the workplace, members of minority groups often, 
consciously or unconsciously, adopt the workplace ethos of the majority group. 

Institutionalizing traditional values. 

It is even possible that when we think we are testing for desirable traits, we 
are actually selecting for harmful ones. At least one fire service manager has 
openly questioned whether there might in fact be a direct correlation between 
high scores on the entry-level test and later incidence of job-related injuries. 
15 A fresh look at traditionally valued behaviors and abilities will produce 
hiring processes that not only are fairer to applicants but healthier for the 
fire service as a whole. This applies to attitudes as well as behavior. One 
model program for firefighter stress management has suggested that: 

Basic fire service attitudes, beliefs and values that are largely masculine and 
are believed to promote stress, such as omnipotence, a rigid frontier mentality 
based on strength and toughness, insensitivity, callousness, and extreme risk-
taking, may change in a more positive direction with the introduction of women 
into the fire service. 16 

The ideal in screening firefighter applicants for their physical suitability for 
the job would be a test that would separate those who, with training, could 
become skilled and competent firefighters from those who could not. The test 
would measure each applicant against a standard in an objective way, would not 
give unfair or irrelevant advantages to anyone, and would not disadvantage 
anyone for reasons unrelated to job performance. It 

*In 1988. the Center for Social Policy and Practice in the Workplace at Columbia 
University issued a report on gender integration in the New York City Fire 
Department. Columbia used a job survey to ameasure attitudes of male 
firefighters and officers towards women firefighters. (All of the women fire 
fighters had been on the department for five years at the time of the survey.) 
Men of all levels and experience, regardless of assignment rated FDNY women 
firefighters as less competent than brand-new male recruits on every 
firefighting task except skill in community relations. For tasks requiring 
strength -carrying hose to the fifth floor, making a rescue -men saw the gap in 
"ability" between new recruits and women as being even wider in favor of new 
(male) recruits. Further, women's interpersonal relations were rated as 
significantly less competent than new recruits if the ability to take hazing and 
pranks was the criterion. Columbia took some small solace in the fact that men 
who had actually worked with women firefighters rated them slightly higher 
across all criteria than did men who had not worked with women. 14 

--31--

Test administration 
The best-designed test will not accomplish its intended purpose if it is poorly 
administered. Your test should be established in full detail before the 
application period is announced. Your recruitment literature should offer a 
complete description of what will be on the test, how it will be scored, and how 
the final eligibility list will be established. Some departments have resisted 
giving out information about scoring systems, cut-off times, or even about the 
composition of the test itself; this has a disparate impact on those who may 
require more preparation time (primarily women). The willingness to spend time 
and effort preparing for a test is a strong indicator of commitment: the 
applicant didn't just wander in off the street and decide to be a firefighter. 
The fact that an applicant prepared for the test should be viewed positively, 
not as a strike against him/ her. 

Many fire departments have improved on the practice of requiring candidates to 
wear firefighting gear during the entry-level test. If candidates wear 
protective gear, it must be available in sizes that will fit everyone. 
Applicants who are otherwise qualified may be eliminated by having to use gloves 
that are two sizes too large, or a poorly fitting SCBA that shifts and throws 
them off balance; these factors primarily affect women. A better 
option is to use a weighted vest that simulates the weight of the protective 
gear and SCBA. These are adjustable to a wide range of sizes and do not give an 
advantage to one group over another, as the use of firefighting gear can easily 
do. 

Carefully assess the equipment being used on the test events to be sure that it 
functions as well as equipment used in the field. For example, one fire 
department's test included a ladder extension. The halyard of the rope 
on the test's ladder was a smaller diameter than that on ladders used in the 
field, making it much more difficult to grip effectively. You may choose to make 
a task less difficult than in the field, compensating for the fact that the 
recruit will receive training and practice that will improve his/ her abilities, 
but it is hard to justify a task on the test being more difficult than it would 
actually be on the job. 

As discussed in the section on recruitment and pre-training, all techniques that 
will be permitted on the test should be demonstrated. These should be the same 
as those that have been taught at any test practice sessions. For the sake of 
consistency, there should be an overlap of administrative and safety personnel 
between the practice sessions and the test itself. 

would also be economical and relatively easy to administer. Even if no test can 
precisely meet this ideal, test developers should approach it as closely as 
possible. Fire administrators should look critically at their department's 
physical test to see if it truly measures what it is supposed to measure, in the 
fairest way possible. Three areas where tests often fall short are: 

Comprehensiveness; 

Whether the test contains trainable elements; and 
Whether the test reflects actual fireground practice 

Comprehensiveness 

A comprehensive test assesses the entire range of physical abilities needed on 
the job. Many entry-level firefighter tests primarily assess speed (anaerobic 
capacity) and upper-body strength. [See Appendix 2 for one example.] Yet a 
firefighter's job requires other equally important attributes. Heart attacks 
consistently cause nearly 50% of firefighter line-of-duty deaths, yet many fire 
departments have no endurance component to their entry-level tests. 17 Muscular 
strains and sprains are by far the leading type of injury for fire suppression 
personnel, on and off the fireground, yet flexibility is often given minimal 
consideration or is not tested at all. 18 The same is true of attributes such as 
balance, and small motor movements. If, as often happens, women compare 
favorably with men on the criteria that are not tested, and candidates are only 
tested on those areas where women tend to perform less well than men, the 
results will inaccurately show women to be less qualified for the job than a 
more comprehensive test would indicate. Comprehensive entry-level testing is not 
only fairer to the candidates; it is a benefit to the fire department. The fire 
service should take advantage of ongoing advances in medicine and exercise 
physiology in order to improve and refine its ability to evaluate specific 
physical qualities. Choosing the wrong people at entry level, such as those 
prone to heart attacks or disabling back injuries, does a disservice to the 
worker and to the community served. 

Trainable elements 

Trainable elements on the test should be minimized. Using trainable tasks in 
entry-level tests is specifically discouraged by the EEOC Guidelines. If entry-
level firefighters will all receive basic firefighter training before 
going on the line, make sure your test does not inadvertently give preference to 
candidates who have prior experience. (You may choose to favor those with 
experience by giving extra points through the interview process or elsewhere, 
but that should not be the function of the physical test.) The tasks selected 
should be those that require the least training or knowledge of test equipment 
to perform. 

--32--

Consider an example of what can happen if an entry-level test contains a 
significant number of trainable elements. Taking this hypothetical test for a 
career-level fire department are two candidates. Candidate X has been a 
volunteer firefighter for two years, so s/ he knows some basic firefighting 
skills: how to handle an axe, raise a ladder, drag hose, open a hydrant, etc. 
Candidate Y has no firefighting background but has more of the basic qualities 
the fire department needs in its entry-level candidates: cardiovascular fitness, 
muscular strength and endurance, flexibility, eye-hand coordination, etc. 
Because of his/ her volunteer experience, Candidate X may outscore Candidate Y 
on the test and be the one who is hired. 

What happened, and why? The candidate who, in our example, was the less 
qualified of the two, got the job. It happened because a test that should have 
been predicting job performance instead measured prior exposure to job skills. 
If fire departments threw recruit firefighters into the field without any 
training, one could possibly justify such a test. But a real-world fire 
department that hired both of these candidates would find that, once trained, Y 
was the better firefighter. S/ he was better qualified in terms of basic 
attributes, while X has already had the benefit of some firefighter training and 
so will not improve as much during training. 

The concept of trainability is not limited to fireground evolutions, but may 
refer to aspects of cultural pre-training for which physical tests implicitly 
reward candidates. Job-simulation tests that use firefighting tools and gear 
give an advantage to men as a group, because men are more likely than women to 
have worked with axes, ladders, or heavy/ bulky objects (ventilation fans, 
dummies) before, and may be more familiar with performing tasks in bulky gear or 
gloves. Holding testpractice sessions (see "Recruitment" section) can somewhat 
reduce the impact of trainable elements on a test, but it is even more effective 
to eliminate these elements wherever possible. 

Reflection of actual fireground practice 

Once trainable elements are minimized, an entry-level test should reflect the 
way the job is actually performed. This includes pace, time limits, technique, 
and the selection and sequence of tasks. A test that requires successful 
candidates to perform at an all-out pace does not represent the way the job is 
actually done. While many fire departments are careful to set realistic time 
limits for their tests and to specify that a walking pace be maintained 
throughout, others use tests that, by design or unintentionally, require an all-
out, anaerobic pace.* (If even a brief rest period breaks ups a "long" test 
designed to measure aerobic capacity, stamina and endurance, it may instead 
become two or more anaerobic/ speed tests.) Although actual fireground 
performance calls upon the firefighter's aerobic capacity, these tests require 
speed-to-completion performance and therefore measure only anaerobic capacity. 
Their pace and intensity do not match the way firefighter tasks are really 
performed. Women as a group tend to compare favorably with men on aerobic 
capacity, but may be disadvantaged by tests that over-emphasize anaerobic 
ability. 

Sequential tests that lump all tasks together under an overall time limit do not 
measure minimal ability in any single task. A candidate could perform one task 
at a speed that would be unacceptably slow on the job, but 
still pass the test by completing other tasks at speeds that might be 
unnecessary on the job. 

The diversity of firefighter sizes and shapes, and the corresponding variations 
in effective fireground techniques, must be considered in designing entry-level 
tests. Different firefighters perform fireground tasks in differentways. 
Thismeans that, on the job, the techniques used to accomplish a task will vary 
depending on who is in the workforce. For example, firefighters who have a lower 
center of gravity or greater strength in the lower 

*In 1989, New York City administered an intense, all-out test scored on speed-
to-completion. One male candidate died during the test, and more than thirty 
other men were hospitalized or treated for renal failure. Other cities that have 
administered comparable tests have seen similar medical problems result. 

--33 --

An alternate hiring process 

The Kern County, California, Fire Department developed its Work Experience 
Firefighter Trainee Program in the mid-1980's in order to increase the number of 
women and minorities in suppression positions on the department. KCFD in 1984 
had 487 line personnel, of which 51 were minorities and none were women. The 
Work Experience Program was designed to offer a group of firefighter applicants 
not selected through the department's standard testing process a year of on-the-
job training and testing as an alternate entry path. The program has been 
successful and is a good example of union/ 
management cooperation: both parties were involved in the development of the 
program and both have a stake in its success. 

Kern County's entry-level testing procedure for firefighters normally attracts 
1300-1500 applicants. The written test is given first; only the top 50 or so 
scorers on the written exam are permitted to go on to the physical test. Women 
and minorities who are not in the top 50 are offered the option of the Work 
Experience Program. Candidates go through a second written exam, scored pass/ 
fail, and then to an oral board which establishes their ranking on a list for 
entry into the Program. They also take the entry-level physical and must score 
within a "trainable window:" high enough that it can reasonably be expected that 
they will be able to pass the test at some point during their year of training. 

The trainees then enter the regular ten-week recruit training course along with 
recruits hired from the regular list. (By agreement with the union, this is on a 
one-for-one basis.) After completing the course, trainees are assigned to one of 
four Program training stations, which are selected for the types of apparatus 
housed there, a high level of calls, and generally because the captain or 
engineer on the shift at that station is interested in being involved in 
training. Trainees work a standard firefighter shift and receive two-thirds of 
firefighter base pay with no benefits (including sick leave). Once a month, all 
trainees are brought to the academy to receive additional training. At the end 
of the training year, trainees must take and pass the department's physical 
test. If they fail to do so, they are terminated; if they pass it, they go on to 
become probationary firefighters. 

The program has been successful both in terms of numbers and acceptance: in its 
first four years, nine women and 23 minority men became Kern County 
firefighters. The firefighters' union supports the program and agrees that it 
produces skilled and competent graduates: "These people have proven themselves 
twice over." Representatives of several other firefighters' unions have visited 
Kern County to observe the program's operation. 

The program is also controversial, and not without its administrative problems. 
The low pay and lack of sick leave for trainees who are performing essentially 
the same job as firefighters is one point of criticism. Those within the 
department cite the need for improvement in a few areas: a better method of 
selecting the officers who staff the training stations (to improve consistency 
and quality of training), an option for an "early turn-out" if a candidate can 
pass the physical test before a full year has elapsed, and improved recruitment 
to field more women and minority applicants. 

Most significant, however, is the seeming paradox that the recruits who enter 
firefighter training from the regular hiring list and the trainees who come in 
through the Work Experience Program are often indistinguishable during the 
academy training: that is, the "regular" recruits do not consistently out-
perform or outscore the Work Experience trainees. This strongly suggests that 
the testing process as it is currently administered is not a reliable predictor 
of job success. Trainees who do better in recruit school than those hired off 
the standard list must still complete their year at two-thirds pay before they 
can begin their probation, even if they are able to pass the physical test. 

The Work Experience Program nonetheless is an innovative method of increasing 
the numbers of women and minority men on a fire department, particularly in its 
display of labor/ management cooperation. 

[Thanks to the management, union officials, and members of the Kern County Fire 
Department for making this information available.] 

--34--

An argument for linkage 

Developing a test to measure an applicant's ability to perform any job requires 
a thorough knowledge of the job in question. Once the job analysis has been 
completed and the list of important (frequent or critical) tasks is compiled, 
test developers can, with fire service input, determine which of the tasks to 
include as part of a physical performance test. This selection is the most 
difficult and controversial part of test development. 

On an entry-level exam, job applicants should not be expected to perform tasks 
that firefighters do not perform on the job. Firefighter applicants should also 
not be expected to perform at a higher level than incumbents. Regardless of the 
tasks selected for an entry-level test, the performance standard must be linked 
with the incumbent's level of performance. The lowest level of acceptable and 
effective incumbent performance is the standard for applicant performance. 

The assessment of incumbent performance will provide a framework for 
establishing time limits for completing the tasks that make up the test. An all-
out, fast-as-possible pace is unsafe, unnecessary, and does not reflect real 
firefighting practice. Applicants who can perform necessary tasks at a pace that 
is necessary to the job and at which incumbents can and do perform, must be 
considered capable. 

Basing entry-level standards on incumbent performance has a number of 
advantages. It is relatively easy to compile a job task analysis and to generate 
data on the performance of those on the job. Complex statistical or 
physiological date need not be collected, which reduces administrative costs. 
Most importantly, linkage of entry-level standards to on-the-job performance 
leads to the development of a single performance standard for all firefighters 
within a department. 

part of their bodies (primarily women) may find it more effective to use a 
different technique for pulling a ceiling or cutting a roof than those who have 
greater strength in the upper part of their bodies (primarily men). 

One place this has an impact is in the sequence of events on the test. On the 
job, women firefighters often use their lower bodies as well as their upper-body 
strength in forcing entry. But if the sequence of tasks on the test exhausts all 
lower-body muscles by the time the candidate reaches the forcible-entry 
simulation, candidates will be required to perform the task in a way they might 
not actually perform it on the job -that is, by using their arms only. The test 
will then measure the candidate's ability to perform forcible entry with his/ 
her arms, and not the ability to accomplish the task in the way that is most 
effective for the individual. Those who have less upper-body muscular 
development will be unnecessarily disadvantaged. 

Another place technique can have an impact on test design is where events on a 
job -simulation test are based on techniques that not all firefighters use. Fore 
example, a job-simulation test might require candidates to use the same 
technique to lift a dumbbell that men use to lift ladders on the job. Since 
other equally good ways to lift ladders exist that women may use more 
effectively, the dumbbell lift could eliminate women candidates who could 
actually perform well on the fireground. 

A fire department can defend its entry-level test by showing a positive 
correlation between a firefighter's performance evaluations on the job and his/ 
her performance on the test.* If no women are currently on 

*How "positive" or statistically significant that correlation must be has never 
been defined by Congress, the EEOC. or the courts. 

the job, what appears to be a positive correlation between job performance and 
entry-level test performance may actually only correlate a test biased in favor 
of men with a workforce that is predominantly male. It might also correlate low 
job performance by women who have not been trained in appropriate techniques 
with low performance on such an entry-level test. If a more diverse workforce 
alters job skill performance by using a variety of techniques for lifting 
ladders, the correlation between the exam and fireground performance can go down 
markedly. And as the workplace itself changes -increasing hazardous materials 
incidents, lighter and more sophisticated tools and equipment, increased 
emphasis on fire prevention -selection devices must also change to reflect new 
work tasks and realities. 

Scoring systems 

The scoring system used to rank candidates is another crucial factor in 
determining the fairness of a test. 19 Entry-level physical tests are most often 
scored on a pass/ fail basis. Other options include rank-ordering and "banding." 

Many fire departments have adopted the philosophy of a "qualifying" physical 
test. Employers scoring their test on a pass/ fail basis must fulfill two 
requirements in justifying the cut-off score. First, the test must be 
"reliable:" that is, if it were graded, or the person evaluated, by two 
different people, the results would be fairly similar. Second, the employer must 
have a "justifiable reason" for adopting the score. 20 Pass/ fail physical 
testing generally has the least disparate impact on women, of the three options 
under discussion here. 

--35 --

Other employers, adopting the "more is better" philosophy, score their test on a 
rank-ordered basis. Some group candidates into "bands" based on their scores, 
and consider all individuals within each band to be equally qualified. This 
recognizes and compensates somewhat for the impreciseness of the selection 
device, but it can permit a one-second difference in time to make a five-or ten-
point difference in a candidate's score. 

If a test is used to rank applicants, the employer must show that higher scores 
correlate with better job performance. The Supreme Court has held that where the 
disparity of impact is greater at high passing scores than low, any alleged 
correlation between higher scores and better job performance must be "closely 
scrutinized." 21 

Firefighters of both genders and of all shapes, sizes, and colors have 
demonstrated successful performance on the job. Studies demonstrate that the 
trainable component of many exams is a greater disadvantage to women as a group. 
Given these facts, it makes sense to doubt the reliability of rank-ordered 
scores. A ten-second difference is often all it takes in a rank-ordered, speed-
to-completion test, to separate someone who's hired from someone who isn't. It 
would be extremely difficult to develop a test so accurate that a ten-second 
difference in the overall score would really predict who would be a better 
firefighter. 

A question that is often asked is whether one can justifiably require job 
applicants to perform tasks (or perform at speeds) that firefighters on the job 
can not themselves perform. The rationale for rank-ordering and for high cut-off 
scores for pass-fail tests has traditionally been based in part on common 
assumptions about the effects of age. Fire departments have argued that because 
workers' physical abilities "naturally" deteriorate with age, employers are 
justified in requiring greater physical abilities from new hires than the level 
of physical fitness actually held by incumbent firefighters. 

This assumption is becoming increasingly questionable. The EEOC in 1992 was 
scheduled to issue findings arguing that Congress should revoke the fire 
service's exemption from the Age Discrimination Act. The study that was done to 
research the issue concluded that age was not a reasonable predictor of employee 
performance in the fire service: that "accumulated deficits" in firefighter 
physical ability were only marginally associated with age. 22 As attitudes 
change on the issues of diet, exercise, and smoking, it will be increasingly 
difficult to argue that the fire service can maintain separate standards of 
physical fitness for new hires and incumbents. Rather, the trend in the fire 
service will undoubtedly be to have one standard for firefighters, as reflected 
in the recent revision of NFPA's 1582 "Standard on Medical Requirements for Fire 
Fighters." 

Eliminating bias in testing 

Fire department managers should examine entry-level testing processes carefully 
for elements of bias that give any group an unwarranted advantage. Bias is not 
always obvious. It may be concealed in "substitute indicators" such as using 
speed as the primary scoring criterion. It may be hidden in the job task 
analysis, or in test events that do not measure what they are designed to 
measure because they allow only one technique in the performance of a task, or 
incorporate elements on which candidates can improve with training. It can also 
be as simple as candidates being required to wear gloves on the test, when the 
gloves do not fit all of the candidates. 

Fire departments that use job-simulation tests to assess candidates' performance 
have found these "look-alike" tests to be widely accepted. On the other hand, 
some exercise physiologists have developed job standards that are based on 
complex measures of the energy costs associated with fire suppression tasks, and 
claim that their criterion-linked standards are more defensible in court. 
Whatever the type of test used, where there is disparate impact, the test may be 
challenged in court, and the fire department using the test bears the 
responsibility of defending it. 

Many fire departments have found that establishing the validity of a physical 
test is a lengthy, difficult and expensive process. The employer must justify 
all aspects of the test, from the selection of tasks to be performed to the time 
allowed for completing the tasks. If the test is not scored on a pass-fail 
basis, the employer must demonstrate that a higher score correlates with job 
performance. Regardless of who wins in court, the enormous expenses of time, 
money and morale can produce a no-win situation for both sides in the legal 
challenge. For the good of the fire service, as well as fairness to applicants, 
traditional physical performance tests and standards should be re-evaluated. 23 

Notes: 

1 Affirmative Action Committee, California Fire Chiefs Association; "CFCA Survey 
of Women Fire Fighters," 1976.  
2 29 C. F. R. 1607.7  
3 42 U. S. C. 2000e et seq, as amended.  
4 29 C. F. R. 1607: Uniform Guidelines on Employee Selection Procedures.  
5 Wards Cow Packing Co., Inc. v. Atonio, 109 S. Ct. 2115 (1989). But see Dothard 
v. Rawlinson, 433 U. S. 321 (1977) where the Supreme Court explicitly recognized 
that a plaintiff could establish a statistical showing of disproportionate 
impact with "potential applicant" data.]  
6 The Uniform Guidelines permit an employer to use a test even though it is not 
at the moment fully validated if 1) "substantial evidence" of validity is 
available, and 2) a validation study is in progress that will yield the missing 

--36 --

data in a "reasonable time" (unless a study is not feasible). [29 C. F. R. 
1607.5( J)] If the test is subsequently found invalid, adherence to this 
section will not legally insulate the employer from a charge of discrimination. 
7 These definitions were developed in reliance on standards developed by the 
American Psychological Association, the American Education Research Association, 
and the National Council on Measurement in Education in 1974. [29 C. F. R. 
1607.5( C).] Published by the EEOC in 1978, the definitions have not been 
revised or reviewed for possible conflicts with later developments in testing 
and exercise physiology. 
8 Berkman v. Koch, 536 F. Supp. 177 (E. D. N. Y. 1982) aff'd 705 F. 2d 584 (2d 
Cir. 1983). 
9 29 C. F. R.  1630. 
10 29 C. F. R.  1607.5( F). 
11 29 C. F. R. 1630.14( a). 
12 Vulcan Society v. Civil Service Commission, 360 F. Supp. 1265, 1274 (S. D. N. 
Y. 1973). 
13 See Kilgo v. Bowman Transp., 570 F. Supp. 1509 (N. D. Ga. 1983), aff'd 789 F. 
2d 859 ( 11 th Cir. 1986). Job analysis was found wanting for several reasons, 
including the fact that it profiled the trucking industry according to its 
current overrepresentation of male employees. See also Vulcan Pioneers v. N. J. 
Dept. of Civil Service, 832 F. 2d 811 (3d Cir. 1987). 
14 Center for Social Policv and Practice in the Workplace, "Gender Integration 
in the New York Fire Department: A Review A and Recommendations," Columbia 
University School of Social Work, 1988. 
15 Osby, R., "Guidelines for Effective Fire Service Affirmative Action," Fire 
Chief; September 1991, p. 53. 
16 Stress Management: Model Program for Maintaining Firefighter Well-Being, 
produced by the IAFC Foundation for FEMA/ U. S. Fire Administration, 1991, p. 
35. 
17 Washburn, Arthur E., Paul R. LeBlanc, and Rita F. Fahy, "Report on I991 Fire 
Fighter Fatalities," NFPA Journal, July-August 1992, pp. 40-54. 
18 Karter, Michael J., Jr., and Paul R. LeBlanc, "U. S. Fire Fighter Injuries -
1990," NFPA Journal, November-December 1991, pp. 43-48. 
19 The Uniform Guidelines address cut-off scores at 29 C. F. R.  1607.5(H). 
20 In Gillespie v. Wisconsin, the court said the employer must use a 
professional estimate of the requisite abilities or at least a logical 
"breakpoint." 771 F. 2d 1035 (7th Cir. 1985). 
21 Guardians Assn. v. Civil Service Commission , 630 F. 2d 79 (2d Cir. 1980). 
Also see Pina v. City of East Providence, 492 F. Supp. 1240 (D. R. I. 1980); 
Brunet v City of Columbus, 642 F. Supp. 12 14 (S. D. Ohio 1986), appeal 
dismissed, 826 F. 2d 1062 (6th Cir. l987), cert denied, 485 U. S. 1034 (1988); 
Zamlen v. City of Cleveland, 686 F. Supp. 631 (N. D. Ohio 1988), aff'd, 906 F. 
2d 209 (6th Cir. 1990), cert denied, 111 S. Ct. 1388 (1991). 
22 Landy, Frank J., "Research on the use of fitness tests for police and 
firefighting jobs," The Pennsylvania State University Center for Applied 
Behavioral Sciences, 1992. 
23 This section has part of its philosophical basis in the excellent analysis of 
testing and EEO by Kellman, M., "Concepts of Discrimination in 
'Genera1 Ability' Job Testing," I04 Harvard Law Review 1158 (April 1991). 

--37 --

The training program should be comprehensive in including abilities that are 
needed on the job, and should exclude those that are irrelevant. 

The quality of a fire department's recruit training is crucial to every 
firefighter's chances for success on the job. It can be doubly so for women 
recruits. Women often enter recruit training with more to learn. They may have 
less familiarity with the fire service than do many of the other recruits, or 
less past experience working with ladders, axes, power saws, and other tools and 
equipment that are commonly part of men's cultural pre-training. This means that 
they must work and study harder in order to complete the training successfully. 
It also means that any inadequacy on the part of the curriculum or the 
instructors will have a greater impact on them. 

The quality of a fire department's recruit training program should be assessed 
for the following characteristics: 

A comprehensive curriculum that teaches the skills and knowledge recruits will 
need on the job; 
Presentation of a variety of techniques for accomplishing physical tasks; 
Effective teaching methods; 
Qualified and motivated instructors; and 
Consistency in how material is presented and how recruits are rated. 

The training curriculum 

The contents of basic firefighter training should be drawn from the tasks a 
probationary firefighter is expected to be able to perform and the knowledge s/ 
he is expected to have. The curriculum design should be based on a job task 
analysis. 

The fire service has a strong tendency to allow evolutions, skills, or 
techniques to remain as part of recruit training even when they are no longer 
relevant to the job. Instructors sometimes rationalize this by describing the 
requirement as good for "toughening the recruits" or for "building character." 
The real reasons such items persist may have more to do with tradition, with 
what the instructors had to do when they were recruits, or with a hidden desire 
to make the training as difficult as possible. Evolutions that are not required 
by the job have little or no place in a realistic, productive training program. 
The time allotted for recruit training is usually limited and can be much better 
spent on the skills and knowledge the firefighter actually needs. And poor 
performance on an irrelevant evolution can unjustifiably brand a recruit (to 
others and, most damagingly, to him/ herself) as being "borderline" or "having 
problems." 

There may be some justification for including items that help teach skills or 
develop strengths that will be needed on the job. Calisthenics and aerobic 
exercise, for example, are part of many recruit academies. While firefighters do 
not perform mile runs on the job, running is an effective way of improving the 
aerobic capacity that is crucial to a firefighter's job performance. 

The training program should be comprehensive in including abilities that are 
needed on the job, and should exclude those that are irrelevant. Eliminate or 
revise any areas that implicitly require recruits already to possess certain 
skills or types of knowledge. These hidden requirements may exist not because 
this "pre-training" is really necessary, but because the type of recruit you've 
always had has always known these things. 

One woman firefighter described her experiences: 

When I was first being taught to open a hydrant, they handed me the hydrant 
wrench and told me, "You use this just like you would any other wrench." I had 
never, to my absolutely certain knowledge, ever held a wrench of any kind 
before. They tell me to cut along the floor joists; I have never wielded an axe, 
never heard the term "joist." We talk about the dangers of vehicle extrication; 
I am clueless as to the internal workings of a car. Five months into the job, 
with all new gear that 

--38 --

genuinely fits, and strength that is adequate for most situations, I am still 
perpetually handicapped by my ignorance of information that boys in our culture 
just seem to absorb. 1 

Find ways to impart such skills or information to recruits who don't possess 
them. One fire department, for example, hired university personnel to come in 
and teach study skills to its recruits. Others offer extra sessions on basic 
tool use or incorporate training on residential heating systems and basic 
electrical systems into their curriculum. 

Look at both the job and your training to identify new areas of need. Fire 
departments have been undergoing rapid change; your training curriculum has 
probably changed as a result. Hazardous materials training has undoubtedly been 
added because of increased fire department awareness, the need for hazmat 
response, and related legal requirements. But have other elements such as 
cultural diversity training, anti-harassment education, communications skills, 
and conflict resolution also been incorporated, to reflect other new workplace 
needs? 

Technique 

Assess your current techniques for performing tasks in the same way that you 
have looked at the training curriculum. To require recruits to perform a task in 
the most difficult way possible simply because it is difficult is 
a legacy of the boot-camp methodology of firefighter instruction. Some women 
firefighters have been instructed that they must operate a 2-" line without 
being able to rest it on their hip; others have been informed that it's 
"cheating" to bend one's knees when pulling a halyard to extend the fly on a 
ground ladder. 

As one battalion chief said, "Any training instructor who thinks there's only 
one way to perform an evolution is missing the point." Just as was done for the 
entry-level physical test, techniques for smaller people, shorter people, and 
people with different body mechanics and leverage should be incorporated 
wherever possible into physical skills and evolutions. For many skills, several 
different techniques are possible without compromising safety. Demonstrate the 
different techniques equally; don't give the impression that one is somehow 
inferior or should only be used if the recruit is having trouble with the 
"normal" or "regular" method. 

--39 --

A firefighter training class for women 

At the request of the Jacksonville Fire Department, the Florida Community 
College at Jacksonville (FCCJ) in 1990 offered a women-only firefighter 
certification class, the only such program ever run in Florida. (FCCJ had 
earlier run a Black Firefighters' Program that placed 75 of 88 participants with 
JFD.) The women's class was designed to increase the number of women on the 
Jacksonville department, and it succeeded in doubling that number from eight to 
sixteen.

Florida is one of a few states that permit people to take firefighter training 
in a vocational-school setting before applying to a tire department, FCCJ offers 
the training on a regular basis, but was asked to make this class open to women 
only. "We feel that an environment with only female students would be less 
threatening, and students would feel more at ease requesting help if needed," 
the Jacksonville Director of Public Safety said. 

Following a publicity campaign and orientation session, interested women were 
given written and physical performance tests. Those scoring below the cutoffs on 
the written tests were allowed to continue with the program while attending 
remedial classes in English, reading, and/ or math. The physical test was given 
as a diagnostic tool to determine areas where work was needed, and to establish 
a baseline to document later improvement. The women who passed the test were 
allowed to go directly into the certification program; 69 of the remaining 79 
women entered a sixteen-week physical training course designed by a physical 
education professor at FCCJ. 

Halfway through the course, the students took the physical test again. All of 
the 39 women remaining in the program improved their times by two minutes or 
more; nineteen passed the test, and six came within five percent of a passing 
time. Based on these results, it was decided to begin the firefighter 
certification class in mid-April. Both day and evening sessions were offered; 33 
women attended in the daytime (eight hours a day, five days a week) and six came 
at night and on Saturdays, for a total of 372 hours of training over the course 
of the program. 

Joe Fowler, Director of the Public Services Program at FCCJ, was impressed by 
the ability and dedication of the women. "At one point, I received a phone call 
from the coordinator telling me that I needed to be at a ladder evolution test 
the next day because it was felt that six or more of the students would fail. I 
showed up bright and early, and so did the women; not one failed." 

A variety of funding sources made it financially possible for women to take the 
course. Only the six women in the evening classes were working full time during 
the program, and many of the women had quit their jobs in order to participate. 
Seventeen women took advantage of a scholarship loan program from FCCJ 
underwritten by a local bank, that provided a $200/ week stipend for the nine 
weeks of training, to be paid back over three years at $55/ month. Several women 
received book fees and tuition from a non-traditional women's employment program 
or a local Private Industry Council. 
Some women also received funding to cover child care expenses. 

Twenty-four women successfully completed the course. For the fifteen who dropped 
out or failed, the primary reason was the written portion of the course. Fowler 
noted that this was unusual, and speculated that so much emphasis might have 
been put on the physical conditioning aspects of the course that its mental and 
intellectual demands might not have received enough attention. 

The placement rate with the Jacksonville Fire Department of the women who 
graduated from the course was not as high as had been hoped, due to a number of 
problems and delays, and also to a priority shift that led the department to 
hire certified paramedics before considering other candidates. Nevertheless, at 
least eight of the women were hired by JFD later that year, and the department 
was carrying about 60 vacancies, with the hiring list valid for two years. 
Several other women in the class were hired as firefighters by other 
departments. 

[Thanks to Joe Fowler of the Florida Community College at Jacksonville for 
making this information available.] 

--40--

The use of alternate techniques is usually controversial at first. Officers and 
instructors tend to view the traditional methods as "right," and then find some 
pretext for justifying them as "safer." Real issues of safety are 
often hard to separate from what is simply a desire not to make things easier. 
For example, many women firefighters have found that using a reverse grip on a 
ladder halyard (with the thumb edge of the hands facing downward) allows a more 
efficient use of strength. Some departments have accepted this technique; others 
have expressed concern that the resulting rotating motion of the wrist might 
lead to injuries. 

In reality, techniques that are moreefficient for smaller, lighter people often 
also end up being safer and more efficient for others. "If the big guys use the 
same technique as the smaller people, they distribute the work more throughout 
their body, fatigue more slowly, and have less potential for pulling muscles," 
the training chief for one department observed. When evolutions require 
coordination of several people's efforts, some standardization of technique may 
be necessary for efficient operation, but efficiency, effectiveness and safety 
should be the guiding criteria, not "how we' ve always done it." 

Delivering the training 

Firefighter training has traditionally been modeled on team sports and the 
military. Reasons for this include: 

They are what the instructors themselves know, 
from their own backgrounds and from their training as firefighters; 
They are usually effective with recruits who have those backgrounds; 
They are consistent with other paramilitary aspects of firefighting. 

Neither of the first two is a compelling reason to continue to train in a 
particular way, if the people you're training have different backgrounds than 
those for whom the training method was designed. Most fire academies are now 
finding it productive, regardless of who the recruits are, to emphasize learning 
over intimidation. Where the old approach was, "Let'ssee who can survive this 
course," the new one is, "We're going to do all we can to teach you to be a 
firefighter." If particular aspects of paramilitary culture are important, they 
can be taught specifically, such as when to take an order without discussing it, 
or how the chain of command works, but the training setting should be responsive 
to the students' needs. 

Instructors 

Instructors should be selected for their ability to teach and to communicate, 
their sensitivity to the needs of a variety of students, and their willingness 
to offer extra assistance to students who request it. They should have a 
positive and supportive attitude towards training and towards the recruits. 
Instructors should not be assigned 

--41--

to the training center as punishment, because of a temporary or permanent 
disability, or in order to get points on their next promotional process. 

The instructional staff should include women, minority group members, and people 
of different heights and sizes. This is particularly crucial for classes that 
have women and minority recruits, but it is an important general practice as 
well. Academy training is the recruit's first point of extended contact with the 
fire department. It is used in many ways to instruct recruits in basic fire 
department reality -discipline, punctuality, etc. -and it should also give the 
clear message that the fire department is a culturally diverse workplace. All 
instructors should be trained on cultural diversity and anti-harassment issues 
as well. 

Consistency and fairness 

Consistency in the presentation of information to recruits is very important. 
This includes both curriculum items and information about how the class will be 
run. The criteria for passing or failing the academy should be clearly explained 
to all recruits and strictly adhered to by the instructors and staff. There 
should be no sources of "inside information" regarding tests, evaluations, or 
techniques; all recruits should have equal access to any useful knowledge. 

Ensure that your instructors permit recruits a chance to receive full 
instruction and practice on all tasks before they are evaluated, and that each 
student completes each task for which they are responsible. Time constraints 
sometimes lure instructors into "checking off" students who in fact have only 
watched someone else perform a task; this is unfair to the student and to the 
department. If tests or evaluations will be given without notice, students must 
be clearly warned that this is possible, and 
should be informed as to what material is subject to such evaluation. 
Documentation on the performance of all students in both written and practical 
skills must be comprehensive and consistent. Some departments have begun using 
videotapes of recruits' physical performance both as learning tools-the 
instructor can sit down with the student later and point out any problem areas-
and as part of the evaluation process. 

Notes:
1 Brown, Cathy, "One Crazy Person Running In," WFS 

Comprehensive, impartial policies... let all personnel know what the ground 
rules are, and make it more likely that each individual will be treated fairly. 

The ability of a fire department to retainwomen firefighters will depend, in 
large part, on whether it develops and implements clear and fair policies in 
areas that have a unique or particular impact on women. These areas, to be 
discussed on the following pages, include reproductive health and safety, child 
care, firefighter marriages, hair length and grooming, and fire station 
facilities. The very important topic of sexual harassment will be discussed at 
length in the following section. 

It is important to have these policies in place before the first women are ever 
hired. There are four reasons for this: 

Policy development and implementation can be handled carefully, not rushed into 
place at the last minute. 

The department shows that it is prepared for women to be firefighters and 
supportive of their presence. Single-gender firehouse facilities, male-based 
hair standards, and/ or a lack of a maternity policy, all give the clear message 
that women aren't really expected to make careers within the department. 

Any controversy surrounding the implementation of a policy will be focused on 
management and on the policy itself; if women are already on the job, they often 
become scapegoats and are blamed for unpopular policies. Additionally, if 
policies are inadequate, it is often the women who must seek to have them 
changed, thus drawing unwanted attention to themselves and again being blamed 
for the change. 

All members of the organization know what they can expect. The "we'll deal with 
it when it happens" approach to pregnancy, for example, means that a woman who 
is being responsible about family planning will not be able to start her family, 
since she has no idea what will happen to her if she becomes pregnant. Women 
whose pregnancies are unplanned will be subjected to unnecessary stress and the 
possibility of financial hardship. Similarly, firefighter couples who wish to 
marry are entitled to know what the impact of their marriage would be on their 
work assignments and promotional opportunities. 

In paid fire departments, some of these policies, such as maternity leave, may 
be subject to collective bargaining with the firefighters' union and thus can 
not be unilaterally implemented. In such situations, it is important for the 
union's negotiating team to be informed about the issues and energetic about 
pursuing them. If written policies have not been negotiated or implemented, 
management should clarify what the current policy is, or what the lack of policy 
means. For example, what will happen to a firefighter or recruit who becomes 
pregnant? Similarly, all other fire department policies should be reviewed for 
their impact on women. For example, if all fire departments in the area have 
residency requirements, what would happen if two firefighters from different 
departments got married? 

Many volunteer fire departments do not have written policies in these or any 
other areas. There are compelling reasons for this to change, particularly if 
volunteers receive compensation for their time and can be considered employees 
under state or federal law. For all fire departments, having comprehensive, 
impartial policies in place lets all personnel know what the ground rules are 
and makes it more likely that each individual will be treated fairly. This 
enhances recruitment, morale, retention, performance, and almost every other 
aspect of fire service life. 

--42--

Up until the late 1970's, the fire service gave little thought to maternity or 
family issues. Although women had been volunteer firefighters for many years, 
most fire chiefs, especially chiefs of paid departments, believed that they 
would never have to deal with women on the job. Many departments that did have 
women firefighters dealt reactively rather than proactively with new issues and 
situations as they arose. Instead of anticipating the future and planning for 
it, fire chiefs were often caught off guard by change, with results that served 
no one's best interests. 

This was especially true regarding the issue of maternity . Until fairly 
recently, many employers in all types of work refused to deal with maternity as 
an issue in the workplace. Only a generation ago, motherhood and work outside 
the home were considered mutually exclusive. If a woman had a job at all, it was 
expected that she would quit once she started having children. Employers were 
allowed to treat pregnant employees in any way they chose, and the law offered 
no protection for these women. As recently as 1964, forty percent of a11 
employers terminated workers who became pregnant. 

Times have changed. Two-income families are now the rule rather than the 
exception among families with two parents, and most women who work do so because 
their income is needed to support themselves and their families. More than half 
of all women with a child under one year old are working outside the home. Fewer 
than ten percent of all U. S. families now reflect the traditional model of a 
husband who works and a wife who stays home to raise the children. 1 Yet 
policies in the workplace that support employees' dual roles as breadwinners and 
caregivers to children (and, increasingly, to aging parents) have been slow to 
develop. 

The development of workable policies in the fire service has been more 
challenging due to the nature of the job: the odd hours, the hazardous work 
environment, the near impossibility of taking years off from the job for the 
purpose of child rearing. Because the issue is inherently complex, and because 
at first only a few women, widely scattered around the country, were affected, 
the overwhelming tendency of fire departments was to avoid the issue as long as 
possible, and often to find ways to encourage (or coerce) women who did become 
pregnant to quit their jobs. 

A 1986 survey of seventy fire departments nationwide found that only ten percent 
had a maternity or pregnancy policy specifically designed for fire department 
employees 2 Forty-four percent had no maternity provisions whatsoever. Four 
years later, the picture had changed only slightly. A 1990 survey showed that 
between a quarter and a third of fire departments in the country that employed 
women had no written policy regarding maternity, and an additional ten percent 
had only a city-or county-wide policy that did not specifically address women 
firefighters. Between thirty and fifty percent of departments reported having 
some sort of written maternity policy for women firefighters, although in many 
cases this simply consisted of language specifying that pregnant women could use 
sick leave and vacation time, or that departmental off-duty injury leave 
provisions applied to pregnant women firefighters. 3 

This section on reproductive issues will discuss legal aspects of the maternity 
issue, clarify the difference between maternity policies and pregnancy policies, 
and explain the concept of gender-neutral parental leave. 

Pregnancy and the law 

One federal statute and two court decisions have set the course for the current 
discussion of maternity policies in the workplace. The law is the Pregnancy 
Discrimination Act of 1978 (PDA), an amendment to Title VII of the Civil Rights 
Act of 1964. The PDA broadens the definition of sex discrimination set forth 
under Title VII to include discrimination based on pregnancy and childbirth. It 
states: 

Women affected by pregnancy, childbirth or related medical conditions shall be 
treated the same for all employment related purposes, including the receipt of 
benefits under fringe benefit programs, as other persons not so affected but 
similar in their ability or inability to work... 4 

This law applies to all employers with fifteen or more employees, and to 
employment agencies and labor organizations. 

The PDA was the first significant piece of legislation to deal with maternity in 
theworkplace. Its main purpose was to prevent arbitrary and discriminatory 
treatment of pregnant employees. The PDA guaranteed that pregnant women would 
have access to the benefits already in place for other workers. For example, 
company health insurance plans could no longer exclude coverage for pregnancy 
and childbirth. An employer could not refuse to hire or promote a woman solely 
on the basis of pregnancy. Disability caused by pregnancy had to be covered 
under an existing disability program. If the employer gave temporarily disabled 
workers light duty, it was also required to give pregnant employees light duty. 
Most importantly, a woman could not be arbitrarily fired from her job if she 
became pregnant, nor could she be required to take an extended leave that was 
not deemed medically necessary. 5 

The Pregnancy Discrimination Act allowed women to continue their employment well 
into pregnancy and to return to work as soon as they were physically able. The 
intent of the law was to end the discrimination that pregnant women had 
historically faced in the workplace. 

--43 --

In the years following the passage of the PDA, several states developed policies 
mandating certain types of benefits for pregnancy and childbirth. California 
passed a law that guaranteed up to four months of unpaid leave for the purpose 
of child birth and recovery. The California Federal Savings and Loan Association 
challenged this law as a violation of the Pregnancy Discrimination Act, arguing 
that since the PDA stated that all employees should be treated the same, no 
special benefits could legally be allowed for pregnancy and childbirth. 

The case went to the Supreme Court, and in 1987 the Court upheld the state of 
California's policy and clarified the intention of the Pregnancy Discrimination 
Act. The majority opinion stated that the law was intended to "construct a floor 
beneath which pregnancy benefits may not drop, not a ceiling above which they 
may not rise." 6 This decision provided the opportunity for individual employers 
to develop specialized types of maternity policies. 

Some fire departments, as well as employers in other potentially hazardous work 
environments, developed policies for pregnancy in the workplace that were based 
on the concept of "fetal protection." Conditions and substances exist in many 
workplaces that offer either probable or proven hazards to a developing fetus 
and to the reproductive health of both men and women workers. These hazards 
include both chemical and environmental factors. Policies based on fetal 
protection often required a woman to leave a certain type of job, such as active 
firefighting, at some point in her pregnancy (in many cases, as soon as the 
pregnancy was known). This requirement was based not on the woman's ability or 
inability to perform her job, but rather on the employer's concern that some 
aspect of her work might prove harmful to the developing fetus. 

The Supreme Court considered such fetal protection policies in its 1991 UAWV. 
Johnson Controls decision. This case concerned a battery manufacturer that had 
barred al1 fertile women from working in jobs using lead, based on the premise 
that lead could harm a fetus. The Supreme Court rejected this policy as a form 
of sex discrimination and a violation of the Pregnancy Discrimination Act. The 
majority opinion stated: "Decisions about the welfare of futurechildren must be 
left to the parents who conceive, bear, support, and raise them rather than the 
employers who hire those parents." It further pointed out: 

It is no more appropriate for the courts than it is for individual employers to 
decide whether a woman's reproductive role is more important to herself and her 
family than her economic role. Congress has left this choice to the woman as 
hers to make. 7 

Although other court decisions relating to pregnancy and employment exist in the 
lower courts, no other Supreme Court decisions have modified or contradicted the 
thrust of California Federal Savings & Loan and Johnson Controls. These 
decisions provide guidance for policy development regarding pregnancy and 
maternity in the fire service. 

Policy Development 

Although employment policies that relate to pregnancy and childbirth are often 
grouped under the general heading of "maternity policies," there are really 
three types of policies that should be considered. These are: maternity leave 
policies, pregnancy policies, and parental leave policies. 

Maternity leave policies. 

These policies address the specific period of time when a woman is disabled as a 
result of childbirth. All women who go through childbirth are temporarily 
disabled by it to some degree, whether it be for a few days or for several 
months. Allowing time for women to have their children and physically recover 
afterwards is a need in every workplace. When a woman's pregnancy does not 
restrict her ability to do her job, and when she suffers no complications from 
the pregnancy or delivery, a typical maternity leave might be six to eight 
weeks. Extensions may be available if the pregnancy and/ or delivery are very 
difficult. In some cases, employers provide this time as paid or partly-paid 
leave specifically for childbirth. In other instances, women must use sick or 
vacation time to insure a paycheck during the time surrounding childbirth. 

Pregnancy policies. 

Women firefighters need maternity leave just like all other women workers, but, 
like women in other hazardous professions, their needs are more complex than 
that. A typical maternity leave assumes that a pregnant woman can and will work 
at her usual job long into her pregnancy. The PDA guarantees women the right to 
do this as long as they are able to perform all of their job functions. However, 
in the case of active firefighting, there is real concern as to whether women 
should continue in their usual job assignments while pregnant. 

A number of chemical and environmental factors can adversely affect pregnancy. 
(See inset on medical considerations, page 45.) Many of these substances or 
conditions have been shown to have adverse repro-ductive outcomes in both males 
and females in animal studies; for the most part, the human research as it 
relates to firefighting is too sparse to support solid conclusions. On the basis 
of the research that does exist, most physicians agree that women should stop 
fighting fires and doing other high-risk work at some point in their 
pregnancies. Exactly what point is most appropriate is a subject of some debate. 
Because many environmental hazards are most dangerous to a fetus during the 
first trimester (the first three months a woman is pregnant), many fire 
departments want women to leave hazardous duty as soon as their pregnancies are 
known. The majority of women prefer this arrangement as well. 8 

--44 --

The general trend among career-level fire departments is to offer alternate d u 
t y to a firefighter during the term of her pregnancy. This type of assignment 
is sometimes known as "light duty." Volunteer departments may recommend that a 
pregnant firefighter limit her activities to non-hazardous duties within the 
department as well. Although a transfer to non-hazardous or "light" duty may be 
recommended during pregnancy, and may be supported by all employees, the Supreme 
Court decision in Johnson Controls strongly suggests that such transfers can not 
be mandatory. In response to the decision, some fire departments have changed 
policies of mandatory transfer to ones that strongly recommend such a change of 
assignment. 

As research increases, more attention is being given to the reproductive risks 
of parental exposure near the time of conception. Some people feel that women 
and men who are trying to conceive should avoid environments of potential risk 
to reproductive health. At least one fire department has implemented a policy of 
allowing, on request, a voluntary transfer to alternate, non-hazardous duty for 
any firefighter, male or female, who is trying to conceive. 

The fire department must provide education if any reproductive safety policy is 
to be implemented successfully. All employees must understand the hazards to 
reproductive health that firefighting poses to men and women. A qualified 
physician, or other professional who is well versed in the existing research on 
the issue, should conduct classes on this subject for all firefighters and 
officers. 

Women firefighters should also be educated early in their careers about the 
options that exist for them should they become pregnant. The fire department 
should develop reasonable policies and clearly define the options within them. 
The ideal policy is one where non-hazardous duty is guaranteed for the term of a 
pregnancy and while the mother is nursing. The transfer should be to meaningful 
work that does not penalize the woman, and it should involve no loss of pay or 
benefits. Pregnant firefighters have worked successfully in such areas as 
training, public education, prevention and inspection, policy development and 
communications. Fire departments of all sizes have found ways to utilize the 
pregnant employee productively in a role that does not offer reproductive 
hazards; the department and the employee both benefit from the short-term 
assignment to a non-combat position. The International Association of Fire 
Fighters in 1992 adopted the position that the pregnant firefighter should be 
offered the opportunity for voluntary transfer from firefighting at any time 
during 
her pregnancy without loss of pay or benefits. 

When considering options for alternate duty, the term "non-hazardous" offers a 
clearer description of what is being sought than does "light" duty. A light-duty 
assignment is not physically taxing, but it may still expose the worker to 
hazardous environments. For example, a light-duty task in one fire department 
required a pregnant firefighter to fuel all of the department's staff cars every 
day. Excessive exposure to gasoline and 

Medical considerations of firefighting and pregnancy 

The job of firefighting presents many potential hazards to healthy reproduction. 
It poses physical hazards such as drastic temperature variations, extreme and 
unpredictable physical exertion demands, and psychological stress. Firefighters 
may also be exposed to biological or radiation hazards. Additionally, the fire 
environment may produce a wide range of chemical agents, including irritant and 
asphyxiant gases and other toxins. 

Human reproductive health as it is affected by the work environment is a 
relatively new area of study. The clearest connectionbetween an environmental 
agent and adverse reproductive outcomes for both men and women is in the case of 
ionizing radiation, which is not a common hazard for most firefighters. 
Prolonged exposure to high ambient temperatures, however, may also have a 
detrimental effect on fertility and pregnancy. High heat exposure has been 
related to infertility in men and may be linked to neural defects in the babies 
of exposed mothers. 

Chemical agents in the fire environment are numerous and unpredictable. The 
toxic effects of fire smoke have been tentatively linked to a number of physical 
problems, including respiratory disease, coronary artery disease and 
malignancies. Many chemical agents in the fire environment may also adversely 
affect reproduction. Carbon monoxide, carbon dioxide, hydrogen cyanide, acrolein 
and other aldehydes, sulfur dioxide, hydrogen chloride, nitrogen dioxide and 
benzene are all commonly produced in fire environments. Research shows that all 
of these compounds may have detrimental effects on reproduction. Pregnant women 
and their fetuses are especially affected by carbon monoxide exposures. 

Although much more study is needed, existing research suggests that both men and 
women are vulnerable to reproductive toxicity in the firefighting environment. 
In addition, the potential hazards to developing fetuses pose special concerns 
for pregnant firefighters. 

Source: "Reproductive Hazards of Firefighting I and II," Melissa McDiarmid, M. 
D., et al., American Journal of Industrial Medicine, 19: 433-472 (1991).

--45 --

Maternity and parental leave policy checklist 
 
The specific terms of a fire department maternity policy will vary depending on 
the needs of the city or other employer. However, all comprehensive policies 
have some points in common. Keep the following guidelines in mind as you work to 
develop your department's policy. 

The policy should guarantee that the pregnant employee will not lose her job. 
Firing an employee because of pregnancy is a violation of the Pregnancy 
Discrimination Act of 1978. 

Alternate, non-hazardous duty should be available but not mandatory. The 
employee who transfers to this type of assignment should not lose any pay or 
benefits by doing so. 

It is the employer's responsibility to educate all employees, both male and 
female, about reproductive hazards in the workplace, to enable them to make 
informed decisions about conceiving and bearing children. 

The employee's health care benefits should be maintained during any type of 
leave related to pregnancy. 

Pregnant employees should not be required to exhaust all sick leave, vacation 
time or other forms of personal leave, before being allowed to use maternity 
leave. Use of these other types of leave for the purpose of maternity should be 
at the employee's discretion. 

Pregnant employees should not lose seniority or eligibility for promotion due to 
any paid leaves or transfers to non-hazardous assignments. 

Unpaid leave should be an option, both during pregnancy and after the birth. 
Parental leave should be gender-neutral and equally available to both parents 
regardless of their marital status, as well as to non-biological parents. 

If maternity/ parental leave is part ofcontract language, and the contract does 
not cover recruit and probationary firefighters, the department's policy should 
address what options are available to the recruit or probationary firefighter 
who becomes pregnant or becomes a parent. 

diesel fumes during pregnancy may cause health problems. Similarly, doing arson 
investigation in freshly burned buildings is probably not the best choice for an 
alternate assignment. Non-hazardous duty will still permit the pregnant 
firefighter to take any training or recertification classes that other 
firefighters are under-going, as long as the classes' activities do not pose any 
risks to her. This not only keeps the department from having to train her 
retroactively and keeps her from falling behind in her training, but it also 
allows her to remain in touch with her co-workers and with combat operations 
during the time she is reassigned. 

A fire department is not required to offer alternate-duty assignments to 
pregnant firefighters unless it has a policy of reassigning all employees who 
have temporary disabilities. The essence of the Pregnancy Discrimination Act is 
that pregnant employees must be treated at least as well as other employees who 
are temporarily disabled. However, pregnant employees may be offered alternate 
duty even if that option is not available to all other employees. The legality 
of this type of variance in treatment was clearly upheld in California Federal 
Savings & Loan. 

It is also important to remem-ber that the law, as of 1992, upholds a woman's 
right to continue working in a hazardous environment even during pregnancy. The 
overwhelming majority of women will not choose to do this. However, if faced 
with a choice between a higher-risk pregnancy and economic devastation caused by 
a significant loss of pay and benefits during pregnancy (because no alternate 
duty is offered), some women will feel compelled to choose the former. 

What is the best solution? Although pregnancy poses a challenge to fire 
departments, the issue is certainly manageable. Many cities and other juris-
dictions have arrived at good solutions that consider the needs of both the 
employee and the employer. A policy that allows the employee to continue being a 
contributing member of the department during pregnancy, and that assures her of 
continued pay, benefits, and seniority at normal levels, is an attainable goal, 
even for small fire departments. 

In a minority of cases, a pregnant employee will be unable to work even in an 
alternate duty assignment because of health complications during pregnancy. A 
leave of absence during pregnancy and childbirth should be an option on every 
fire department. Such leaves are usually unpaid, but may include continued 
accrual of seniority and benefits. At the very least, an unpaid leave should 
include continued medical insurance coverage, even if the employee must pay the 
full premium for the coverage. Unpaid leaves should be available for the 
duration of the pregnancy, and should include enough time to accommodate 
recovery from a delivery that involves complications. 

--46 --

Some fire departments have developed policies that require the opinion of a 
doctor, often the employee's personal physician, as the deciding factor for how 
long a pregnant woman can work safely in her fire service job. Since many 
physicians are not familiar with the actual demands and hazards of firefighting, 
they should be educated about the job before they are asked to give such an 
opinion. Fire departments may wish to develop a standard physician's release 
form for this purpose, which specifically lists the requirements of the job. Any 
such form used in cases of pregnancy must also be used in a comparable way for 
other non-duty-related disabilities, such as off-the-job injuries. 

Parental Leave. 

Most women will be physically capable of returning to full firefighting duty 
within six to eight weeks following the birth of their babies. However, a new 
mother or father may wish to spend more time with an infant beyond the time 
needed for physical recovery. Increasingly, employers are offering what is known 
as parental leave for those employees who want or need more time to be full-time 
parents to a new baby or a newly adopted child. 

Parental leave is not a new concept. Among the world's industrialized countries, 
the United States and South Africa are the only two that do not have national 
policies that guarantee leave for the purpose of parenting or family care. The 
parental leave policies of six European countries (Austria, Germany, France, 
Italy, Finland, and Sweden) guarantee from 12 to 52 weeks of leave, with 60-100% 
salary retained during all or part of the leave. Canada offers 17-41 weeks of 
parental leave, with 15 weeks at 60% salary guaranteed. 

Many employers, including city or county governments and fire departments, have 
recognized parental leave as a policy that can benefit both workers and their 
employers. Parental leave policies may be negotiated into contracts, developed 
by managers as standard practices, or passed as local ordinances. In general, 
parental leave policies are gender-neutral: because parental leave is different 
from the type of leave needed for physical recovery from childbirth, either 
parent would be eligible for this type of leave. Four months of unpaid leave is 
a standard parental leave in this country, although some employers provide up to 
a year. In an increasing percentage of cases, such leave may also be used for 
elder care: employees who require time off work in order to care for an ill or 
bedridden older relative. 

Legislation guaranteeing access to unpaid parental leave for most U. S. 
employees was passed by Congress in 1991 and 1992, but the legislation was 
vetoed both times by the President, who nonetheless stated that employers should 
offer this type of leave to their employees. The bill that was passed included 
care of a critically ill or injured family member as a valid reason for using 
parental (or "family") leave. 

Fire departments have just begun to recognize the value of parental leave as a 
way of retaining good employees and of improving morale. Of fire departments 
from across the country surveyed in 1990, fewer than half provided some form of 
parental leave for all employees. One department allowed only one day of leave 
for a father when his child was born. The trend, however, is for fire 
departments to consider more realistic policies 
for parental leave and to extend these benefits to both partners involved in 
child-rearing, regardless of their gender. 

--47 --

Firefighters have unique requirements when it comes to child care. Most need 
something other than the normal day time care options that are commonly 
available. Firefighters' children often need non-parental child care for more 
than 24 hours at a time. Many firefighters are subject to emergency call-back 
during major incidents, and may need someone to take care of their children on a 
moment's notice at any hour of the day or night. Two-firefighter couples or 
single parents are especially affected by these circumstances. The problem 
particularly affects women firefighters: 31% of women firefighters are married 
to or involved with other firefighters; 11% are, or have been, single parents. 

Many cities and private employers are beginning to take an interest in the child 
care needs of their employees. They recognize that child care problems cause 
absenteeism, poor productivity and morale, and may lead to the loss of good 
employees. Problems with child care are a significant reason why women may not 
enter the fire service, may leave early in their careers, or may not return 
after having children. 

Although governments and private employers are giving more attention to this 
issue, most existing programs address only the needs of employees who work 
relatively conventional hours. The few employers' who support child care centers 
for their workers most often maintain these centers only during extended 
business hours. Centers that can accommodate 24-hour child care or emergency 
drop-ins at any hour are virtually non-existent. Other management practices that 
may help some employees with child care problems, such as job-sharing and 
flexible hours, are either not feasible or not often practiced for firefighters. 

Creative solutions are needed and have begun to emerge. One fire chief has 
suggested that his city develop old fire stations into around-the-clock child 
care centers 

Problems with child care are a significant reason women may not enter the fire 
service, may leave early in their careers, or may not return after having 
children. 

specifically for the benefit of firefighters' children. "We found that some 
qualified people do not apply for the job because they're concerned about what 
they'd do with their kids," he said. "I don't think it benefits the department 
if qualified people get away because of that." 10 (I In the U. K., the London 
Fire Brigade provides child care allowances to parents who pay babysitters, and 
subsidizes spots in child care centers for its employees' children. 11 The 
Suisun City, California, Fire Department has increased the off-duty response of 
its full-time personnel to major incidents by outfitting and staffing one of its 
rehab vehicles to handle child care. Firefighters responding to the call can 
drop off their children at the fire station or at staging, to be cared for by 
members of the rehab team for the duration of the incident. 12 Other fire 
departments provide child care during off-duty training sessions, to encourage 
greater participation. Positive examples are also being set by some hospitals 
and airlines, which have many employees who need child care at unusual hours. 

As single-parent families and two-firefighter couples become more common, the 
issue of child care for firefighters will become increasingly important to fire 
service managers. Problems with child care can prevent individuals from entering 
the fire service or may influence their career tracks once they are there. The 
burden falls most heavily on women with children, especially single mothers. 

--48 --

Fire departments have historically had a strong family tradition. Sons have 
followed fathers into fire service careers for generations. Brothers have served 
side by side as career or volunteer firefighters. Now that women are an integral 
part of the fire service, a new family tradition has emerged. Although women may 
follow their fathers (or mothers) into the fire service, and sisters and 
brothers may both choose firefighting vocations, the most common type of 
familial relationship between male and female firefighters is that of marriage. 

According to Women in the Fire Service's 1990 survey, 20% of all women 
firefighters surveyed were married to firefighters. Another eleven percent were 
involved in permanent or long-term relationships with other firefighters. Most 
of the marriages were between firefighters on the same department, and the 
majority of marriages and relationships developed after both employees were 
hired. 

It should not be surprising that these figures are so high. Once a person has 
finished school, the workplace is the most likely place to meet friends, social 
partners, or mates. This is true in any profession, but seems especially so with 
firefighters. The nature of the job, particularly 
the unusual hours and work environment, can make a conventional social life 
difficult. Strong bonds of friendship and loyalty have always developed among 
firefighters who work closely together under difficult circumstances. It is 
natural that these same feelings would develop between men and women 
firefighters, and that good friendships might potentially lead to further 
involvement or commitment. 

Fire departments have reacted to this trend of firefighter relationships in 
widely varying ways. Some have taken a completely laissez-faire attitude and 
have not interfered in any way with firefighter couples, even allowing them to 
continue working in the same station together. Other departments have taken the 
opposite approach, attempting to impose very restrictive policies on these 
employees. An extreme case of this type of policy was one that prohibited 
marriages between employees and made marriage to another firefighter a cause for 
dismissal. The policy was made effective retroactively so that the one woman on 
the department (who was married to a co-worker) would be affected. Another 
example would be of departments that attempt to discover which couples are 
dating or otherwise emotionally involved with each other, and reassign one or 
both parties. Such policies go beyond legitimate employer concerns into the 
realm of harassment, resulting in unnecessary stress for the employees as they 
attempt to conceal relationships and even marriages from their co-workers. 

Policies against nepotism (favoritism to a relative) are a legacy of 19th-
century political "spoils" systems and were originally put in place to prevent 
local political officials from appointing their relatives to jobs. They are 
stronger in some parts of the country than others; of fire departments recently 
surveyed, less than a third had a formal written anti-nepotism policy. Some 
policies included strong statements such as the following: 

The employment of relatives in the same organization tends to have a number of 
undesirable results. In the interest of preventing potential abuses in hiring, 
supervisory authority, or the appearance thereof, it is the policy of the City 
to limit hiring and supervision of relatives by City employees. 

Others took a more moderate approach: 

The department recognizes that there are many situations where two individuals 
who have a personal relationship may appropriately be allowed to work in the 
same program, activity or location without adverse impact. However, under 
circumstances where work, safety, morale, or impartial supervision is 
demonstrably and adversely impacted by a personal relationship, the affected 
employees may be accommodated by the reassignment of one or the other. 

Some anti-nepotism policies apply to all employees of a city or county 
government, not just the fire department. These policies may not be enforced at 
all in some cases, or may be enforced unevenly from department to department or 
individual to individual. Such inconsistency in the enforcement of a policy can 
create exactly the type of problems that the policy is designed to prevent. 

The anti-nepotism policies of some cities restrict the hiring of relatives but 
do not address the potential for employees to become related through marriage 
once both individuals are employed. Restrictive policies written specifically to 
address couples on the job may require the transfer or career limitation of one 
or both employeesaffected. Since women firefighters often have less seniority 
and lower rank than their partners, such policies may have a disparate, negative 
impact on women employees. 

Relationships in the workplace are a fact of life. They need not be viewed as a 
problem to be solved or as a situation to be prevented. Where real problems do 
exist, either with the couple themselves or due to co-workers' or managers' 
resentment of the couple, they should be dealt with individually. Perhaps the 
best policies are ones that take into account job performance as they seek to 
manage relationships in the work environment. It is possible to develop policies 
that both respect the rights and privacy of individuals and maintain a 
professional work environment for all employees. 

--49--

The issue of hair standards continues to be unresolved for firefighters of both 
genders, There are several reasons for the continuing controversy as it relates 
to women. Many departments are still hiring their first women and so are just 
going through the process of addressing their hair standards. It also appears 
that as women become more a part of the fire service, both new and experienced 
women firefighters are becoming less willing to sacrifice a favored hair style 
simply to comply with standards that were designed for a male workforce. As the 
fire service moves away from a paramilitary organizational approach to its 
employees, fire service managers in general are adopting a more flexible 
approach to employee grooming standards. 

A fire chief who takes an extreme approach, such as requiring all employees to 
have military-style short hair based on male norms, is demonstrating the 
department's hostility to the presence of women and may be risking a sex 
discrimination charge since, based on traditional hair styles, most women would 
be excluded from the job while most men would not. The search for a clear answer 
is made more difficult by discrepancies in the way the courts and the EEOC have 
decided hair-rule challenges; these discrepancies have contributed to the 
confusion that surrounds the issue. 

This section of the manual will explore the legal background for firefighter 
hair-length requirements, from the perspective of both the EEOC and the courts. 
It will discuss the two primary reasons for fire departments to have hair-length 
policies, and offer guidance in policy development. Although this section does 
not explicitly address related grooming issues such as the wearing of jewelry, 
some references to jewelry are provided in the sample policy language on page 
51. 

The legal background 

The courts have generally allowed employers more latitude in establishing work 
rules for hair length than they have in dealing with "physically immutable" or 
unchangeable characteristics such as height. Many early cases were brought by 
men, including police officers and firefighters, challenging standards which 
prohibited long hair on men. Since the mid-1970's, the courts have consistently 
held that prohibiting long hair for male employees is not sex discrimination 
under Title VII if the employer's grooming standards for both sexes are related 
to community standards and are applied in an even-handed manner. 13 The courts 
have made a distinction between hair standards and issues where discrimination 
affects "fundamental rights" or is based on immutable characteristics." ' 

The judicial and administrative branches of the government disagree on a basic 
point of sex discrimination law as it affects hair and appearance standards on 
the job. The courts have defined Title VII as a weapon against sex-linked 
practices that seriously impair fair employment, but have decided that the law 
was not intended to interfere with employers who wish to set reasonable 
appearance standards required by their business. The Federal Equal Employment 
Opportunity Commission (EEOC), on the other hand, has consistently treated 
different appearance rules for men and women as constituting sex discrimination 
under Title VII. 15 At the same time, the EEOC has upheld reasonable safety 
hazard concerns in industry. 

While the applicability of Title VII to hair standards is thus undecided, the 
constitutional protections afforded to employees in the workplace are clearly 
limited. Numerous cases have been brought on constitutional grounds. In these 
cases, employees have argued that appearance is an aspect of personal liberty, 
so that any interference with that "right" must be justified by a legitimate 
state interest. The courts, in response, have generally upheld a public 
employer's right to impose grooming regulations that can be justified by the 
need for discipline, uniformity and esprit de corps, even where no safety 
considerations exist. 16 

However, a 1992 case filed under Louisiana constitutional law resulted in a 
ruling against a public employer, the City of Shreveport. At issue was the 
city's attempt to restrict firefighters' hair to shoulder length or shorter. 
(Women had been on the fire department for eleven years and had previously been 
permitted to pin their hair up to conform with the hair standard.) In issuing an 
injunction against the employer, the judge found that "the regulation (was) not 
gender neutral" because it affected women differently from men and "ha( d) the 
effect of classification of individuals on the basis of sex." The ruling 
continued: 

Similarity of appearance can be and was in fact achieved by requiring fire 
personnel on duty or in uniform to have their hair, if longer than regulation 
length, pinned to meet a length requirement established by their employer. The 
esprit de corps and equal treatment as togrooming standards are easily achieved 
by uniform enforcement of hair length while on duty or in uniform with a 
recognition of an individual's right to have whatever length of hair he or she 
desires as long as while on duty or in uniform it is kept to a level set forth 
in the employer's regulation... While similarity of appearance has been 
recognized as an appropriate and rational goal in a "para-military" civilian 
service, commonality may not and should not be required at the expense of reason 
and purpose." 

--50 --

Safety vs. grooming 

Apart from the legal aspects, confusion also exists on hair-length issues 
because fire departments have, in the past, required firefighters to have short 
hair for two different reasons: because it was, with the prevailing protective 
gear, safer during firefighting operations, and because it looked neater, more 
professional, or more uniform. Where these two reasons have become intertwined 
into one policy, it is necessary to sort out the real and justifiable reasons 
for the policy. 

A safety standard is gender-neutral: fire will burn exposed hair regardless of 
the sex of the person whose head it's on. Advances in protective equipment in 
recent years have made it possible for firefighters to have much longer hair 
than in the past and still be much safer than ever. SCBA facepieces and flame-
resistant hoods and helmet liners insure that all surfaces on the head are 
protected. For this reason, many fire departments have adopted a safety-based 
hair standard that simply states that "No hair shall be exposed during 
firefighting activities." This approach avoids the need to regulate the actual 
length of the hair, and bases its restriction simply on the justifiable need for 
firefighter safety.* 

Establishing a policy that is based solely on grooming and appearance concerns 
has a more favorable impact on women, for while a safety standard must be 
gender-neutral, a grooming standard need not be. Even though the EEOC disagrees, 
the courts have consistently held that employers can legally require male 
employees to wear their hair shorter than female employees and that such 
policies do not constitute illegal sex discrimination. 

*In the mid-1980's. the Madison, Wisconsin. Fire Department administration, 
which had previously had a policy requiring extremely short hair for both men 
and women firefighters. reassessed the need for such a policy. In doing so, it 
determined that long hair, if not exposed during firefighting operations, was no 
more dangerous than short hair, and in fact the bulk of hair pinned up inside 
the helmet actually offered insulating protection to the firefighter's head. The 
policy was changed to a "safety only" standard. 

Examples of language from fire department hair-length and grooming policies

"Hair shall be neatly groomed and the length or bulk of the hair shall not be 
excessive or present a ragged, unkempt or extreme appearance. (Men:) Hair may 
cover one half of the ear but shall not cover the entire ear. (Women:) Hair may 
not extend beyond the lower part of the shoulder blades. 

"Members are discouraged from wearing rings or other jewelry on the fire or 
training ground. Female members may wear earrings providing they do not extend 
below the bottom of the ear." 

(Women:) "Hair must be clean and neatly arranged. When in uniform, back hair 
must not fall more than one-quarter inch below the lower edge of the collar. No 
hair must show under the front brim of fire service headgear. Afro, natural, 
bouffant, and other similar hair styles are permitted, but... bulk of hair must 
not exceed two inches. In no case is the bulk of the hair permitted interference 
with the proper wearing of fire service headgear. 

"Only pins, combs or barrettes that are similar in color to the individual's 
hair color may be worn to meet the requirements of the regulation. Jewelry which 
extends beyond the ear lobe or... is loose or protrudes and may catch in 
machinery or equipment may not be worn while on duty." 

"It is recognized that traditionally acceptable standards for female hairstyles 
differ considerably from those of males. Female hairstyles that would normally 
not conform to the standards outlined in this S. O. P. may be pinned up or 
secured in order to comply while on duty. In these instances, the hair must be 
pinned up or secured at all times while on duty, and shall not interfere with 
the proper wearing of uniform hats or protective equipment, or in any way create 
a safety hazard." 

(Men and women:) "There are many hair styles that are acceptable. So long as the 
person's hair is kept in a neat, clean manner, the acceptability of the style 
will be judged by these criteria: Hair styles that preclude the proper wearing 
(of SCBA) are not permitted... Hair will be worn so that it does not extend 
below the bottom of the uniform shirt collar while standing in an erect 
position. Hair may be pinned or worn in a way to keep hair above the bottom of 
the collar..." 

"To facilitate a professional appearance, hair and grooming standards must be 
followed. These standards havebeen modified to meet contemporary styles without 
jeopardizing the safety of firefighters involved in the hazardous activities 
associated with firefighting. 

"When in a normal standing position, the hair can extend to the top of the 
collar area. Hair will not extend beyond the bottom of the earlobe. Longer hair 
is acceptable if it is pinned up in a neat manner and does not interfere with 
the wearing of departmental headgear. No ribbons or ornaments shall be worn in 
the hair except for neat inconspicuous bobby pins or conservative barrettes 
which blend with the hair color. Hair... will not exceed two inches in height." 

--51--

Policy development 

Firefighter hair length can easily become a controversial issue within a 
department. From a common-sense perspective, even if not a legal one, finding a 
solution requires a balancing of employee and employer interests. For the 
employee, hairstyle is a matter of personal identity, and a preferred hair 
length can not be put back on at the end of a work shift in the way that a 
uniform is removed. The employer's responsibility for personnel safety and their 
interest in a professional appearance can encompass a wide diversity of hair 
lengths and styles. The best grooming standard may well be one that screens both 
sexes on a community-based standard of dress and appearance, a standard that 
applies an equal burden to both sexes. 

--52--

Most fire stations in use today were planned and built with a single-gender 
workforce in mind. Many of these buildings are now being used by a workforce 
that includes both women and men. Not surprisingly, this can result in 
inadequacies that are a source of inconvenience, discomfort, embarrassment, and 
friction for all concerned. Different fire departments have developed a variety 
of solutions to the problems created by inadequate facilities. The cheapest and 
easiest answers are usually the first to be implemented: a "men/ women" or 
"occupied/ unoccupied" flip sign on the door of the station's only restroom or 
shower, or a lock on the door, can be readily installed. Makeshift partitions, 
such as a row of lockers or a rollaway curtain, can often be put up between beds 
if bunkroom separation is desired. These are short-term solutions to real or 
perceived needs concerning personal privacy in the fire station. The underlying 
question that guides the development of long-range answers is whether men and 
women on the job should be provided with separate facilities or not. 

The legal background 

The expense to the employer of providing separate restrooms, showers, locker 
rooms and bunkrooms for women and men usually will not support excluding women 
from an occupation.' s According to the EEOC Guidelines, 

Some states require that separate restrooms be provided for employees of each 
sex. An employer will be deemed to have engaged in unlawful employment practice 
if it refuses to hire or otherwise adversely affects the employment 
opportunities of applicants or employees in order to avoid the provision of such 
restrooms for persons of that sex. 19 

An even more emphatic provision occurs in the 
Guidelines of the Office of Federal Contract Compliance: 

The employer's policies and practices must assure appropriate physical 
facilities to both sexes. The employer may not refuse to hire men or women, or 
deny men or women a particular job because there are no restroom or associated 
facilities, unless the employer is able to show that the construction of the 
facilities would be unreasonable for such reasons as excessive expense or lack 
of space. 20 

In one case where a firm had refused to hire a woman welder on the grounds that 
its repair yard lacked locker and restroom facilities for women, the EEOC 
discovered that the employer had actually had separate facilities during World 
War II when it had many women workers. 21 Since the existence of male-only 
facilities is often the result of the past discrimination that Title VII was 
designed to eliminate, allowing cost as a defense would only honor and 
perpetuate that discrimination. 

One state law that applies to some fire stations is Section 2350 of the 
California Labor Code. It requires that business establishments that have five 
or more employees must provide separate bathrooms for each sex, and that no 
person may use bathrooms designated for the opposite sex. An interesting 
question that has come up regarding interpretation of this law is whether a fire 
station that normally houses a crew of four could be considered at shift change 
to "have" eight employees, particularly if it is common practice for the 
oncoming crew members to arrive early in order to take showers and change their 
clothes. Other states may have comparable provisions in their labor codes or 
other laws. 

Local building or health codes usually require employers to provide bathrooms, 
and sometimes other facilities, for each gender in the workplace. As most fire 
stations are the property of municipal or county government, they have generally 
been made exempt from the provisions of these codes. Where such exemptions do 
not exist, of course, the fire department would be responsible for compliance. 

A few fire departments assign women only to stations that "have facilities for 
women." This is not generally considered an acceptable long-term solution, 
particularly where there is an appreciable difference in the kind of work 
carried out at the different stations -a lighter or heavier call load, different 
types of apparatus, specialty teams-or where station assignments are on a 
seniority bid basis and the woman would otherwise be entitled to bid for the 
off-limits stations. The result can be an unworkable inflexibility for 
management, particularly if it prevents women from "roving" or "floating" to 
certain stations for one or a few shifts. It can also generate resentment from 
maleco-workers that the woman doesn't have to take her turn at roving, 
particularly if her low seniority would normally make this part of her job. And 
it is unfairly restrictive of the woman, if she is not permitted to make shift 
exchanges or time trades with firefighters at certain stations. 

The impact of inadequate facilities 

One fire service observer, commenting on the problem of inadequate station 
facilities, wrote: 

Under the best circumstances, bad facilities are an inconvenience which women 
suffer from in far greater proportion. Under the worst conditions, 
poorfacilities can lead to problems with morale and job performance, and an 
increase in the occurrence of harassment. At least one discrimination lawsuit 
has been filed which was due in part to inadequate facilities. A lawsuit costs a 
lot more than a locker room, and in the end, no one wins. 

When the need for women's facilities in the fire station is neither recognized 
nor addressed, the... 

--53--

department may be saying that women are not important enough here to deserve 
decent facilities, that women may not be around long enough to warrant planning 
for the future, that women are not wanted at this station, and this is a 
reasonable way to keep them out; or that we are too busy here to consider the 
real needs of our personnel. All of these are harmful messages, both for women 
and for the organization of which they are a part. 22 

There are two common effects of forcing firefighters in a newly integrated 
workforce to occupy inadequate facilities. One is that the women are blamed for 
"causing" the problem. Even though it is the design of the station that is 
lacking, the feeling among the men is often that since "there wasn't a problem 
until she got here," it's the woman firefighter's fault. Solutions such as 
bumping an officer out of his private room to give it to the woman can generate 
a similar resentment. Where this type of hostility exists, providing facilities 
that offer privacy for both genders becomes only half of the solution. It is 
important for management to make it clear that alterations to the facilities are 
being done not "for the women" but for better privacy for women and men alike. 

Women and men in the workforce -and particularly women, if they are in the 
minority or are the newest firefighters -will usually adapt to situations that 
are less than ideal... But just because a person... can develop behaviors to 
cope with a situation or environment doesn't mean it's right to leave things 
that way indefinitely. 

Another common reaction to inadequate station facilities is the tendency to 
adapt and accommodate to them. Women and men in the workforce -and particularly 
women, if they are in the minority or are the newest firefighters -will usually 
adapt to situations that are less than ideal. Many women firefighters do not 
routinely shower at work, or they get up an extra hour early in the morning in 
order to shower before the men need the shower facilities. Women have learned to 
use broom closets as changing rooms; firefighters of both genders develop the 
habit of looking for feet under the restroom stall walls. But just because a 
person or group can develop behaviors to cope with a situation or environment 
doesn't mean it's right to leave things that way indefinitely. All firefighters 
deserve some basic privacy, either individually or by gender, for personal 
functions. Management should make it a priority to provide this. 

Possible solutions 

Develop a five-or ten-year plan for remodeling your firehouses. All new stations 
that are built, and any significant remodeling of existing stations, should 
include adequate facilities for a two-gender workforce. Women may not be on the 
department now, but most fire stations will stand for a half century or more. To 
continue to build them on old designs means you will only be creating more of 
the same type of problem that firehouse designers fifty years ago created for 
you today. 

Although crews in many fire stations manage to cope quite well with shared 
facilities, it is preferable for station design to provide privacy for both 
sexes in restroom, shower, and changing areas. The issue of separate bunkrooms 
for women and men is more controversial. As mentioned earlier, taking an 
officer's room away to give to a woman firefighter usually creates hard 
feelings. Tucking an ad hoc "women's bunkroom" off in one corner of the station 
(such as a rollaway bed in the weight room) is inconvenient for everyone and a 
clear message that the woman doesn'tbelong. The most common solution is for 
women and men to share the one existing bunkroom. Many women firefighters prefer 
this arrangement, because it keeps them a part of the crew and a part of the 
information-sharing process that begins as soon as a call comes in. On the other 
hand, some men and women are not at all comfortable sharing a bunkroom in this 
fashion. 

The real long-term solution to the bunkroom question is to provide privacy for 
everyone. Many new firehouses are now being built to a design that features 
cubicles containing a bed, desk, lamp, and three or four lockers 
(for one person on each shift), with a curtain across the doorway. This provides 
privacy and a reduction of sound or light from theothers in the room. (Snoring 
may be a common source of humor among firefighters, but 
routinely being deprived of sleep by one or more snoring co-workers is also a 
significant source of job-related stress.) If the partitions do not extend all 
the way to the ceiling, the open space at the top allows for air circulation and 
allows emergency tones and information to be 
heard. 

This is a solution that pleases everyone and doesn't pit the women against the 
men, the paramedics against the suppression personnel, or the officers against 
the firefighters. It also avoids controversies over whether the women's bunkroom 
in the new station should be the same size as the men's bunkroom, whether men 
are allowed to use the women's bunkroom if no women are assigned to the station 
on that shift, whether a station that houses two officers should have men and 
women officer's bunkrooms, etc. It is a solution that respects the privacy and 
individuality of all firefighters without regard for gender, and for that reason 
is usually supported by all concerned. 

--54--

Notes: 
1 New York Times, January 17, 1986. 
2 Willing, Linda, "Maternity Survey," Women in the Fire Service Quarterly. 
Summer 1987, pp. 1-6. 
3 Women in the Fire Service, 1990. 
4 42 U. S. C. 2000e (K) 
5 See EEOC Questions and Answers on Pregnancy Discrimination, C. C. H. 3951 
(April 20, 1979). 
6 California Federal Swings & Loan v. Guerra, 107 S. Ct. 683,42 F. E. P. 1073 
(1987). 
7 Supreme Court of the United States, No. 89-I2I5. UAW v.. Johnson Controls 
Inc.. majority Court opinion delivered by Justice Blackmun on March 20, I991. 
8 "Those surveyed were asked to describe... the ideal maternity policy. The vast 
majority outlined a policy that would provide light duty for the term of the 
pregnancy... then leave permitted during actual delivery and for three to six 
months after birth." Willing, Linda, "Maternity Survey." Women in the Fire 
Service Quarter/ y, Summer 1987, p. 4. 
9 Only two percent of all government and private employers sponsor day care 
centers for their employees' children, according to the U. S. Labor Department 
Bureau of Statistics (1988). 
10 Bowers, Karen, "Old firehouses may get rebirth," Rocky Mountain News, 8/ l8/ 
89: quoting Denver Fire Chief Richard Gonzalez. 
11 Allcock, Ann, "Workplace Child Care and the London Fire Brigade," Women in 
the Fire Service Quurterly, Summer I991, pp. 8-9. 
12 Stevens, Larry H., "But who will watch the kids?" Fire Chief April 1992, pp. 
113-I14. 
13 Dodge v. Giant Food, Inc., 488 F. 2d 1333 (D. C. Cir. 1973); Baker v. Calif. 
Lund Title Co., 507 F. 2d 895 (9th Cir. 1974) cert denied, 422 U. S. 1046 
(1975); Longo v. Carlisle DeCoppet & Co., 537 F. 2d 685 (2d Cir. 1976); Earwood 
v. Continental Southeastern Lines, Inc., 539 F. 2d I349 (4th 
Cir. 1976); Barker v. Taft Broadcasting Co., 549 F. 2d 400 (6th Cir. 1977); 
Knott v. Missouri Pac. R. R. Co., 527 F. 2d 1249 (8th Cir. 1975). 
14 E. g., an employer's refusal to hire women with small children [Phillips v. 
Martin-Marietta Corp., 400 U. S. 542 (197l)] or the firing of women who marry 
[Sprogis v. United Airlines. 444 F. 2d 1194 (7th Cir. 1971)]. 
15 E. g.. EEOC Dec. No. 71-1529, 3 F. E. P. 952 (5/ 9/ 71). 
16 Quinn v. Muscare, 425 U. S. 560, reh'g denied, 426 U. S. 954 (1976) [male 
firefighter challenge to hair standard]; Kelley v. Johnson, 425 U. S. 238 (1976) 
[male police officer]. 
17 Sellers v. Citv of Shreveport, et al., 1992. The employer defended the policy 
as a grooming standard, stipulating that the safety of firefighters was not at 
issue. 
18 As a rule, expense will not support gender as a bona fide occupational 
qualification unless the expense would be clearly unreasonable. See EEOC Case 
No. YNY 9-047 (5/ 21/ 69), C. C. H. Empl. Prac. Guide 6010. 
19 29 C. F. R. 1604.2( b)( 5). 
20 4 I C. F. R. 60-20.3( e)( 1970). 
21 EEOC Dec. No. 70-558 (2/ l9/ 70), C. C. H. Empl. Prac. Guide 6137. 
22 Willing, Linda, "Bedrooms and Bathrooms: The Hidden Message," WFS Quarterly, 
Winter 1988-89, pp. 1-2. 

--55--

Only in about 5% of cases does the victim... report an incident of harassment. 
Rather than come forward with a complaint, women are much more likely to leave a 
job, request a transfer, or suffer in silence and hope the problem goes away. 

Sexual harassment is a form of sex discrimination. It is illegal, it can 
devastate those who experience it, and it often destroys the morale and 
productivity of the work environment. It is also widespread in the fire service: 
at least 60-74% of women firefighters have experienced some form of sexual 
harassment at work or in their volunteer departments, from relatively minor 
incidents up to sexual assault and rape. 1 

Sex discrimination on the job occurs when employment decisions are based on 
an employee's sex instead of his or her qualifications. Sexual harassment occurs 
when an employee receives unwelcome behavior from the employer (or someone under 
the employer's control) that only happens because of the employee's sex. There 
are two types of sexual harassment. "Quid pro quo" harassment involves demands 
for sexual favors in return for employment benefits. "Hostile environment" 
harassment involves behavior motivated by the target's gender that makes the 
workplace offensive, hostile or intimidating. (See inset below for examples.) 

The key concept in defining and identifying sexual harassment is that it is 
unwelcome. Sexual harassment is not "natural," "normal," or a "compliment." It 
is a power play by the harasser that is degrading and humiliating to the target. 
The common motivation for sexual harassment is aggression, not sexual desire. 
The physical appearance and behavior of the target are not the "cause" of sexual 
harassment. Sexual harassment of all kinds is increasingly viewed as a form of 
violence against women. (The vast majority of harassers are men, and most 
victims of harassment are women.) 

Even though sexual harassment is a common occurrence, it is widely 
misunderstood. Persistent myths that tend to trivialize it include the idea that 
women secretly enjoy the sexual attention, and that a woman who brings sexual 
harassment charges is probably lying to get back at someone. Although there are 
legal sanctions and, usually, employer policies against it, sexual harassment is 
grossly under-reported. Studies consistently indicate that only in about 5% of 
cases does the victim (or "target") report an incident of harassment. Rather 
than come forward with a complaint, women are much more likely to leave a job, 
request a transfer, or suffer in silence and hope the problem goes away. 

Examples of "quid pro quo" harassment: 

"If you'll go out with me tomorrow night, I'll make sure you get all the 
training you need to make your probation." 

'You're not driving the engine unless you give me a kiss." 

"I'll be on the interview board for your promotion. If you expect me to give you 
a good rating, you'd better sleep with me." 

Examples of "hostile environment" harassment: 

Unwanted touches, kisses, and other personal/ sexua1 attention 
Referring to women in derogatory, vulgar, and/ or sexual terms 
Posting of graphic or violent pornography in the workplace 

--56--

The tendency for women not to report harassment is just as strong in the fire 
service as it is in other workplaces. Following are representative comments from 
women firefighters who have been harassed but not reported it: 

I didn't want to be labeled a troublemaker, and I didn't feel a positive outcome 
was possible. 

Much of the harassment occurred when I was on probation and felt I could not 
speak out... I did attempt to speak to my officers; all of them shrugged off my 
appeals for help. 

I didn't want to be "singled out" even more. 

I want to keep my job. It's clear that those who seek legal recourse can't come 
back to work. 

I overlook most of it and just keep on going. 2 

Women's reluctance to report incidents of sexual harassment stems from several 
sources. First, the interactions involved are very personal and of a nature that 
many individuals are not comfortable discussing. Second, a woman's socialization 
encourages her to feel sorry for the harasser or to believe that something in 
her own behavior caused the harassment. Third, targets of harassment may sense-
often with justification -that complaining would do no good and might even make 
matters worse. Sexual harassment is an intimate violation that often occurs 
without witnesses. Women who are its targets generally feel powerless to stop 
it. Women firefighters, who are usually subjected to strong pressures to "go 
along to get along," and to fit in and be "one of the guys," are especially 
deprived of most forms of support in trying to put a stop to workplace 
harassment.

People who are targets of sexual harassment exhibit a wide range of responses to 
the behavior. Charac-teristically, most do not feel that many options are open 
to them, and they therefore may respond in ways that are not effective in 
getting the behavior to stop and do not help management learn that a problem 
exists. Typical responses fall into several recognizable categories. 

Detachment: joking, removing oneself from the seriousness of the problem 

Denial: pretending the problem doesn't exist 

Relabeling: excusing the behavior, telling oneself the harasser "was just trying 
to be friendly" 

Appeasement: trying to placate the harasser 

Self-blame

Endurance: putting up with the situation 

Avoidance: quitting one's job or requesting a transfer 

Social support: counseling, seeking out others who have been harassed 

Confrontation: informing the harasser that their behavior is unwelcome 

Reporting 3

Denying that sexual harassment is a problem simply because women fail to report 
it, ignores the ways in which women are forced to submit to harassment or deny 
that it is happening to them. Given these pressures, a target of harassment 
cannot be said to be "tolerating" or "voluntarily submitting" to the behavior if 
she fails to  complain about each and every incident. Women may be reluctant to 
report sexual harassment for a number of reasons. 

Lack of confidence in the system: believing the employer will do nothing to stop 
the problem 

Fear of retaliation: fearing the harassment will get worse, or the employer will 
retaliate in some way 

Fear of loss of privacy: being concerned that the target's personal life and 
past will be dragged in as somehow relevant to the harasser's behavior 

Isolation: lack of support systems for reporting in the first place; loss of any 
friends or allies in the workplace if the target "rocks the boat" 

Embarrassment 

Financial need 

Sense of guilt: unwillingness to get an otherwise "nice guy" in trouble 

Socialization 

Women's unwillingness to report incidences of sexual harassment is often 
justified in view of the "victim- blaming" that can occur when complaints are 
made, and of the types of retaliation that often follow. 

The law on sexual harassment 

The EEOC Guidelines define illegal sexual harassment as follows. 

Unwelcome sexual advances, requests for sexual favors, and other verbal or 
physical conduct of a sexual nature constitute sexual harassment when: 

(1) submission to such conduct is made either explicitly or implicitly a term or 
condition of an individual's employment, 

(2) submission to or rejection of such conduct by an individual is used as the 
basis for employment decisions affecting such individual, or 

(3) such conduct has the purpose or effect of unreasonably interfering with an 
individual's work performance or creating an intimidating, hostile, or offensive 
working environment. 

[Source: 29 C. F. R. 1604.11.] 

--57--

Sexual harassment is illegal under federal law, 4 state, local or municipal fair 
employment laws, state tort laws,* and some state unemployment and workers' 
compensation laws. It is also a violation of some collective bargaining 
agreements. The first court case to define sexual harassment as a form of 
discrimination was decided in 1976. 5 The federal Equal Employment Opportunity 
Commission (EEOC) first issued guidelines on sexual harassment in 1980. 6 
Another landmark was established in 1986, when a unanimous Supreme Court 
affirmed that employees have a right to a work environment that is free of 
sexual harassment. 7 Noting that Title VII forbids discrimination in "terms, 
conditions and privileges of employment," the Court agreed with the EEOC that 
Congress intended, through Title VII, "to strike at the entire spectrum of 
disparate treatment of men and women in employment,"* including non-economic 
injury (" hostile environment"). [Title VII of the Civil Rights Act of 1964, as 
amended, is the federal law banning discrimination on the basis of race, 
religion, sex and national origin.] 

Some courts have taken the position that if the harasser makes sexual overtures 
to or engages in harassing conduct with employees of both sexes, or if the 
conduct is equally offensive to men and women workers, the plaintiff does not 
have a remedy under Title VII. Even in such cases, however, the plaintiff might 
still have a claim under state or local laws, depending on the jurisdiction. 

Hostile work environment harassment is particularly a problem for women who 
enter a predominantly male field such as firefighting because rough language, 
sexual jokes, "centerfold" postings, sex-based videotapes or television 
programming such as X-rated cable channels, touching, gesturing, and frequent 
comments about clothing, body, lifestyle and behavior are excused as "normal" 
hazing or treatment as "one of the boys." Some courts have found in favor of 
employers whose workplace is "permeated by an extensive amount of lewd and 
vulgar conversation and conduct," 9 if the complainant initiated and 
participated in theconduct. This perspective, however, fails to take into 
account the social pressures on women in non-traditional jobs to become accepted 
by adapting to the highly sexualized male cultural norms of the workplace. 

Subjectivity of offensiveness: the "reasonable person" and "reasonable woman" 
standards 

Helpful though it would be, it is impossible to make a comprehensive list of all 
behavior that could constitute sexual harassment. Many situations must be 
examined individually; what is harassment in one case may not be in others. This 
can seem confusing until one focuses on the key concepts: "unwelcome," 
"intimidating or hostile," and "interfering with work performance." What is 
important is the effect of the questionable behavior on its target or, in some 
cases, on others in the work environment. 

Only "unwelcome" conduct can be considered sexual harassment, but behavior that 
is amusing to one person may be unwelcome to another. In cases that go to court, 
the court must determine whether the complainant was actually offended or 
oppressed by the conduct in question. The court will also look at whether the 
complainant's reaction to the offensive behavior was "reasonable." Courts are 
still struggling with what standard determines whether the complainant's 
reaction to arguably abusive conduct was "reasonable." Some courts have adopted 
a "reasonable person" standard: the harasser's conduct must be such that it 
would affect the work performance and psychological well-being of a reasonable 
individual, as well as being actually offensive to the particular complainant. 
Not surprisingly, the social attitudes of particular judges have played a large 
part in determining what the reasonable person is expected to endure. However, 
many people expect this to change dramatically as these cases begin to be heard 
by juries pursuant to the Civil Rights Act of 1991. [See Appendix 1 for a 
summary of the 1991 Civil Rights Act.] 

Recent legal factors affecting sexual harassment litigation 

Many observers expect the passage of the 1991 Civil Rights Act to give a 
significant boost to sexual harassment lawsuits. For the first time, the law 
permits a jury to hear these allegations. Juries, compared to the judges who 
have heard these cases to date, may be more likely to display shock and outrage 
over harassment. This may translate into damages: also for the first time, the 
law permits compensatory and punitive damages to be awarded in sexual harassment 
cases. 10 

Another boost to sexual harassment lawsuits also came in 1991 when a federal 
judge approved the first class-action lawsuit for sexual harassment." 
Previously, sexual harassment suits have only been brought by individuals. Class 
action lawsuits have a greater impact and permit harassment victims to pool 
their resources. The Eveleth case was brought by three women iron miners and 
claims that all 100 women who worked or applied for work at the mine were 
subjected not only to discrimination in hiring and in terms and conditions of 
employment, but also to a pattern of sexual harassment and a hostile work 
environment. 

*Applicable laws might include those prohibiting intentional infliction of 
emotional distress, wrongful discharge, contract interference, invasion of 
privacy, and assault and battery.

--58--

Stopping sexual harassment: the fire chief's role 

Fire chiefs of career, volunteer, and paid-on-call departments who wish to 
minimize problems of sexual harassment should consider the following steps. 

Adopt written policies prohibiting sexual discrimination and sexual harassment, 
and a workable, confidential, step-by-step procedure for the filing of 
complaints. 

Provide training for all personnel -firefighters, officers, and support staff -
on multicultural issues, including sexual harassment. Anti-woman behavior is 
part of the dominant culture of many firehouses and should be addressed as such. 
These sessions should facilitate discussion, and not simply consist of reading 
the department's policy and considering everyone to have been "trained." 

Remember that "what you permit, you promote." Do not ignore harassment. To do so 
sends the message that you are in agreement with the harassing behavior or 
discriminatory attitudes. Do not place all of the burden for reporting and 
correcting the problem on the harassed individual or group. Each stage of 
prejudiced behavior encourages the next; extreme behavior develops when more 
subtle behavior is permitted to continue. 

Support -do not discourage -people who bring complaints of harassment to your 
attention. Handle complaints confidentially and in a timely manner. An open-door 
policy goes a long way towards resolving problems at the lowest level, long 
before the chief is faced with a polarized situation or an expensive lawsuit. 

Prevent retaliation against those who have filed complaints, and against any 
witnesses who support their allegations. If the charge is found to have merit, 
discipline the harasser appropriately. Don't "solve the problem" by transferring 
the target to a new station against his/ her will. 

Ensure personal privacy for everyone in station accommodations. Lack of privacy 
increases the tensions and resentment that lead to harassment. 

Keep in mind that just because you do not hear about sexual harassment occurring 
does not mean that it is not there. Use exit interviews (interviews with people 
who leave the job) as a reality check. A good manager will want to understand 
the reasons behind an employee's request for a change in status, whether it is 
an application for transfer or a notice of resignation. 

Be a role model. Avoid patronizing behavior or tokenism toward any group; be 
aware of language, policies, images, or situations that have questionable gender 
or racial connotations (e. g., the term "non-white") and correct any 
stereotyping that occurs. Be aware of, and correct, behavior that reflects your 
own prejudices. 

The Sixth Circuit has taken the position that a woman surveyed said they would 
be complimented if they were who "voluntarily" enters a workplace must take it 
as she finds it. 12 The woman's workplace in that case included pictures of nude 
women, and a co-worker who routinely referred to women by derogatory sexual 
epithets. The court held that the obscene language might be "annoying" but not 
"startling" to the reasonable person because society condones, openly displays 
and commercially exploits erotica in public places such as newsstands, 
television and the movies. One judge, in a partial dissent, criticized the 
majority' s "what you see is what you get" attitude. The dissent pointed out 
that the "reasonable person" standard fails to take into account the divergence 
between women's and men's views of appropriate conduct. 13 (For example, in one 
study, 67% of men propositioned by a woman at work. When women were asked if 
they would take such a proposition from a man in the workplace as a compliment, 
only 17% said yes. 14) 

The Sixth Circuit decision failed to recognize the difference between 
pornography encountered in private life and in the workplace. Such material on a 
home television, in the movies or on the newsstand can be turned off, not 
attended, or avoided. Erotica and pornography in the workplace are usually 
displayed so that they cannot be avoided. Further, the not-so-subtle message of 
the material, and of its presence being condoned in the workplace, is that the 
sexual objectification and trivialization of women workers is acceptable. 

--59 --

Other courts, recognizing that a woman's perspective may differ substantially 
from that of a man, have adopted the "reasonable woman" standard. The Ninth 
Circuit, and district courts throughout the country, have concluded that 
pornographic posters and language could seriously affect the psychological well-
being of the reasonable woman and interfere with her ability to perform her job. 
15 In a case involving nude calendars posted at the workplace, the court stated: 

The proliferation of [pornographic] material may be found to create an 
atmosphere in which women are viewed as men's sexual playthings rather than as 
their equal co-workers. 16 

Less clear-cut from a legal standpoint are calendars, posters and advertisements 
that show women partially dressed and posed in sexually attractive ways ranging 
from "cute" to "seductive." Because these women are 
often portrayed as firefighters, such material sends the message that how a 
woman looks has some relevance to how she does her job. They also convey a very 
confusing message on sexual harassment, since many fire service men have only a 
vague understanding of what does or does not constitute harassment. Such 
material is an insult to women's professionalism, as it encourages people to 
judge women firefighters on the basis of physical attractiveness rather than 
legitimate standards of performance. Exploiting and stereotyping groups of 
people to appeal to or titillate other groups is degrading; the fire service 
must reject such behaviors as other professional organizations have done. 
Stereotyping of women as sexual objects should be prohibited in the same way 
that unacceptable ethnic portrayals are. 

Examples of ways women firefighters have been sexually harassed on the job or in 
their volunteer fire departments: 

"An officer put moves on me. I rejected him and was treated badly." 

"There's nothing I can prove. Obscene things put in my bed, locker, gear. I feel 
more aggravated, let down, lonely, like I'll never be totally accepted." 

"Comments like, 'It's much better when you work in a t-shirt. We can see your 
(breasts) better." 

"Continuous! Posters on walls, asking for dates, requests for sex, hugging, 
touching, leering, urinating in front of me, being screamed at that I don't 
belong here..." 

"I am harassed all the time. Most of the men are not well educated and have 
never related to a woman in other than sexual terms. They do not know how to 
treat a woman as an equal." 

[Source: Survey of women fire fighters, Women in the Fire Service, 1990.] 

Constant remarks about the physical attributes of women, and using curse words 
or sexual terms to refer to women (co-workers and others), are also degrading 
and offensive to many women workers, even if they themselves are not the object 
of the commentary. Such behavior, whether it is unintentional harassment or a 
form of "hate speech" intended to hurt the listener, serves to isolate women 
from their male co-workers. Striking a balance between protecting the minority 
group member from the intimidating effect of such speech and the speaker's First 
Amendment rights is an area of the law generating considerable controversy. 
Rules intended to prohibit and punish hate speech, from municipal regulations to 
college campus rules, are being challenged in a variety of legal contexts. But 
as the workforce changes its composition to include more women and more people 
of color, employers and co-workers will find that previously "acceptable" 
behavior and speech will not be considered acceptable within the new cultural 
standards of the workplace. 

Gender-based "non-sexual" harassment 

The EEOC definition of harassment refers to conduct "of a sexual nature." Courts 
have held that actions that contain no sexual element but are directed against 
an employee because of her or his gender are also illegal sexual harassment. 17 
Illegal discriminatory conduct based on gender that interferes with women's 
working conditions has been excused by some employers and co-workers as an 
acceptable or "natural" reaction by men to the change occasioned by women 
entering the firehouse workplace. In the fire service, such illegal conduct has 
included refusal to trade shifts, train, work with or eat with the woman 
firefighter, as well as interference with her gear or personal property. In such 
situations, courts will look at the "pervasiveness" of the conduct and whether 
there was also harassment that was explicitly sexual. However, pervasiveness is 
not defined just by length of time; the offensiveness of the individual actions 
is also considered. l8 

A female employee need not subject herself to an extended period of demeaning 
and degrading provocation before being entitled to seek theremedies provided 
under Title VII. 19 

Lewd language, pornographic materials, vandalism to personal property, and 
anonymous telephone calls can indicate a hostile work environment and be 
actionable under Title VII even if it is unclear who is responsible for the 
acts. 20 Harassing conduct that has not yet caused psychological damage but 
hasimpacted on anemployee's work habits and may seriously affect the 
psychological well-being of the employee in the future, may create an illegally 
abusive work environment. 21 Courts have also held that the observance of sexual 
harassment of others could create a hostile environment. 22 

--60 --

Stopping sexual harassment: the station officer's role 

All station officers or acting officers, whatever their rank, are responsible 
for maintaining a harassment-free work environment in their stations. 
Departmental procedures may assign the officer a specific role or 
responsibilities in the harassment complaint procedure, but even in departments 
that have no clear anti-harassment policy, first-line supervisors are in a 
crucial position with respect to preventing sexual harassment. 

Stop any behavior occurring in your station or crew that is clearly harassment. 
In order to do this, you must be able to identify harassment when it occurs and 
to deal with it fairly, effectively, and quietly. If the training provided by 
your department on these issues is inadequate, use your own initiative to get 
additional training and information. 

Educate your crew on what does and does not constitute harassment. This should 
be a routine part of departmental training, but if your fire department does not 
offer such training, or if the training has been inadequate, consider developing 
and implementing a comprehensive anti-harassment training program for the people 
you supervise. Every fire department employee should have a working knowledge of 
sexual harassment as well as of the department's policies and procedures. 

If a member of your crew brings a complaint of sexual harassment to you, be 
supportive. Do not downplay the reported incident or attempt to make excuses for 
the behavior. Follow through on the complaint swiftly, impartially, and without 
discussing it with those whom it does not concern. Targets of harassment will 
not feel free to use the system if they fear that the whole station will 
immediately know of their complaint. Nor is it fair to someone who has been 
accused of harassment for the accusation to be made known, particularly if it 
should turn out to be unfounded. Only those directly involved should know of the 
complaint; those called as witnesses should be cautioned not to discuss the 
matter with others. 

Prevent any kind of retaliation against the person who has filed the complaint. 
Harassment targets often believe that filing a complaint would do no good and 
would probably only make matters worse. If this kind of attitude prevails in 
your fire station, harassment will not be reported and will only escalate, 
creating a nightmare for the officer as well as for the target( s). 

Do not overreact to harassment, but do not fail to act. Discipline should follow 
the department's established guidelines, and should reflect whether the offense 
is the individual's first or just the latest in a long series; it must also be 
appropriate for the severity of the behavior. A firefighter guilty of attempted 
sexual assault would logically be disciplined more severely than one who brought 
copies of pornographic magazines to work. 

Creating a harassment-free work environment includes stopping harassment by 
those who are not in the workforce. Be alert to discriminatory or harassing 
behavior by visitors to the stations: members of the public, friends of 
firefighters, equipment salespeople or repairers, and others. Handling these 
situations will require tact and diplomacy, but any person who behaves in that 
way must be made aware that you do not support their behavior or attitude, and 
that they will not be welcome in the station if the behavior continues. 

--61--

If a co-worker is being sexually harassed 

Many workers who would never harass anyone themselves are guilty of tolerating 
harassment that occurs in their workplace. Some onlookers may mistake the 
target's silence for acceptance; others may not want to get involved or may fear 
losing the camaraderie of their co-workers by being a "spoilsport." Fair-minded 
and supportive co-workers, however, will refuse to condone harassing behavior in 
the workplace. Your support of the target, as a friend or a witness, can be 
crucial to her becoming aware that the behavior need not be tolerated. 

If you observe behavior at work that seems questionable, don't assume it's 
welcome just because the recipient doesn't complain. Talk with her privately, 
letting her know that you felt the behavior might be inappropriate. Especially 
if she is a new recruit or brand new in the station, remind her that she doesn't 
have to accept unwelcome sexual behavior, whether it involves comments, physical 
contact, pornographic posters or videotapes. Emphasize to her that she has your 
support in getting the behavior to stop. 

If the behavior is clearly harassment but the target is unwilling to take steps 
to stop it, talk with the harasser in private. Let him know that you find the 
behavior inappropriate and that it's not okay with you. If your own work 
environment is being made uncomfortable by the sexual behavior of others, you 
have the right to ask that the behavior stop, or even to file a sexual 
harassment complaint yourself. 

If you think your own behavior towards a co-worker, present or past, might be or 
might have been harassment, stop the behavior. To determine where to draw the 
line between friendly behavior or joking and harassment, consider: 

-Is there an equal exchange? 
-Would you do or say the same thing to your mother or father? To another person 
of your gender? 
-Would you want to see coverage of your behavior on the six o'clock news? 

Ask the co-worker about it, privately. Let him or her know that the behavior 
will not continue if it's a problem, and that you can still be friends. If, 
after you've asked about the behavior, you're still not sure about it, stop the 
behavior anyway. There are hundreds of different ways for women and men to 
interact enjoyably and professionally in the workplace; don't risk harming a 
positive work relationship by behaving in ways that make either of you 
uncomfortable. 

Liability for sexual harassment 

An employer may be held absolutely liable for acts of quid pro quo harassment by 
employees who function as supervisors or as surrogates for the employer. (" 
Absolutely liable" means that the employer is liable even if it had no actual 
knowledge of the acts.) The court are divided on whether absolute liability 
applies to "hostile environment" harassment. The Supreme Court has rejected 
blanket employer liability, but has also held that absence of notice to an 
employer does not always insulate the employer from liability, even when the 
employer established an anti-discrimination policy and grievance procedure, and 
the employee failed to use it. The Court also found that the employer's lack of 
actual knowledge will not necessarily protect the employer from liability. If 
the harassment is sufficiently pervasive, the employer will be assumed to have 
"constructive" 
knowledge. 23 

The EEOC Guidelines emphasize that employers have an affirmative obligation to 
prevent sexual harassment: 

Prevention is the best tool for the elimination of sexual harassment. An 
employer should take all steps necessary to prevent sexual harassment from 
occurring, such as affirmatively raising the subject, expressing strong 
disapproval, developing appropriate sanctions, informing employees of their 
right to raise and how to raise the issue of harassment under Title VII, and 
developing methods to sensitize all concerned. 24 

The EEOC Guidelines also state that an employer is responsible for harassing 
acts of its agents, regardless of whether the acts were forbidden by or known to 
the employer. 25 If anemployer fails toinvestigate, investigates but bungles or 
fails to follow its own grievance procedures, or fails to take appropriate 
corrective action, a fact-finder may find grounds for employer liability. Some 
cases have mentioned adopting a "reasonable employer" approach. Employers have 
also been held liable for the acts of non-supervisory employees and even of non-
employees, where the employer knew, or should have known, of the conduct and 
failed to take immediate and appropriate corrective action. 26 

--62--

If you are being sexually harassed 

Fire department employees who are the targets of sexual harassment should:

Know the department's policies prohibiting sex discrimination and sexual 
harassment, and the procedures for filing a complaint. 

Politely and firmly tell the harasser to stop, in front of witnesses if 
possible. If you are unable to confront the harasser directly, write a letter 
and give it to the harasser in the presence of a witness. Keep a copy of the 
letter in a safe place, not at work. Or speak to your supervisor, to Personnel 
or to an EEO officer. 

If the harasser repeats the conduct, inform your supervisor immediately and 
follow it up with a note or letter to the supervisor. Again, keep a copy in a 
safe place, not at work. It is important that you give notice of this offensive 
behavior to your employer and that you have a record that you did so. (Courts 
will generally only hold an employer liable for sexual harassment where it can 
be shown that the employer knew, or should have known, about the conduct.) 

Document all incidents in a diary with time, place, names of witnesses, what was 
said or done, and an exact account of your response and any physical or 
emotional stress you experienced. Keep this log in a safe place, not at work. 

Talk with other women on the job or who have left the job, especially those who 
have worked with the harasser in the past; they may also have been targets. Do 
not be surprised or discouraged if other women do not support your decision to 
fight or report the harassment. 

Keep records of all positive evaluations, promotions, etc., in the event that 
your complaint results in retaliation against you by your employer, officer, or 
other firefighters. 

Contact your union, labor organization or employee group for assistance. If you 
work under a contract, be familiar with its anti-harassment clauses and with 
your rights under the by-laws of your union. 

Contact women's organizations for support. You are not the first woman to be 
victimized by this kind of behavior. Some chapters of the National Organization 
for Women (NOW) sponsor support groups for victims of harassment, and many 
chapters of 9 to 5 can give you support as well. Other women's professional and 
trade groups, such as Women in the Fire Service, may be able to offer advice and 
resources. 

Be aware that sexual harassment, and the decision to take action against it, are 
very stressful. Take advantage of any employer-sponsored employee assistance 
programs. Try not to internalize guilt. Any incidents of sexual harassment that 
happened to you were not your fault, the harasser did not "mean well," and he 
was not doing it because he likes you. Sexual harassment is not something you 
have to tolerate because you chose to enter a non-traditional field; you do not 
have to adapt to the ways of your co-workers "at any cost. " If you have friends 
and co-workers who can offer support, including corroboration of incidents, 
depend on them. Be aware, however, that the general public is largely uneducated 
and often unsympathetic on this issue. 

If informal or internal remedies fail to stop the harassment, if you 
lackconfidence in the internal remedies (for example, if the person in charge of 
investigating your complaint is the one who is harassing you, or has threatened 
retaliation), or if you are retaliated against for complaining about the 
harassment, you should consult an attorney. Seek out a lawyer who has experience 
in handling employment discrimination complaints. Try to obtain private counsel, 
even though local, state or federal human rights agencies may assign a staff 
attorney to handle your formal complaint. The women's bar association or working 
women's advocacy groups may be able to refer you to an experienced attorney. 

File a formal complaint with the federal Equal Employment Opportunity Commission 
or with your state or local Fair Employment Practices agency. There are specific 
time limits for filing such complaints, depending on whether the harassment is 
continuing or retaliation occurred, and whether your state or locality has an 
FEP agency. Title VII requires that you file with the EEOC within 180 days of 
the last act of discrimination. In areas with state or local FEP agencies, that 
time period is extended by 90 days if you filed with the local agency first; 
some states require you to file with the local agency first. To protect 
yourself, file as soon as possible. You may wish to file the charge and then ask 
that it be held while you attempt to resolve the problem internally. You can 
always drop the charge if matters are resolved to your satisfaction. 

--63--

The following is a generic anti-harassment policy that may suggest ideas or 
provide language for the development of a policy for your fire department. No 
such policy should be implemented without considering your department's specific 
needs or seeking qualified legal advice. 

The Fire Department is committed to providing a harassment-free work environment 
for all persons, regardless of their race, sex, religion, color, age, handicap, 
national origin or sexual orientation. Any employee who engages in such 
harassment, who permits employees under his/ her supervision to engage in such 
harassment, or who retaliates or permits retaliation against an employee who 
reports such harassment, is guilty of misconduct and shall be subject to 
remedial action which may include the imposition of discipline up to and 
including discharge. Retaliation against witnesses or persons who participate in 
the investigation of harassment is also misconduct, and offenders may be subject 
to discipline up to and including discharge. 

In the workplace, constitutionally protected speech does not include ethnic or 
sex-related slurs, unwelcome sexual advances, the display of derogatory graphic 
materials, verbal or physical conduct of a racial or sexual nature, or other 
forms of harassing conduct. This type of behavior is unprofessional, and 
produces an uncomfortable work environment. It will not be tolerated. 

Some departments write the EEOC's definition of sexual harassment (see page 56) 
into their policy. lf state law or local ordinances provide a more comprehensive 
definition, it may also be included. This information may be expanded by 
providing specific examples of unacceptable behavior such as the following. 

Sexual harassment includes, but is not limited to, the following: 

Unwelcome or unwanted sexual advances, including patting, pinching, brushing up 
against, hugging, cornering, kissing, fondling, or any other similar physical 
conduct considered unacceptable by another individual; 

Requests or demands for sexual favors, including subtle or blatant expectations, 
pressures or requests for any type of sexual favor accompanied by an implied or 
stated promise of preferential treatment or negative consequence concerning 
one's employment status; 

Verbal abuse or kidding that is sexually oriented and considered unacceptableby 
another individual, including commenting about an individual's body or 
appearance where such comments go beyond mere courtesy; telling "dirty jokes" 
that are clearly unwanted and considered offensive by others, or any sexually-
oriented comments, innuendos or actions that offend others; 

Engaging in any type of sexually-oriented conduct that would unreasonably 
interfere with another's work performance, including extending unwanted sexual 
attention to someone that reduces personal productivity or time available to 
work at assigned tasks; 

Creating a work environment that is intimidating, hostile or offensive because 
of unwelcome or unwanted sexually-oriented conversations, suggestions, requests, 
demands, physical contacts or attention or display of posters, photos or 
calendars. 

The more "entry points" there are into the complaint process, or ways a 
complaint can be filed, such as with the supervisor, through the City' s EEO or 
personnel officer, the department's human relations committee, etc., the more 
likely it is that targets of harassment will make use of the procedure. 

Complaint procedure 

Individuals who experience sexual harassment should make it clear to the 
offending person that such behavior is offensive to them. 

Upon the occurrence of an act of sexual harassment, or upon repetition of such 
acts, the victim should immediately report the incident to her or his 
supervisor, to the department's EEO counselor, or the Personnel Department's 
sexual harassment counselor. All employees are assured that they may make such 
reports without fear of retaliation or reprisal by the City, Department 
management, or their supervisors. 

The employee has the right to speak in private with the person to whom the 
sexual harassment complaint is made, or to have a witness to the harassment 
present. 

Each complaint of sexual harassment will be fully and completely investigated by 
the department's EEO counselor or by the Personnel Department's sexual 
harassment counselor. All investigations will be handled with discretion, 
sensitivity and due concern for the dignity of those involved, and will be as 
thorough as necessary. Anyone who is alleged to have committed acts of sexual 
harassment will be contacted during the investigation and permitted to make a 
statement. 

All persons named as potential witnesses by the employee will be contacted as 
required during the course of the investigation. Any employee who has observed 
the incident( s) of sexual harassment should cooperate in the investigation. All 
employees are assured that they may cooperate in such investigation without fear 
of retaliation or reprisal by the City, Department management, or their 
supervisors. 

--64 --

Employees may expect a timely resolution of all complaints. 

The policy should inform employees that even if they do not use the City's 
complaint process, they do not lose theprotection of state and federal law. 
information about state FEP and federa1 EEO complaint procedures should be made 
available to all employees: 

An employee may take advantage of the formal grievance procedure in resolving 
the complaint. An employee may also file a complaint with (or seek advice from) 
the City's Equal Employment Opportunity coordinator without going to a 
departmental superior. The employee may decline to use the City's procedures and 
file a complaint directly with the state Department of Human Relations or with 
the U. S. Equal Employment Opportunity Commission. S/ he may also file with 
either of these agencies while simultaneously pursuing the City's complaint 
procedure. 

Information and advice about sexual harassment may be obtained by contacting the 
Personnel Department's sexual harassment counselor. 

Supervisors' responsibilities 

All supervisorsand acting supervisors shall maintain a working environment which 
is free and secure from occupational hazards including sexual harassment. Any 
intrusion into the work location of any element which can cause an undue 
interference to an employee's performance of assigned duties shall not be 
tolerated. Supervisors should demonstrate by their own conduct that they 
arecommitted to providing a workenvironment free of harassment. Supervisors 
shall at all times refrain from harassment and retaliation and should counsel 
and instruct subordinates in defining and preventing harassment. 

Supervisors or acting supervisors shall immediately deal with any act of sexual 
harassment of which they become aware. If the supervisor or acting supervisor is 
unable to make a resolution or feels the incident is likely to go to the 
grievance stage, s/ he shall notify the EEO Officer within 24 hours. Every 
precaution shall be taken to ensure confidentiality at this informal 
information-gathering stage. This shall be followed by a written report. 

The supervisor or acting supervisor shall immediately investigate any complaint 
of sexual harassment, and move to have any such incident resolved. Supervisors 
will notify the fire chief any time an employee complains of harassment or of 
conduct which could constitute harassment. 

When employees report harassment by citizens, supervisors shall use all 
appropriate means to stop the harassing conduct. The supervisor shall promptly 
inform the department head or division head about the report and what was done 
to resolve it. 

Confidentiality 

All employees shall cooperate in investigating complaints of harassment. The 
nature of harassment violations, particularly those involving sexual harassment, 
requires a high degree of confidentiality and flexibility in approaches to 
investigation and resolution. All employees shall keep their communications in 
such an investigation confidential and shall disclose them only to City 
officials and employees who need the disclosure in order to perform their 
duties. 

Notes: 

1 Women in the Fire Service survey, 1990; Sunset Associates/Diane Sanchez 
survey, 1991. These findings are consistent with sexual harassment data from 
women in other fields: for example, in a 1990 survey of women in the military, 
two-thirds said they had been sexually harassed. Overall estimates of the 
percentage of women in the workforce who have been sexually harassed range 
upwards of fifty percent. National Council for Research on Women, Sexuul 
Harassment: Research and Resources, 1991, p. 9. 
2 Ibid. 
3 Fitzgerald, Louise F., Y. Gold, and K. F. Brock, quote in National Council for 
Research on Women, Sexual Harassment: Research and Resources, 1991, p. 11. 
4 Title VII of the Civil Rights Act of 1964, as amended, 42 U. S. C.  2000e et 
seq. 
5 Williams v. Saxbe, 413 F. Supp. 654 (D. D. C. 1976); 587 F. 2d 1240 (D. C. 
Cir. 1978) order vacated and case remanded. 487 F. Supp. 1387 (D. D. C. 1980) 
[after trial de novo sexual harassment determined to exist] 
6 29 C. F. R. 1604.11. 
7 Meritor Savings Bank v. Vinson, 106 S. Ct. 2399. 
8 Id. at 2404. 
9 Gun v. Depro Circuit Systems, 28 F. E. P. 639 (E. D. MO. 1982). Also see 
Swentek v. USAIR, Inc., 830 F. 2d 552, 557 (4th Cir. 1987) finding that the 
appropriate inquiry is whether the complainant welcomed the particular sexual 
antics complained of and not whether she "was the kind of person who could not 
be offended by such comments and therefore welcomed them generally." 
10 The Civil Rights Act does not permit punitive damages against government 
employers. It also limits the amount of compensatory and punitive damages to no 
more than $50,000 to $300,000, depending on how many employees work for the 
employer. 1977 A( b)( 3) of the Revised Statutes as added by Civil Rights Acts 
of 1991 102. Such damages in cases of harassment on racial or ethnic grounds 
are not limited; in 1992, legislation was in Congress that would remove the caps 
on damages in sexual harassment cases. Compensatory damages are available for 
"future pecuniary losses, emotional pain, suffering, inconvenience, mental 
anguish, loss of enjoyment of life, and other non-pecuniary losses." Id. 

--65--

11 Jenson v. Eveleth Taconite Co., 139 F. R. D. 657 (D. C. Mn. 1991). 
12 Rabidue v. Osceola Refining Co., 805 F. 2d 611 (6th Cir. 1986), cert. denied, 
107 S. Ct. 1983 (1987). 
13 See also Brooms v. Regal Tube Co,. 881 F. 2d 4 12 (1989), where the Seventh 
Circuit aligns itself with the Sixth Circuit analysis that both objective and 
subjective standards (a "dual-pronged" test) are appropriate in determining 
whether there was a hostile work environment. 
14 Goleman, D., "Sexual Harassment: It's About Power, Not Lust," New York Times, 
October 22, 1991; C1 , C12. 
15 Ellison v. Brady, 924 F. 2d 872 (9th Cir. 1991 ), Robinson v. Jacksonville 
Shipyards, 54 F. E. P. 83 (M. D. Fla. 1988); Jenson v. Eveleth Taconite Co., 139 
F. R. D. 657 (D. Ct. Mn. 1991); Barbetta v. Chemlan Services, 669 F. Supp. 569 
(W. D. N. Y. 1987). 
16 669 F. Supp. at 573 
17 See McKinney v. Dole, 765 F. 2d 1129, 1138 (D. C. Cir. 1985); Hall v. Gus 
Construction Co., 842 F. 2d 1010, 1013 (8th Cir. 1988); Hicks v. Gates Rubber 
Co., 833 F. 2d 1406. 1415 (10th Cir. 1987); Bell v. Crackin Good Bakers Inc., 
777 F. 2d 1497 (11th Cir. 1985). 
18 See Carrero v. New York City Housing Auth., 890 F. 2d 569. 578 (2d Cir. 
1989). 
19 Andrews v. City of Philadelphia, 895 F. 2d 1469, 1485 (3d Cir. 1990): "The 
pervasive use of derogatory and insulting terms" could be probative of a 
sexually hostile environment. 
20 Id. 
21 Howard v. Dept. of Air Force, 877 F. 2d 952, 955 (Fed. Cir. 1989). 
22 EEOC v. Gurnee Inn Corp., 48 F. E. P. 871, 879 (N. D. 111. 1988), aff'd, 914 
F. 2d 815 (7th Cir. 1990). 
23 Meritor Savings Bunk v. Vinson, op cit. 
24 29C. F. R. 1604.11( f). 
25 29 C. F. R.  1604.11( c). 
26 Non-supervisory co-worker EEOC Guidelines 29 C. F. R. 1604.11 (d); cases 
include Hall v. Gus Construction, 842 F. 2d 1010 (8th Cir. 1988) [incidents of 
harassment were so numerous that the employer was liable for failing to discover 
what was going on and remedy it]. According to case law, the non-supervisory 
harasser is not himself liable under Title VII [he may be under tort or other 
local law] because he is neither an employer nor an agent of an employer under 
Title VII. Non-employee EEOC Guidelines 29 C. F. R. 1604.11( e); cases on the 
issue of employer liability for harassment by non-employee( s) include EEOC v. 
Sage Realty Corp., 507 F. Supp. 599 (S. D. N. Y. 1981) [revealing uniform led to 
many incidents of harassment by non-employees]. 

As a fire department begins to include more minority group members and women in 
its ranks, it undergoes change: a change from a "monocultural" workforce (in 
this case, white male) to a multi-cultural one. This transition can leave 
firefighters and officers of the dominant group feeling threatened, angry and 
resentful. On the other hand, it can be dealt with pro-actively to validate and 
channel people's reactions, and improve communication and understanding. 
Training on cultural diversity issues comes under many names: "Employment Equity 
Training," "Anti-Harassment Education," "Professionalism and Human Awareness," 
etc. By any name, the training is an important tool in managing a workforce that 
is in cultural transition. 

Incumbent firefighters sometimes write cultural diversity training off as 
"special treatment for the women." " They didn't have any classes like that for 
me when I came on," is a common reaction. But hiring women doesn't just mean 
that some of your firefighters will be called Stephanie and Jackie instead of 
Steve and Jack. Women firefighters represent a change not just in the workforce, 
but in how many male firefighters perceive the job, themselves, and even women 
in general. One primary purpose of cultural diversity training in the fire 
service is to help employees-incumbent male firefighters in particular-through 
those stresses and transitions. 

The litigation that can result from discriminatory practices is expensive. The 
reason to do cultural diversity training, however, is not to "stay out of legal 
trouble" or to keep your employees from getting into trouble. Managers provide 
cultural diversity training for themselves and their workforce because it's 
smart and because it promotes fairness. Disharmony and discrimination are 
expensive even if things never go as far as a lawsuit. They can be costly in 
terms of factors that can not be assigned a dollar value: poor morale, a high 
turnover of employees (particularly from just those groups you are trying to 
recruit and retain), or a discredited reputation for the department within the 
community. Cultural diversity training is not about "staying out of trouble" or 
about "coddling" women or people of color. It is about managing change 
aggressively and progressively. 

Some managers have been slow to recognize that miscommunication between men and 
women in the workplace has a strong cultural component. But male culture is the 
dominant culture of the firehouse. The more forcefully that culture expresses 
itself in the work environment, the more difficult it will be for many women to 
find productive and happy careers there. Understanding differences between women 
and men as cultural differences lifts the burden from individuals; training on 
these issues gives all firefighters the tools to create a more harmonious 
workplace. 

Cultural diversity training is not about "staying out of trouble..." It is about 
managing change aggressively and progressively. 

--67--

The goals of cultural diversity training 

Cultural diversity training is not designed to change people's attitudes. It 
focuses instead on their behavior in the workplace, and emphasizes that whatever 
one's beliefs, one has the obligation to behave fairly to others at work. 
Learning to value diversity means learning that no one, including oneself, has 
all the answers. Several fire service realities breed and reinforce prejudice 
and narrow vision on the part of the dominant group (white men). These include: 

A tradition of cultural dominance that is now being threatened by social change 
and systemic upheaval; 

The dominant group's ignorance of or unfamiliarity with other cultures; 

The dominant group's failure to perceive itself as just one culture out of many; 
and 

Direct competition for limited rewards. 

Fortunately, other factors offer room for thedevelopment of acceptance and 
harmony. Many of the factors that strengthen the bonds among white male 
firefighters can extend to minority and women firefighters as well: 

A common purpose on the job; 

Frequent contact with each other in the pursuit of common goals; 

The sharing of intense experiences; and 

Mutual interdependence in critical situations. 

Good cultural diversity training will identify the forces that encourage 
intolerance, and find ways to employ and build upon the cohesive forces to 
combat the destructive ones. 

The training should make it clear that it is the workforce that is 
multicultural, not just the women and minority men. Employees should gain an 
awareness of how they fit into the mosaic and how their view of "reality" 
influences and limits how comfortable they are with people who are different 
from themselves. The training should also recognize that new issues arise when 
racial stereotypes are added to sexual stereotypes: for example, white male 
stereotypes about African-American women are different from those about African-
American men or about white women. 

--68--

One department's approach to cultural diversity issues 

The Prince George's County, Maryland, Fire Department in 1991 undertook a unique 
approach to supporting workforce cultural diversity. Fire Chief Steven T. 
Edwards recognized that while the department had been progressive with respect 
to hiring women and minorities, its ability to manage workforce diversity had 
lagged. In response, he organized a two-day departmental conference entitled 
"Fireforce 2000." A group of Prince George's County firefighters and line 
officers whose make-up replicated that of Workforce 2000* was asked to develop 
recommendations for improving the management of cultural diversity that could be 
implemented in the department over an 18-24-month period. A conference setting 
was chosen because it would permit greater employee participation in decision-
making and a freer flow of information and ideas. 

The conference included general sessions in which speakers identified the 
conference objectives and presented information on demographic trends in the 
workforce and the nature of cultural diversity issues. A licensed social worker 
with expertise in organizational effectiveness and gender issues assisted the 
participants in examining their own issues, recognizing the impact of 
stereotypes on their lives, and creating a safe atmosphere within the conference 
where sensitive issues could be discussed without anyone feeling attacked. A 
videotape on how mental frameworks limit people's thinking was also shown to 
help participants develop creative solutions to problems. 

For parts of both days, the participants formed smaller discussion groups to 
identify those problems and issues most critical to the department. Following 
brainstorming and evaluation, the small groups developed strategies in response 
to the problems, priorities, an implementation timetable, and methods for 
measuring the success of each strategy. 

After the conference concluded, representatives attended a meeting of senior 
management to present their ideas: a mentoring program for professional 
development, sensitivity training for all department members, improvements in 
the promotional process, etc. The group unanimously endorsed the idea of keeping 
"Fireforce 2000" together for ongoing meetings to monitor the developing 
programs and work on issues of continuing concern. 

* That is, simulating the anticipated ethnic and gender composition of the labor 
force in the year 2000. The Hudson Institute's 1987 report, Workforce 2000, 
predicts that white men will comprise less than half the workforce by the year 
2000, and that more than 80% of the net new workforce entrants will be women and 
minorities. 

[Thanks to Chief Steven T. Edwards and Major William Goodwin of the Prince 
George's County Fire Department for the above information.] 

Implementing cultural diversity training 

Some fire departments handle anti-harassment and cultural diversity training in-
house. Because hiring outside professionals can be expensive, the temptation to 
"just have Captain Smith take everyone through the material" often wins out. The 
disadvantages to saving money in this way are considerable. Most fire 
departments, as well as most city/county administrations, do not employ people 
who have expertise in this area. The individual( s) in charge of presenting the 
information and facilitating the discussions must be knowledgeable in cultural 
diversity issues and skilled in handling verbal conflicts and situations charged 
with strong emotions. When they are not, the training all too often consists 
either of simply reading through the department's anti-harassment policies and 
warning the attendees of the penalties for violations, or of unleashing a free-
for-all discussion on sensitive and controversial issues without being able to 
channel the energy positively or resolve the conflicts that arise. The result 
can be worse than not offering the training at all. 

When good cultural diversity training is made a management priority, it will 
also receive budgetary priority. Hiring a professional consulting firm to 
develop and deliver cultural diversity training for your department does cost 
money. It also means that you can hire trainers who have both expertise and 
experience, and makes it much more likely that the training will have a positive 
effect. 

The most realistic solution is to hire a trainer who will incorporate members of 
your department into the design and initial delivery of the program, and then 
hand off subsequent training to them. This helps negate the perception that an 
outside trainer does not understand firehouse reality, further demonstrates 
management's commitment to the program, and ensures the greatest possible "fit" 
between your needs and the program's content. The trainer should design a 
program that is geared to your department. Its schedule should accommodate 
firefighters' shifts, the geographic distribution of employees throughout the 
city or district, and the demands of emergency responses. The program's 

--69 --

design must reflect the department's current level of acceptance of diversity 
and address employees' primary issues and concerns. This should mean that the 
trainer will come into the stations and department headquarters to seek a wide 
range of personnel input before the exact content of the course is finalized. 

Volunteer fire departments can also benefit greatly from cultural diversity 
training. Disharmony within volunteer ranks can very easily lead to firefighters 
or officers leaving the department, a loss most volunteer organizations can not 
afford. Providing training that will help bridge cultural gaps and other 
interpersonal barriers can mean the difference between a smoothly running 
organization and an inefficient, unreliable one. 
It can also increase the possibility of recruiting new members from among 
previously excluded groups in the community. Financial constraints on volunteer 
departments will call for creative solutions to make the training possible. 
Consultants' donated time, joint training with other departments, and grants or 
other funds from community sources or state fire agencies, may all be options. 

For members of fire departments that do not provide cultural diversity training, 
other sources are often available. State fire academies may offer or be willing 
to develop programs that can be brought to individual departments or offered on 
a regional basis. Universities with governmental affairs departments will 
sometimes work with fire service agencies to develop and deliver programs. Many 
fire service conferences now offer workshops and speakers on cultural diversity 
issues and resources. The Commonwealth of Virginia holds an annual two-day EEO/ 
AA symposium for the fire service. (See inset.)

Guidelines for cultural diversity training 

Some consultants in workforce diversity deal primarily with ethnic issues. If 
you select trainers from outside your department, make sure they are also 
familiar with gender issues in male-dominated workplaces and have included those 
issues as an integral part of their curriculum -not simply tacked on some 
information about sexual harassment.

All personnel must receive the training, but education and the commitment to 
change start at the top. This means that cultural diversity and anti-harassment 
training are for the chief and senior staff as well as for the firefighters. All 
managerial personnel should receive specially designed training that addresses 
their needs and roles as supervisors. Members of the department's upper echelons 
should also be present at each training session for firefighters, not to 
supervise or to control behavior, but to listen and learn, and to demonstrate by 
their presence management's commitment to the program. It may be desirable to 
spend part of the time in 
smaller-group sessions where officers are not present, in order to facilitate 
discussion, but firefighters and line officers must see that the management team 
is also going through the training.

Group size should be limited to 20-25 attendees per session. Larger sessions 
tend to become lectures and do not provide time for each person to speak at any 
length. The ground rules for the discussion should allow  everyone to raise 
their concerns but make it clear that "beating up on" any one person or group 
will not be permitted. 

Cultural diversity training is not a "one-shot deal." The department should hold 
follow-up sessions for all personnel on a regular basis. These should not simply 
repeat and regurgitate the information presented in the original training, but 
should build on prior training to  improve understanding and communications. The 
trainer should devise an evaluation process that will gather feedback on the 
original training. Future sessions should incorporate changes based this 
information. Finally and importantly, training on cultural diversity issues 
should be included in the recruit curriculum or other basic firefighter training 
and in all officer training courses conducted by the department. 

A state source of cultural diversity training The Virginia Fire Services Board 
and Department of Fire Programs have held annual Equal Employment Opportunity/ 
Affirmative Action symposia since 1988. More than 300 people from several states 
attended the 1991 Symposium. The Symposium offers firefighters and officers an 
exposure to the basic concepts of cultural diversity, with the expectation that 
this opportunity for learning and increased awareness will have a positive 
impact on both attitude and behavior at work. Participants report favorably on 
both the content and impact of the symposia presentations: nearly 75% indicated 
that their attitudes towards minority and women firefighters had changed as a 
result of their participation in the event. (This is particularly noteworthy 
when considering that people who voluntarily attend such events are more likely 
to be relatively progressive or open-minded already.) 

[Information about the Symposium can be obtained from the Virginia Fire Services 
Board, Department of Fire Programs, Parham/ 64 Building, Suite 200; 2807 Parham 
Road: Richmond, VA 23294: phone 804/ 527-4236.] 

--70 --

There are no "quick fixes" or easy answers to the issues that surround workforce 
diversity. When a fire department diversifies -when it goes from being all white 
male to being fully inclusive of people of color and women -its leadership must 
also enter into a commitment to fair treatment, equal opportunity, and valuing 
diversity. Hiring a few women in order to "stay out of court" and dropping them 
to sink or swim in the male culture of the firehouse is reactive behavior, not a 
proactive policy. The transition from a monocultural to a multicultural fire 
service must be managed with intelligence and sensitivity. One battalion chief 
said of his department: 

The only reason this city has been successful in retaining large numbers of 
women firefighters is because of the individual women's ability to put up with 
an incredible amount of grief, and a few men's willingness to adapt and work 
things out. 

Those who promote change within an institution often face strong reactions. 
Those who represent change often become targets of that reaction. The fire 
service manager is in a key position to ensure that women firefighters do not 
shoulder the entire burden of fire service cultural transition. Fire 
departments, firefighters' union locals, and other fire service groups have 
developed a variety of methods for providing ongoing support to women and people 
of color on the job. Some of these are described in the following sections. 

Mentoring programs. 

These match up an incumbent firefighter with a newer firefighter, usually a new 
recruit. The mentor provides personal contact, information on unofficial "rules" 
and behavior standards within the organization, the benefit of the mentor's 
experience as guidance for the younger firefighter, and if need be, a 
sympathetic voice or a shoulder to cry on. Programs are voluntary and though 
facilitated by management, operate at the individual level to provide crucial 
support for the firefighter early in his/ her career or volunteer service. 

Workforce diversity steering committees, women's issues committees, human 
relations committees. These committees or task forces can operate within a fire 
department or union local, or on a city-wide or county-wide basis. Their 
function is to provide information to management and/ or union leadership 
regarding the 

When a fire department... goes from being all white male to being fully 
inclusive of people of color and women, its leadership must also enter into a 
commitment to fair treatment, equal opportunity, and valuing diversity. 

--71--

concerns of women and minorities on the job. (See inset on the San Diego Women's 
Issues Committee.) 

Local or national organizations of minority or women firefighters. (See Appendix 
3 for a list of national groups.) Local support networks of women firefighters 
are operating in many parts of the country. These can be informal groups that 
give a few women the opportunity to share problems and solutions over breakfast 
once a month, or more established organizations that hold regular meetings, put 
out a newsletter, and offer workshops and speakers on topics of interest. Their 
networking, support, and problem-solving functions can be critical to women's 
performance and longevity on the job. One local network of African-American 
women firefighters, for example, has developed a program that assists women in 
preparing for fire department jobs, from strength training on through the 
application and interview processes. 

Other sources of support. Many resources that are not gender-specific can offer 
services or resources that will help employees work through the stresses that 
accompany the process of cultural transition. These include Employee Assistance 
Programs (EAP's), departmental training in stress management, conflict 
resolution, and communications skills, and training for officers or officer 
candidates in leadership styles and personnel management. (See page 73 for one 
such program.) 

Departmental initiatives for identifying problems and solutions. Unique 
responses to the needs of individual fire departments are constantly being 
developed. (See inset on Prince George's County "Fireforce2000" conference, page 
69, for one example.) The range of solutions is as wide as the collective 
creativity of the people in your fire department can make it. 

One union's support of women 

Since 1985, the San Diego Fire Fighters (IAFF Local 145) have sponsored and 
supported a Women's Issues Committee. The committee exists to allow the union to 
have input from women firefighters about their concerns over issues such as 
parental leave, recruitment, uniforms, and station facilities, While the 
committee was created and is funded by the local's executive board, decisions as 
to how its members would be selected and how the committee would operate have 
been left up to its chair. 

The committee meets monthly at the union office and has full access to its 
facilities. A liaison person from the executive board and a secretary who takes 
the minutes also attend the meetings. The committee has been involved in 
projects such as the establishment of a maternity leave policy, development of a 
recruitment packet funded by the local, improvements in the fit of women 
firefighters' uniforms, and creation of a role-model program for new recruits. 

The impact of the committee has been both to make the local more responsive to 
women's needs, and to make women more interested in being involved with the 
local. As a result of the committee's work and the local's support, the name of 
the "California State Firemen's Association" was changed in 1990 to the" 
California State Firefighters' Association." CSFA has also established its own 
women's issues committee that serves as a resource to all California fire 
departments. 

The Women's Issues Committee of Local 145 is a creative response to gender 
integration concerns. Other IAFF locals have, with guidance from the 
International, established Human Relations Committees that serve a comparable 
purpose with respect to ethnic minorities as well. 

[Thanks to members of Local 145 and its Women 's Issues Committee for the 
information presented here.] 

--72--

Conflict resolution training 

In 1988, the San Francisco Fire Department entered into a consent decree over 
its hiring practices. This consent decree also contained a requirement that the 
department "establish and maintain an informal mediation process to handle 
internal disputes." In response to that mandate, the SFFD has developed a "Peer 
Mediation" program that attempts to resolve conflicts over small issues before 
they escalate into major conflicts and charges of discrimination or harassment. 

Under the program, volunteers from both uniformed and civilian personnel undergo 
an intensive training course in order to become peer mediators. The course is 
seven days long, eight hours a day, and takes place over a two-week period. 
Students spend the first two days learning to understand the elements of 
communication, the third day exploring sources of cultural conflict in the 
workplace, and the final four days learning and practicing the techniques and 
skills of mediation. 

Mediators are used in both formal and informal ways. Informally, they can use 
their training to defuse conflicts in their station, to communicate better with 
co-workers or subordinates, and to manage potential conflict situations 
encountered during emergency responses. Many of them have also reported being 
able to use the techniques off the job, to deal with situations at home. 

The formal process begins when two parties to a conflict agree to have their 
dispute mediated, and select a mediator from the department's list. The entire 
process is confidential and voluntary: either individual may withdraw at any 
point. The mediator uses a four-step process to assist the two sides to resolve 
the problem: 

1. Each person tells the mediator his/ her version of the situation. Ground 
rules require mutual respect (no name-calling, no interrupting) throughout the 
process. The mediator asks questions to clarify the issues and each person's 
feelings and fears about it. 

2. The mediator opens communication between the two, helping each to understand 
how the other views the conflict and is affected by it, and then has them talk 
directly with each other about specific issues. 

3. The mediator and the disputants discuss options for resolving the conflict, 
both this time and in case it arises again. 

4. The two jointly agree upon a resolution. 

The program was developed by a team of consultants and a fire department task 
force. When it was first established, ninety department members volunteered to 
be trained as mediators. As word of the program's effectiveness has spread, the 
list has continued to grow longer. A small group of the mediators has gone 
through an advanced course and will be providing in-service training for the 
department. 

[For more information about SFFD's Peer Mediation program, see the May/ June 
1991 issue of NFPA Journal for an article by Victoria Macklin, the department's 
Manager of Human Resources.] 

--73--

For firefighters to function optimally, their protective clothing must fit well 
and comfortably... A firefighter with ill-fitting protective equipment will be 
inefficient and more prone to injury. 

Firefighters' protective clothing and equipment must provide protection from 
heat and smoke. Hazardous materials gear is designed to provide an even higher 
level of protection. That is what the fire service has come to expect: 
protection. But for firefighters to function optimally, their protective 
clothing must fit well and comfortably without causing undue heat stress or 
adding excessive weight. A firefighter with ill-fitting protective equipment 
will be inefficient and more prone to injury. 

Over the years, studies have addressed the functions of fit, weight, and heat 
stress in various components of the firefighter's protective clothing. In 
Pittsburgh, for example, the fire department conducted a fit study with its SCBA 
facepieces. They found that 20% of their firefighters required large facepieces, 
and, overall, that the department needed all three sizes that the manufacturer 
offered. The department combined these three sizes with three sizes of nosecups, 
representing nine possible configurations of masks/ nosecups for maximized fit. 
NFPA 1500 (5-3.9) requires fit testing on an annual basis and permits only 
members with properly fitting facepieces to function in a hazardous atmosphere. 

Women in the Fire Service (WFS) conducted a national survey of women 
firefighters in 1990, to which more than 400 women responded. One section of the 
survey pertained to uniforms and protective gear. Eighty percent of the women 
reported that they had experienced fit problems with protective gear or uniforms 
at some time during their firefighting service; 45% of the career firefighters 
and 56% of the volunteers indicated that they still had problems with one or 
more items of ill-fitting gear. (See chart below.) 

Sources of women's protective gear and uniforms 

In the fall of 1991, WFS distributed a survey to gather information on sizing 
and NFPA compliance of protective clothing and equipment. Items covered in the 
survey included firefighting boots (both rubber and leather), brushfire 
clothing, bunker coats and pants, firefighting gloves, hazardous materials 
suits, helmets, proximity suits, safety shoes, SCBA facepieces, and station 
uniforms. More than 140 manufacturers and distributors of protective clothing, 
station uniforms and breathing 

Percentage of women firefighters reporting improperly fitting protective gear or 
station uniforms 

Item Career firefighters Volunteer firefighters 
Gloves 25% 25% 
Turnout bunker coat 17% 37% 
Turnout/ bunker pants 12% 34% 
Boots 12% 22% 
Uniforms 17% 10% 
Helmet 10% 16% 
SCBA facepiece 10% 21% 
[Source: 1990 survey. Women in the Fire Service] 

--74--

apparatus were sent a survey form and a letter explaining its purpose. The 
information on the following pages is taken directly from the survey forms 
returned by the manufacturers and distributors, who are responsible for its 
accuracy. 

WFS also informed manufacturers of an information-gathering meeting scheduled 
for the 1991 International Association of Fire Chiefs' Conference 
in Toronto. Input received at that meeting is included below. Every manufacturer 
of personal protective equipment that had an exhibit at the IAFC conference was 
visited by a researcher for this handbook and asked either to elaborate on the 
survey form they had filled out or to complete a survey if they had not 
previously done so. 

Report from meeting with representatives of the protective clothing industry 

Fire departments must allow firefighters to be fitted in order to ensure a 
correct fit. In footwear, for example, more information is needed for proper fit 
besides just the length of the foot. The requirement that each member of the 
department must be fitted should be specified in the bid, and a range of sizes -
such as half sizes and varying widths -should be also specified. 

Fire chiefs and others in charge of purchasing should be aware that women's 
sizes and patterns are available in protective gear. To fit women properly, 
manufacturers need to know hip, waist, inseam, and chest measurements. Rise and 
torso measurements are important for both women's and men's turnout/ bunker and 
uniform pants. Measurements should be taken by a manufacturer's representative 
the first time the fire department deals with the company, and again if the 
department decides to change styles, even if staying with the same manufacturer. 

Ill-fitting protective clothing is not just an inconvenience; it is a safety 
issue. For truly accurate fit, a fit test should be done with the garment 
itself. Also, it is important to be aware that sizing is subjective: what "fits" 
according to one person may not feel to another as though it "fits" at all. 

[Participating manufacturers: Fechheimer, Globe Firefighters Suits, Lion 
Apparel, Servus Footwear, The Warrington Group.] 

--75--

Key: The company listed is the manufacturer of the product, except as 
specifically noted. Clothing is made on women's patterns, and footwear on 
women's lasts, as noted. "Union" = union-made product. "OSHA" = meets applicable 
OSHA requirements. "NFPA" = meets applicable NFPA requirements. "ANSI" = meets 
applicable ANSI (footwear) requirements. 

Rubber structural firefighting boots 

Morning Pride: Women's lasts. NFPA, OSHA. Whole and half sizes, narrow and 
regular widths. 
Neptune: (Imports) Viking #9844. Uses inserts, not women's lasts. Union, NFPA, 
OSHA. Sizes 5 to 15-l/ 2. 
Ranger: #31260,31290. Women's lasts. NFPA, OSHA. Sizes 4 to 10. 
Servus: Firebreaker, Firefighter. Women's lasts. Union, NFPA, OSHA. Sizes 4 to 
13 narrow and wide. 

Leather structural firefighting boots 

Ranger: #3042,3063,3044,3046. No women's lasts. NFPA, OSHA. Sizes 5 to 13 M, 5-
12 W. 
Southwest: Eagle. Women's lasts. NFPA, OSHA. Sizes 3-l/ 2 to 15 A-EEEE. 
Warrington: Warrington Pro. Unisex military last. NFPA, OSHA. Sizes 6 up. 
Weinbrenner: Thorogood 804-6116. No women's lasts. OSHA. 

Brush firefighting boots 

Iowa American: (Distributes) Servus. Women's lasts. CAL/ OSHA. Full and half 
sizes. 

Brush firefighting jackets and pants 

Alb: 06, 07, 70, 60. No women's patterns. CAL/ OSHA. Sizes Small to XXL. 
Safeguard America: 71-J, S-82 MOD, 71-T MOD. Women's patterns. CAL/ OSHA. Sizes 
Small to 6XL in jackets and shirts; pants: waist and inseam in 1" increments as 
required. 

Structural firefighting bunker/ turnout coats and pants* 

Alb: C17080, 0708-0, P270080, 7008-0. No women's patterns. NFPA, OSHA. Custom 
sizing. 
Cairns: Aegis, Traditional. Women's patterns. NFPA, OSHA. Sizes XS, S, M, L, XL, 
XXL. 
Fire-Dex: Assault Gear, Series I, Series III. Women's patterns being developed. 
NFPA, OSHA. Coats sizes 32-60, pants sizes 28-56. 
FireGear: [30" coat only, with pants to interface.] Women's patterns. NFPA, 
OSHA. Sizes 28-64 plus oversizes. 
Globe: Globe, Globe Astra. Women's patterns. NFPA, OSHA. Coats sizes 28-52; 
pants sizes 24-52. 
Iowa American: (Distributes) Quaker. Women's patterns in short-style gear. NFPA, 
OSHA. Custom sizing. 
Lion Apparel: Body-Guard, Janesville. Women's patterns being developed. NFPA, 
OSHA. Coats sizes 34-60; pants sizes 30-56. 

Morning Pride: [No bib-style bunker pants.] Women' s patterns. NFPA, OSHA. Full 
range of sizes. 
Ramwear: [High-waisted bunker pants rather than bib-style.] 2000, 500. Women's 
patterns. NFPA, OSHA. Custom sizing. 

* All listed manufacturers and distributors carry bunker coats in both 
traditional and short styles, and bunker pants in traditional and bib styles, 
unless otherwise indicated. 

All information presented here is provided by the individual manufacturers and 
distributors, who are responsible for its accuracy and completeness. 

--76--

Firefighting gloves 

Alb: 589. NFPA, OSHA. Sizes S, M, L, XL. 
Fire-Dex: 500,600,700,800,900 series. NFPA, OSHA. Sizes XS to Jumbo. 
Globe: GL-9, GL-5. NFPA (GL-9), OSHA (GL-5). Sizes XS, S, M, L, XL. 
Glove Corporation: Fireman I, V, VI, VII, VIII. NFPA, OSHA. Sizes XS, S, M, L, 
XL, XXL. 
Knoxville Glove: Fire Guardian, Fire Knox. Union, NFPA, OSHA. Sizes XS, S, M, L, 
XL, J. 
Lion Apparel: Lion G1002, G1004, G1006, G1008. NFPA, OSHA. Sizes S, M, L, XL. 
Morning Pride: NFPA, OSHA. Sizes XS, S, M, L, XL, XXL, J, and made to hand 
tracings. 
Neptune: North Star 2990,2991,2993,2994. OSHA. Sizes XS, S, M, L, XL. 
Shelby: Firewall 5221,5225,5009,5011. Union, NFPA, OSHA. Sizes XS, S, M, L, XL, 
J. 
Tempo: Tempo Max, Tempo Pro. Union, NFPA, OSHA. Sizes XS, S, M, L, XL, J. 

Hazardous materials suits 

Abanda: [Level C] Fortress 7100. NFPA, OSHA. Sizes S to 7XL. 
Chemfab: [Level A, Level B] Challenge 6000, Challenge 5000. Union, NFPA, OSHA. 
Level A: one size; Level B: two sizes. 
ILC Dover: [Level A] Chemturion. NFPA (Limited use), OSHA. Sizes M, L, XL. 
Interspiro: [Level A, Level B, Level C] Trellchem HI'S; Trellchem TS, TB, TL; 
Splash 100,200,300,700. NFPA (Level A only), OSHA. Sizes S, M, L, XL. 
Kappler: [Level B, Level C] Frontline 90593. NFPA. Sizes S to 3XL. 
Lion Apparel: [Level B] Pace Setter. NFPA, OSHA. Sizes XS, S, M, L, XL, XXL. 

Firefighting helmets 

Bullard: FH 2100, FX, Wildfire FH 911, Advent A-l. NFPA. Adjustable. 
Cairns: Metro, Intruder, Patriot, Phoenix, Sam Houston, New Yorker, 
Philadelphian, Classic 1000, Commando, Century. NFPA, OSHA. Adjustable to size 
8. 
Iowa American: (Distributes) Safeco. NFPA, OSHA. Adjustable, XS to XL. 
Morning Pride: Lite Force I, II, III, IV, V, VI. NFPA, OSHA. Adjustable; factory 
assistance for unusual problems Rescue Equipment NW: Pacific K3/ 70, RK/ 70, F3/ 
1. Union, NHPA, OSHA. Adjustable, 21" to 25". 

SCBA facepieces 

Cairns: Pioneer. NFPA, OSHA. One size. 
Draeger: Draeger, Panorama, Nova. NFPA, OSHA. One size. 
Interspiro: NFPA, OSHA. One size; small available "in extreme cases." 
MSA: Ultravue. NFPA, OSHA. Sizes S, M, L. 
Scott: NFPA, OSHA. Sizes (for 4.5 and 2.2) Small, Large, XL; (for IIa) one size. 
Survivair: NFPA, OSHA. 

Safety shoes 

Ranger: [Sneaker style] 1542. Women's lasts. ANSI. Sizes 5-10. 
Southwest: [Chukka boots; oxfords] CM-500,0X-600. No women's lasts. ANSI. Sizes 
3-l/ 2 to 15 A-EEEE. 
Warrington: Pro 2100. Women's lasts. ANSI. Sizes 6 up. 
Weinbrenner: Thorogood 504-6020, 504-6010. ANSI. 

All information presented here is provided by the individual manufacturers and 
distributors, who are responsible for its accuracy and completeness. 

--77--

Station uniforms 

Artcraft Blazer: [Dress uniforms] S/ 800, S/ 801. Women's patterns. Jackets 
sizes 6-24; pants sizes 4-26. 
Cairns: [Coveralls] Series I, Series II, Series III. Women's patterns. NFPA, 
OSHA. Sizes XS to XXL. 
Fechheimer: [Coveralls, jackets, pants, shirts.] Paramount. Women's patterns 
(except coveralls). NFPA, OSHA. Pants sizes 4-24; shirts sizes 28-48. 
Iowa American: [Coveralls, jackets, pants.] Quaker. Women's patterns. Union 
(jackets only), NFPA (jackets only), OSHA (jackets only). Any size. 
Lion Apparel: [Coveralls, jackets, pants, shirts] Stationwear; NX2000 or Flamex. 
Women's patterns in pants and shirts. NFPA (shirts and pants), OSHA (all except 
jackets). Coveralls sizes S-XXXL; women's pants sizes 6-24; women' s shirts 
sizes 6-20. 
Ramwear: [Coveralls] Custom tailored. 
Safeguard America: [Coveralls, jackets, pants, shirts] M-6, 74-J, 91-T, S-83, S-
82. Women's patterns. NFPA, OSHA. Sizes 32XX-short to 64XX-long; waist/ inseam 
in 1" increments; XXS-6XL. 
Topps: [Coveralls, pants, shirts] Women's patterns. NFPA, OSHA. Coveralls sizes 
S-XXL regular and tall; pants sizes 4-28, shirts sizes 8-22. 
Werner Works: [Coveralls, jackets, pants] Pro-Tuff. Women's patterns. Sizes 
XS3XL; women's pants and coveralls sizes 8-22. 
Workrite: [Coveralls, jackets, pants, shirts] 1106N, 1104N, 3327F, 4007F, 2404F, 
2434F, 2344F. Women's patterns in all except jackets. NFPA, OSHA. Sizes 34-54; 
pants sizes 28-50. 

Firefighting proximity suits 

Cairns: Aegis Proximity, Traditional Proximity. Women's patterns. NFPA, OSHA. 
Sizes XS, S, M, L, XL, XXL. 
Fire-Dex: Aluminized. Women's patterns being developed. NFPA, OSHA. 
FireGear: Women's patterns. NFPA, OSHA. Sizes 28-64 plus oversizes. 
Globe: Women's patterns. NFPA. Coats sizes 28-52; pants sizes 24-52. 
Lion Apparel: Body-Guard, Janesville. No women's patterns. NFPA, OSHA. Coats 
sizes 34-60; pants sizes 30-56. 

All information presented here is provided by the individual manufacturers and 
distributors, who are responsible for its accuracy and completeness. 

--78 --

Abanda Protective Apparel 
AmSouth Building, 4th Floor 
P. O. Box 2028 
Decatur, AL 35602 

Alb, Inc. 
366 Somerville Avenue 
Boston, MA 02143 
617/ 666-8111 

Artcraft Blazers 
7502 Thomas St. 
Pittsburgh, PA 15208 
412-242-0266 

E. D. Bullard Company 
Route 7, Box 596 
Cynthiana, KY 41031-8822 
606-234-6616 

Cairns & Brother, Inc. 
60 Webro Road 
P. O. Box 4076 
Clifton, NJ 07012 
201/ 473-5867 
800-4-CAIRNS 

Chemfab/ Chemical Fabrics Corporation 
Daniel Webster Highway 
P. O. Box 1137 
Merrimack, NH 03054 
603-424-9000 

National Draeger, Inc. 
101 Technology Dr. 
P. O. Box 120 
Pittsburgh, PA 15230 
412-787-2207 

Fechheimer Brothers 
(Paramount Protective Uniforms) 
4545 Malsbary Road 
Cincinnati, OH 45242 
513-793-5400 

Fire-Dex Fire Clothing 
3865 W. 150th St. 
Cleveland, OH 44111 
216/ 941-3959 
800-241-6563 

Fire Gear, Inc. 
409 AABC Suite C 
Aspen, CO 81611 
303/ 925-2303 
800-748-1566 

Fyrepel 
P. O. Box 518 
951 Buckeye Ave. 
Newark, OH 43055 

Globe Firefighters Suits 
Loudon Road 
Pittsfield, NH 03263-0128 
603/ 435-8323 

The Glove Corporation 
301 N. Harrison 
Alexandria, IN 46001 
317-724-4481 

ILC Dover, Inc. 
P. O. Box 266 
Frederica, DE 19946 

Interspiro, Inc. 
31 Business Park Dr. 
Branford, CT 06405 
203/ 481-3899 

Iowa American Firefighting Equip. Co., Inc. 
P. 0 Box 517 Industrial Park 
Osceola IA 50213 
515/ 342-6091 
800-342-IOWA 

Kappler USA 
P. O. Box 218 
Guntersville, AL 35976 
800-633-2410 

Knoxville Glove Company 
P. O. Box 138 
Knoxville, TN 37901-0138 
800-251-9738 

Lion Apparel 
3401 Park Center Dr. 
P. O. Box 14576 
Dayton, OH 45414 
513/ 898-1949 
800-421-2926 

--79--

Mine Safety Appliance Co. (MSA) 
P. O. Box 426 
Pittsburgh, PA 15230 
412-967-3167 
800-MSA-2222 

Morning Pride Mfg., Inc. 
1986 Home Ave. 
P. O. Box 557 
Dayton, OH 45417 
513/ 263-2683 

Neptune International, Ltd. 
6925 216th St., SW. 
Lynnwood, WA 98036 
206/ 776-5399 

Ramwear, Inc. 
9302 Progress Pkwy 
Mentor, OH 44060 
216/ 639-0137 
800-777-9497 

Ranger Footwear Co. 
1100 E. Main St. 
Endicott, NY 13760 
607/ 757-4913 
800-847-1307 

Rescue Equipment N. W., Inc. 
P. O. Box 88357 
Seattle, WA 98138 
206/ 735-0312 

Safeguard America, Inc. 
P. O. Box 1649 
Clanton, AL 35045 
205/ 7550-7710 

Scott Aviation 
225 Erie St. 
Lancaster, NY 14086 
716/ 683-5100 

Servus Footwear Co., Inc. 
1136 Second St. 
P. O. Box 3610 
Rock Island, IL 61204 
309/ 786-7741 
800-222-2668 

Shelby Specialty Gloves 
P. O. Box 171814 
Memphis, TN 38187-1814 
901-360-89828 

Horace Small 
P. O. Box 1269 
Nashville, TN 37202-1269 

Southwest Boot Company 
2545 San Fernando Road, Suite 22 
Los Angeles, CA 90065 
213/ 223-2465 

Survivair 
3001 S. Susan St. 
Santa Ana, CA 92704 
714-545-0410 
800-821-7236 

Tempo Glove Manufacturing, Inc. 
3820 W. Wisconsin Ave. 
Milwaukee, WI 53208 
414-344-1100 
800-558-8529 

Topps Manufacturing Co. 
P. O. Box 750 
Rochester, IN 46975 
800-348-2990 
800-552-2351 (in Indiana) 

The Warrington Group Ltd. 
Professional Products Division 
216 Lafayette Road 
North Hampton, NH 03862 
603/ 964-1501 
800-662-3338 

Weinbrenner Shoe Co., Inc. 
108 S. Polk St. 
Merrill, WI 54452 
715/ 536-5521 
800-826-0002 

Werner Works, Inc. 
P. O. Box 974 
1931 N. W. Mulholland Dr. 
Roseburg, Oregon 97470 
503-672-3213 
800-547-0976 

Workrite Uniform Co. 
P. O. Box 1192 
Oxnard, CA 93032 
805-483-0175 
800-521-1888 

--80 --

Bell, Laura, "Where Does Physical Testing Leave Women?" Management Review, 
December 1987, pp. 47-50. 
Bird, James W., "Training Women for the P. A. T.," Fire Engineering, March 1991, 
pp. 87-93. 
Booth, Walter, "Recruiting women and minorities," Fire Chief, May 1987, pp. 49-
53. [Survey of large fire departments regarding their recruitment strategies] 
Brown, Marsha D., "Getting and Keeping Women in Nontraditional Careers," Public 
Personnel Management Journal, Winter 1981, pp. 408-411. 
Chambers, Mary D., "Volunteer Fire Chiefing," International Fire Chief, August 
1980, p. 15. 
Chambers, Mary D., "Women in the Fire Service," Western Fire ]ournal, April 
1981, p. 40. 
Craig, Jane, and R. Jacobs, "The Effect of Working with Women on Male Attitudes 
toward Female Firefighters," Basic and Applied Psychology, March 1985, pp. 61-
74. 
Davis, James E., "A look at performance standards," Fire Chief, August 1991, p. 
56. 
"DCFD affirmative action hiring plan overturned," Fire Chief, May 1987, p. 28. 
Deasy, M., "One Size (Does Not) Fit All," Firehouse, May 1988, pp. 33-36. 
"Department of Justice consent decree," Fire Chief, July 1987, p. 30. 
Devlin & Associates, Employment Equity Reference Manual for Ontario Municipal 
Fire Departments, prepared for the office of the Fire Marshal, Ministry of the 
Solicitor General, 1991. 
Duffy, Richard; J. Sawicki, and A. Beer, "Project FIRES: Final Report," 
International Association of Fire Fighters, 1985. 
Durkin, Edward D., "Recruiting and Hiring Women Firefighters," Fire Chief, May 
1981, pp. 52-55. 
Evans, D. H., "Height, Weight and Physical Agility Requirements," Journal of 
Police Science and Administration, December 1980, pp. 414-436. 
Farley, Lin, Sexual Shakedown: The Sexual Harassment of Women on the Job, 
McGraw-Hill, 1978. 
Feldman, Danah, "Wildland Fire Fighting," International Fire Chief, August 1980, 
pp. 16-17. 
FEMA/ USFA, Physical Fitness Coordinator's Manual for Fire Departments, 1990. 
FEMA/ USFA, Stress Management: Model Program for Maintaining Firefighter Well-
Being, 1991. 
Floren, Terese M., "1990 Survey Results," WFS Quarterly, Winter 1990-1991, pp. 
14-17. 
Floren, Terese M., "Women Firefighters: The Chief's Role," Fire Chief, May 1981, 
pp. 48-51. 
Floren, Terese M., "Women Firefighters Speak: A Survey of the Nation's Female 
Firefighters," Fire Command, December 1980, pp. 22-24 and January 1981, pp. 22-
25. 
Goldfeder, William, "Retaining and Recruiting Members," Fire Engineering, May 
1992, pp. 10-13. [Recruitment of volunteer firefighters] 
Granito, Dolores, "More Women Entering Fire Service," Fire Engineering, March 
1978, pp. 29-30. 
Hamilton, Jo Carol, "Women in the Fire Service," Fire Chief, August 1978, pp. 
81-84. 
Hammond, Ken, "Recruiting women firefighters," Fire Chief, October 1987, pp. 40-
41. [Preparing the department and the spouses of male firefighters for the entry 
of women into firefighting positions] 
Istvan, Sharon, "Fire Protection Engineering," International Fire Chief, August 
1980, p. 21. 
Johnston, William B., Workforce 2000: Work and Workers for the 21st Century, 
Hudson Institute, 1987. 
"Justice actions," Fire Chief, November 1986, p. 25. [Charleston, WV, Police 
Department ordered to reinstate dispatcher fired when she became pregnant] 
"Justice Department acts in discrimination cases," Fire Chief, July 1985, pp. 8-
10. [Deletes numerical hiring goals implemented in 1977 consent decree in San 
Diego] 
"Justice Department sues city," Fire Chief, November 1991, p. 38. [Dept. of 
Justice alleges discrimination against white men when West Palm Beach directed 
the hiring of minorities and women to fill twelve vacancies] 
Kay, Herbert, "Testing recruits," Fire Chief, April 1989, pp. 70+. 
Keene, Kathy, "What is it like to be a female firefighter Fire Chief, September 
1991, pp. 72-74. ?" 
Larkin, Susan R., "Training for Success," Fire Command, August 1989, pp. 38-42. 
[Training women for FDNY entry-level testing] 
Lipkin, Harriett, "Smoothing the Way for Women," International Fire Chief, 
August 1980, pp. 22-24. 
Loden, Marilyn, Workforce America! Managing Employee Diversity as a Vital 
Resource, Business One Irwin, 1991. 
MacKinnon, Catherine A., Sexual Harassment of Working Women, Yale University 
Press, 1979. 

--81 --

Macklin, Victoria S., "Peer Mediation Helps Heal a House Divided," NFPA journal, 
May-June 1991, pp. 62-66. 
Marinucci, Richard A., "Attracting Recruits: A Matter of Image, 
"FireEngineering, July 1991, p 10. [Recruiting volunteer firefighters] 
Marinucci, Richard A., "Women in the Volunteer Fire Service," Fire Engineering, 
January 1991, pp. 10-12. 
Martin, Molly, ed., Hard-Hatted Women, Seal Press, 1989. 
McCarl, Robert, The District of Columbia Fire Fighters Project: A Case Study in 
Occupational Folklife, Smithsonian Institute Press, 1985. 
McDiarmid, Melissa, M. D., et al.," ReproductiveHazardsofFirefightingIandII," 
American Journal of Industrial Medicine, 19: 433-472 (1991). 
McDonald, Bernie R., "Pre-Employment Training: One Department's Program," Fire 
Command, August 1987, pp. 24-28. [Louisville Fire Department] 
McNichol, J., and S. Scanlin, "Proceedings of the National Firefighter Health 
and Safety Forum," Congressional Fire Services Institute, 1991. 
McQueen, Iris, "Sexual harassment," Fire Chief, August 1985, pp. 69-72. 
Misner, J. E., S. A. Plowman, and R. A. Bioleau, "Performance Differences 
between Males and Females on Simulated Firefighting Tasks," Journal of 
Occupational Medicine, 29, (1987), pp. 801-805. 
Naczi, Frances D., "Removing sexism from communications," Fire Chief, November 
1984, pp. 45-46. 
Navarre, Raymond J., "Developing a stress-reducing fire station," Fire Chief, 
February 1987, pp. 46-48. 
Neeves, R., et al., "Physiological and Biomechanical Changes in Fire Fighters 
due to Boot Design Modifications," International Association of Fire Fighters 
and the Federal Emergency Management Agency, 1989. 
National Fire Protection Association, "NFPA 1500: Standard on Fire Department 
Occupational Safety and Health Program," 1987. 
National Fire Protection Association, "NFPA 1971: Standard on Protective 
Clothing for Structural Fire Fighting," 1991. 
National Fire Protection Association, "NFPA 1972: Standard on Helmets for 
Structural Fire Fighting," 1987. 
National Fire Protection Association, "NFPA 1973: Standard on Gloves for 
Structural Fire Fighting," 1988. 
National Fire Protection Association, "NFPA 1974: Standard on Protective 
Footwear for Structural Fire Fighting," 1987. 
National Fire Protection Association, "NFPA 1975: Standard on Station/ Work 
Uniforms for Structural Fire Fighters," 1990. 
National Fire Protection Association, "NFPA 1981: Standard on Open-Circuit Self-
Contained Breathing Apparatus for Structural Fire Fighting," 1987. 
Olshan, Andrew F., K. Teschke, and I'. Baird, "Birth Defects Among Offspring of 
Firemen," American Journal of Epidemiology, Vol. 131, No. 2, pp. 312-321. 
"Oregon Volunteer Firefighter of the Year: Captain Mary Lou Fletcher," Fire 
Command, September 1988, p. 6. 
Osby, Robert E., "Effective fire service affirmative action," Fire Chief 
September 1991, pp. 50-54. 
Paludi, Michele A., and R. B. Barickman, Academic and Workplace Sexual 
Harassment, State University of New York, 1991. 
Pantoga, Fritzie, "Women Firefighters -A Survey," Fire Chief, January 1977, pp. 
51-54. 
Perkins, Kenneth B., "Volunteer Fire Fighters in the U. S.: A Sociological 
Profile of America's Bravest," National Volunteer Fire Council, 1987. 
Petrocellil, William, and B. K. Repa, Sexual Harassment on the Job, Nolo Press, 
1992. 
Randleman, William, "What is discrimination ?" Fire Chief, November 1984, p. 27. 
Roche, Diane C., "Public Fire Education," International Fire Chief, August 1980, 
pp. 20-21. 
Rudder, Beatrice, "Career Fire Fighting," International Fire Chief, August 1980, 
p. 16. 
Rukavina, John, "Fire service, meet the ADA," Fire Chief, June 1992, pp. 30+. 
[Mistitled; actually about the Civil Rights Act of 1991] 
Rukavina, John, "Seeing the future," Fire Chief, September 1992, pp. 22+. 
[Regarding Pennsylvania State University report on the pending expiration of the 
Age Discrimination in Employment Act exemption for firefighters] 
Rule, Charles H., R. E. Osby, J. H. Steffens, and M. R. Rakestraw, "Workforce 
2000," Fire Chief, January 1991, pp. 36-40. 
Sanders, Jo Schuchat, The Nuts and Bolts of NT0: How to Help Women Enter Non-
Traditional Occupations, Scarecrow Press, 1986. 

--82 --

Schmidt, Wayne W., "Background investigations," Fire Chief, July 1990, p. 18. 
[Limits on background investigations in areas such as sexual activity] 
Schmidt, Wayne W., "Civil liability for wrongful discharge," Fire Chief, 
September 1989, pp. 26+. 
Schmidt, Wayne W., "Nepotism and consanguinity relations," Fire Chief, February 
1985, p. 14. [9th Circuit affirms lower court ruling that one employee may be 
required to transfer or quit if two employees marry] 
Schmidt, Wayne W., "Physical fitness standards," Fire Chief, July 1989, p. 42. 
[Legality of employment requirements restricting body fat] 
Schmidt, Wayne W., "Quotas and other discrimination remedies, "Fire Chief, April 
1985, p. 14. 
Schmidt, Wayne W., "Sexual Harassment," Fire Chief, October 1986, pp. 14-15. [U. 
S. Supreme Court decision in Meritor v. Vinson; also Indiana case where judge 
found sexual harassment but not sex discrimination] 
Schmidt, Wayne W., "Sexual Harassment," Fire Chief, February 1987, p. 27. 
[Appeals court reversal of lower court decision that failed to find harassment 
evidence of discrimination] 
Schmidt, Wayne W., "Sexual Harassment," Fire Chief, December 1991, p. 30. [Cases 
involving women police officers] 
Schrader, George, "Avoid sexual harassment hassles," Fire Chief, June 1990, pp. 
47+. [Sexual harassment not an issue of sex but of power and control; recent 
court cases] 
Schumacher, Joe, "Affirmative Action Revisited," Fire Chief, March 1989, pp. 51-
53. 
"Sex Discrimination," Fire and Police Personnel Reporter, August 1984, pp. 13-
15. 
"Sexual Harassment," Fire and Police Personnel Reporter, October 1986, pp. 12-
14. 
Shearer, Robert W., "Can after-hours conduct be grounds for firing?" Fire Chief, 
May 1989, pp. 59-60. 
Shouldis, William, "Sexual Harassment," Fire Engineering, September 1991, pp. 
101+. 
Siegel, Deborah L., Sexual Harassment: Research and Resources, National Council 
for Research on Women, 1991. 
Simons, George, Working Together: How to Become More Effective in a 
Multicultural Organization, Crisp Publications, 1989. 
Simons, George, and D. Weissman, Men and Women: Partners at Work, Crisp 
Publications, 1990. 
Smith, Michael H., "Communications skills for a changing fire service," Fire 
Chief, September 1991, p. 82. 
Sturzenacker, Gloria, "Prejudice Prevention," Chief Fire Executive, April-May 
1986, pp. 43-51. 
Swartout, Robert, "Women Fire Fighters: The Seattle Concept," International Fire 
Chief, August 1980, pp. 10-11. 
Tannen, Deborah, You Just Don't Understand: Women and Men in Conversation, 
Ballantine Books, 1990. 
Thaut, Stanley L., "A history of Tacoma's effort to recruit women firefighters," 
Fire Chief, September 1979, pp. 40-43. 
Thomason, Betsy, "Self-discovery: a way to deal with stress," Fire Chief, 
February 1991, p. 25. 
Tokle, Gary, "1001 Considerations," Fire Command, April 1989, pp. 24-25. 
Turner, Gary, "Butting Heads over Change," Chief Fire Executive, January-
February 1987, pp. 27-30. 
"US Court of Appeals throws out FDNY scoring system," Fire Chief, May 1987, pp. 
14-15. 
Vougioukles, Carol, and L. Buchbinder, "Fire Administration Initiates Women's 
Program," International Fire Chief August 1980, pp. 12-13. 
Vonada, Michael, "Shadow Dancing," Fire Chief, December 1987, p. 50. 
Waters, Michael S., "The Recruitment and Retention of Women in the Career Fire 
Service," International Fire Chief, May 1986, pp. 11-17. 
Webster, Cindy, "Facing off on sexual harassment," Fire Chief, August 1992, pp. 
72-77. 
Webster, Cindy, "First National Conference of Fire Service Women," Fire Chief, 
February 1986, pp. 44-47. 
Williams, Timothy, & S. Evenson, "Physically fit for duty? By whose standards?" 
Fire Chief, March 1988, pp. 43+, April 1988, pp. 58+, May 1988, pp. 55+. 
Willing, Linda, "Love on the Job," Fire Chief August 1990, p. 92. 
Winkle, William, and R. Navarre, "Females in the fire service: the process of 
acceptance," Fire Chief, April 1985, pp. 68-69. [How the Toledo Fire Department 
integrated women into its ranks] 
"Women are Fire Fighters, too!" Fire Command, February 1976, pp. 16-19. 
"Women in the Fire Service," Fire Chief May 1981, pp. 48-51. 
Women's Issues Advisory Committee, Guidelines for Integration of Women into the 
California Fire Service, California Fire Fighter Joint Apprenticeship Program, 
1990. 
"Women's Training Program in Jacksonville," Fire Chief, February 1991, pp. 60-
61. 

--83--

Major provisions of the Civil Rights Act of 1991 

1. For the first time under federal law, permits some compensatory and punitive 
damages (along with attorney's fees) in cases of intentional discrimination 
based on sex, religion, or disability. Punitive damages are only allowed against 
non-public employers; specific caps are mandated on some damages. ' 

2. Permits jury trials in cases filed under Title VII. 

3. Clarifies "mixed motive" cases to insure that if a complainant shows an 
employment action is motivated by an impermissible consideration of race, color, 
religion, sex or national origin, the practice is unlawful even if other lawful 
factors motivated the action or the same action would have resulted without the 
discriminatory motive. [Overturns Price Waterhouse v. Hopkins (1989).] 

4. Where the complainant has shown disparate impact, 2 places the burden of 
proof on the employer to show that the discriminatory practice was both job-
related and justified by "business necessity." 3 [Overturns Wards Cove v. Atonio 
(employer only had to show "business justification").] 

5. Includes on-the-job harassment and other post-hiring conduct under the 
protective umbrella (prohibiting race bias) of 1981 of the Civil Rights Act of 
1866 (42 U. S. C. 1981). Also expands the section to cover employers too small 
to be covered under Title VII, and lengthens the limitations period for filing 
with no requirement to file with the EEOC. [Overturns Patterson v. McLean Credit 
Union (1989).] 

6. Bars challenges to consent decrees by persons who had actual notice of a 
proposed judgement and reasonable opportunity to present objections, and those 
whose interests were adequately represented by another person. Where subsequent 
actions are permitted, the Act gives jurisdiction to the same court and, if 
possible, to the same judge as in the original case. [Overturns Martin v. Wilks 
(1989).] 

7. Provides that a seniority system that intentionally discriminates may be 
challenged when the system is adopted, when an individual becomes subject to it, 
or when a person is actually injured by it. [Overturns Lorance v. AT& T (1989).] 

8. Permits expert fees to be included as part of attorney's fees for purposes of 
reimbursement to plaintiffs who bring actions under 1981 and Title VII. 
[Reverses West Vu. Univ. Hospitals v. Casey (1991).] 

9. Stipulates that U. S. citizens employed in foreign countries by U. S.-owned 
or -controlled companies are covered by Title VII and the ADA, except if 
compliance would violate the law of the foreign country in which the company is 
located. [Overturns EEOC v. ARAMCO (1991).] 

10. Prohibits the use of different cut-off scores, or otherwise altering results 
of employment-related tests, on the basis of race, color, religion, sex or 
national origin. 

Following the signing of the 1991 Civil Rights Act, the federal government took 
a number of actions that limit its scope. The EEOC ruled that the new law does 
not apply to thousands of pending cases, or to any victims who file claims based 
on discriminatory conduct that occurred before the Act was signed (11/ 21/ 91). 
This may violate the intent of Congress, which explicitly exempted cases already 
decided (e. g., the Wards Cove plaintiffs) from the new law. As of 1992, it was 
not clear how this will apply to cases where there is a continuing pattern of 
discrimination and if discriminatory conduct prior to November 1991 can work to 
insulate an employer from liability for discriminatory conduct occurring after 
that date. 

1 Legislation was pending in Congress in 1992 to remove those caps. 
2 The law does not define "disparate impact," leaving intact the Supreme Court's 
definition in Wards Cove v. Atonio (1989) (the proper comparison is between the 
racial composition of qualified persons in the labor market and persons holding 
the jobs in question). Unlawful disparate impact is also shown if complainant 
shows there was a less discriminatory alternative available but the employer 
refused to use it. 
3 Business necessity is not a defense to intentional discrimination. 

--84 --

Sex discrimination: general 

What forms of discrimination are illegal? Discrimination based on race, sex, 
religion, national origin, ancestry, disability, and in some states or 
localities, sexual orientation, political affiliation, marital status, and 
arrest record. Discrimination is prohibited in all terms, benefits and 
conditions of employment, including hiring, firing, layoff, promotion, wages and 
compensation, fringe benefits, assignment, and training. 

Applicable laws: 

Title VII of the Civil Rights Act of 1964, as amended, 42 U. S. C.  2000e et 
seq. 
Pregnancy Discrimination Act of 1978 (amendings 701 of Title VII), 42 U. S. C. 
2000e (K): pregnancy-related conditions are to be treated the same as other 
disabling conditions. 
Equal Pay Act of 1963, 29 U. S. C. 206( d). 
State and Local Fiscal Assistance Act of 1972: "revenue-sharing" for public 
safety. 
Americans with Disabilities Act, P. L. 101-336. 
Executive Order 11246 (1965), as amended: prohibits employment discrimination on 
the basis of race, color, national origin or sex in institutions or agencies 
with federal contracts over $10,000 (including "grants" that involve a benefit 
to the federal government). 
Intergovernmental Personnel Act of 1970: agencies or programs of state and local 
governments that receive grants-in-aid from the federal government 
Civil Rights Act of 1871, 42 U. S. C. 1983: creates no statutory rights in and 
of itself, but has been used to enforce federally protected rights from other 
sources (not including Title VII). 
Age Discrimination in Employment Act of 1967, 29 U. S. C. 621 et seq: 
firefighters currently exempt from prohibitions on age limits in hiring, 
retirement, etc. As of 1992, this exemption was under Congressional review. 

The volunteer fire service and gender-based discrimination 

A woman volunteer firefighter seeking to obtain the protections of Title VII 
would encounter the limitation that Title VII applies only to "employees." 
Volunteers may have legal remedies other than Title VII, but being considered as 
an employee will significantly increase the volunteer's protection against sex 
discrimination. Courts have consistently ruled that under Title VII, volunteers 
are not employees. 1 

In many states, however, volunteer firefighters are considered to be employees 
for the purposes of anti-discrimination law. This determination may depend on 
many factors, including how state fair employment practices laws are worded, 
whether volunteers receive any monetary compensation for their services, and 
whether they are part of a state pension system. Even if the volunteer is not 
considered to be an employee, state tort actions would still be available, i. 
e., assault and battery, intentional infliction of emotional distress, etc. If 
not covered under Title VII, volunteers could still be protected by the Civil 
Rights Act of 1871. 

1 Tadros v. Colman, 898 F. 2d 10 (2d Cir. 1990). Smith v. Berks Community 
Television, 657 F. Supp. 794 (E. D. Pa. 1987). The Tadros court said plaintiff 
could only be an employee if the defendant both controls his/ her work and pays 
him/ her. 
2 42 U. S. C. 1983 

Reproductive issues 

Two U. S. Supreme Court decisions, Johnson Controls and California Federal 
Savings & Laon, have significant impact on maternity leave issues and the rights 
of fertile and/ or pregnant workers. 

UAW v. Johnson Controls 111 S. Ct. 1196 (1991) 

The EEOC's Policy Guidance states: "As a result of the Supreme Court's decision 
in Johnson Controls, policies that exclude members of one sex from a workplace 
for the purpose of protecting fetuses cannot be justified under Title VII. Thus, 
if a charging party alleges that the respondent has excluded members of one sex 
from employment based on a fetal protection policy, and if the investigation 
confirms this allegation, 'cause' should be found. It does not matter whether 
the employer can prove that a substance to which its workers are exposed will 
endanger the health of a fetus. It also does not matter whether the employer can 
prove that it will incur a higher cost as a result of hiring women. Individuals 
who can perform the essential functions of a job must be considered eligible for 
employment, regardless of the presence of workplace hazards to fetuses." C. C. 
H. Empl. Prac. Guide 5306 (6/ 28/ 91). 

--85--

The Court's decision: Sex-specific fetal protection policies are, on their face, 
sex discrimination under Title VII because such policies require only female 
employees to produce proof that they are not capable of reproducing. 
Policies which exclude employees on the basis of gender and childbearing 
capacity rather than fertility are also sex discrimination under the Pregnancy 
Discrimination Act. A policy which discriminates on the basis of sex can only be 
defended if it is a "bona fide occupational qualification" (BFOQ). BFOQ must be 
defined as skills and aptitudes that affect the employee's ability to do the 
job. "The BFOQ is not so broad that it transforms this deep social concern (the 
possibility of injury to future children) into an essential aspect of battery-
making. " "Decisions about the welfare of future children must be left to the 
parents who conceive, bear, support and raise them rather than to employers who 
hire those parents." 

Maternity policies that require a woman to leave fire suppression duty at a 
specified point in her pregnancy will no longer be considered legal. However, a 
fire department administration that offers its firefighters both education 
regarding the potential reproductive hazards of firefighting and meaningful 
alternative duty while the employee is attempting to conceive a child or is 
pregnant, will be offering its employees the option of having a child and having 
a job. 

California Federal Savings & Loan v. Guerra, 107 S. Ct. 683,42 F. E. P. 1073 
(1987) 

The Court's decision: "Congress intended the Pregnancy Discrimination Act to be 
a 'floor beneath which pregnancy disability benefits may not drop -not a ceiling 
above which they may not rise." ' (at 692) 

Anti-nepotism rules 

Anti-nepotism rules are usually regarded by fact-finders as "sex-neutral" in 
thaton their face they apply to both men and women equally. A complainant must 
present ample statistics to show disparate impact* and that the rule is not 
justified by business necessity. A complainant must also check to see if state 
and local Fair Employment Practices (FEP) laws would (1) ban discrimination on 
the basis of marital status, and/ or (2) enable the no-spouse rule to be 
defended as a BFOQ. 

Relevant cases: 

Yuhas v. Libby-Owens-Ford, 562 F. 2d 496 (7th Cir. 1977), cert denied, 435 U. S. 
934 (1978), rev'g411 F. Supp. 77 (N. D. Ill. 1976). 

Plaintiff's statistics established prima facie case of sex discrimination but 
court accepted employer's "business" justifications that employment of both 
spouses in the came capacity would hurt the morale of other employees and of the 
spouses themselves. 

EEOC Decision No. 75-239 (1976), CCH EEOC Decisions 6492. 

Employer did not meet business necessity burden; e. g., previous history had 
allowed relatives to work and there was no evidence the employer had had 
problems before instituting the anti-nepotism rule. 

Volchahoske v. City of Grand Island, 10 E. P. D. 10,247 (Neb. 1975). Ordinance 
prohibiting employment of both husband and wife found unconstitutional 
interference with "right to marry" protected under the lst, 5th, 9th and 14th 
Amendments [city must show compelling interest]. 

Sebetic v. Hagerty, 640 F. Supp. 1274 (E. D. Wis. 1986), aff'd 819 F. 2d 1144 
(7th Cir.), cert denied 108 S. Ct. 235 (1987). Rule prohibited spouses of law 
enforcement officers from being dispatchers. Court held no-spouse policy valid 
based on need to avoid dangerous incidents that may occur when dispatcher's 
spouse is officer on call. The rule did not significantly interfere with the 
right to marry, and the policy was not a pretext for sex discrimination. 

Espinoza v. Thorna, 580 F. 2d 346 (8th Cir. 1978) Court applied a no-spouse rule 
to an unmarried couple. 

* If the rule is "no spouse" rather than "no relative," plaintiff must establish 
the proposition that it is most often the wife who is terminated under the "no 
spouse" rule. 

--86--

This memorandum was issued by a state Fair Employent Practices Agency in finding 
probable cause of unfair discrimination in the design and administration of a 
fire department entry-level physical test. 

Memorandum 

A determination has been made, based on the investigation results stated below, 
that there is PROBABLE CAUSE to credit Charging Party's allegation of an unfair 
discriminatory practice by Respondent in violation of (State) Statutes... 

I. The Actions and Inactions of the Respondent City Evidence an lntent to 
Continue a Pattern and Practice of Discrimination Against Female Firefighter 
Applicants. 

The May, 1988 physical abilities test given by the City of to test applicants 
for entry level fire fighter positions was defective and discriminatory in the 
way it was conceived, administered, and scored. This test of 136 seconds was 
essentially the determinant of who would become a firefighter. As discussed in 
the following sections, all that need be shown to prove discrimination is that 
there was a significant adverse impact on female applicants which was not shown 
to be necessary to test for essential job skills or that there was an 
alternative test which is as accurate as the test given that does not as 
adversely affect female applicants. Here, however, virtually every time an 
option existed on how to construct the test the option that was most likely to 
adversely affect female applicants or unfairly help male applicants was 
selected. The nature of these basic decisions demonstrated an intent by the City 
to continue a long-standing pattern and practice of discrimination against women 
in the selection of firefighters. 

By constructing a test that does not measure aerobic capacity (stamina), the 
City created a less rigorous, less valid test than they should have. By not 
selecting to test for essential job skills that women have performed well on in 
other cities' tests, the City unnecessarily hindered women's opportunity to be 
successful. As have most other jurisdictions around the country, (the City) 
identified stamina as a critical requisite ability for firefighters. With this 
knowledge and with the knowledge that women typically do well on aerobic tasks, 
the City nevertheless chose to use a short series of test elements which 
individually and in combination were anaerobic in nature and thus did not test 
stamina (aerobic) skills. 

A test which fails to adequately measure aerobic capacity and by its omission is 
over-sampling anaerobic capacity and strength, needlessly reduces the job-
relatedness of the test while simultaneously increasing its adverse impact 
against females. Since the federal Uniform Guidelines on Employee Selection 
(UGL) require the employer to select from among comparably job related selection 
procedures, the least onerous alternative, the use of a less job related 
procedure which is predictably more onerous to females is clearly illegal. 

Further evidence of intent is found in the City's use of rank-ordering of test 
score results. Despite clear knowledge that rank-ordering would not be valid and 
would unfairly prejudice women's opportunities to become firefighters, the City 
chose to mandate the ranking of applicant scores and, thus, discriminate against 
women. The federal Uniform Guidelines on Employee Selection prohibit the rank-
ordering of scores where there is adverse impact on a protected class of 
applicants unless it is shown that higher scores predict better performance on 
the job. The City has known this since at least 1985 and has been told about the 
problem a number of times; nevertheless, it chose to mandate, by ordinance, the 
rank-ordering of applicants on the firefighter exam. The City was fully aware 
that it had no evidence that higher scores on the test mean better performance 
on the job, and the City was fully aware that this arbitrary ranking would 
exclude women from fire suppression work. 

In addition, the City's choice of which test events were made "pass/ fail" and 
which were timed and counted in the final "score" seemed intentionally designed 
to not give fair credit for items women were known to excel in, making the test 
more burdensome on women. Two test components which were not timed were the 
"blind maze" which required the blind-folded applicant to follow a hose line 
through a maze and the "ladder climb." These activities more realistically 
duplicate actual fire fighting skills than many of the timed activities. These 
were also test components in which women would be expected to do better than 
men... both simulate key job skills but do not emphasize upper body strength. A 
study from another jurisdiction known by the Respondent found that women 
firefighters completed a ladder climb event significantly faster than male 
firefighters. (Concerns about safety on the ladder climb were resolved by 
another city by using a safety harness.) 

Exacerbating this problem is that the tasks which were timed and used to create 
the rank order and cut-off scores were often testing for and rewarding behavior 
that is detrimental to effective firefighting. There were strong rewards for 
upper body strength and sprinting even when responsible firefighting prohibits 
sprinting. In a smoke filled environment it can lead to fatigue or smoke 
inhalation. Although upper body strength is a characteristic that can be 

--87--

tested for, it is not the sole characteristic that leads to effective 
firefighting skills. The ability to be a weight lifter is not necessarily the 
ability to be a firefighter. The test's disproportionate emphasis on only these 
skills further indicated the intent to exclude women firefighters. 

Finally, the City's assertion that it tried to facilitate the women's entry into 
the fire service by encourage female applicants to participate in a one-year 
conditioning program at the YMCA lacks credibility. Most, if not all, of the 
women did devote themselves to the year-long course; however, the program 
emphasized aerobic rather than anaerobic conditioning. Conversely, the 
firefighter exam emphasized anaerobic capacity. The women, in essence, wasted a 
year of hard work in developing an important element of job-readiness which was 
admittedly not measured in the ultimate test. 

As one former fire chief in another city stated, "If you were going to design a 
test to exclude women, you'd end up with (this) test." The experience, knowledge 
and expertise of those who developed the physical abilities test negate a 
conclusion that its severe adverse effect was unexpected or unplanned. 

II. The Physical Abilities Test Had an Unnecessary Adverse Impact on Female 
Applicants and is Discriminatory Even in the Absence of an lntent to 
Discriminate. 

The City has admitted that its physical abilities test adversely affected women 
applicants... that the test methods are discriminatory in effect. The City has 
never employed a female firefighter, none was deemed to have passed its 1988 
physical exam and no women will be hired for the duration of the new eligibility 
list. Because of this, the City has the burden of proving that its testing 
procedures have a "manifest relationship to the employment in question." Dothard 
v. Rawlingson, 433 U. S. 321,329 (1977). 

For reasons set forth below, the City has failed to meet its burden to show that 
its methodology is valid and that the extreme effect it has on women is 
justified: 

1. The EEOC's Uniform Guidelines for Employee Selection provide that "( w) here 
cutoff scores are used, they should normally be set so as to be reasonable and 
consistent with normal expectations of acceptable proficiency within the work 
force,..." 29 C. F. R. 1607.5( H). 

It is well-established practice to "norm" a test and set a cutoff score by using 
a random sample of incumbent employees in the job classification. Despite 
recommendation from both its Personnel Department and its consultant that a 
random selection would provide the best sample of performance within the 
Department, the Respondent normed the test using only volunteers who had been 
previously rated "excellent" or "superior" in aerobic fitness. When the sensible 
proposal was made to use as part of the norming group successful female 
firefighters from other jurisdictions to determine the test's validity for 
quality female firefighters, the proposal was rejected. 

Despite the Respondent's position that new firefighters should have at least a 
"good" aerobic fitness rating, no current firefighters at that fitness rating 
were used as normers to set the cutoff standard. Since two of the normers in 
"excellent" or "superior" aerobic condition scored lower than the cutoff time 
set at two minutes and 16 seconds, it is possible to speculate that a number of 
firefighters in "good" condition would also fail the exam. 

2. Stamina (aerobic capacity as opposed to anaerobic capacity) was one of three 
critical requisite abilities identified in the Respondent's report concerning 
the 1988 physical test. According to an exercise physiologist who reviewed the 
test, (this) exam was too short to measure aerobic capacity. Both he and an 
industrial psychologist who reviewed the Respondent's test agreed that by 
failing to measure aerobic capacity, the City needlessly reduced the job-
relatedness of the test while simultaneously increasing its adverse impact upon 
females. 

One of the Respondent's test developers admitted that he was concerned that the 
tasks be sequenced to provide more aerobic involvement, more closely simulating 
the work at a fire scene. He also admitted, however, that the physical test was 
predominantly anaerobic. 

3. The validity of the test, its job-relatedness, was also seriously compromised 
by the instructions that participants "run" through the exercises. A number of 
fire service witnesses stated that such running at an actual fire scene is 
considered a safety violation. One of the Respondent's training staff made it 
clear that firefighters are taught not to run and are stopped from running if 
they do so in training. 

Test normers and participants were also instructed to "dive" through a window 
obstacle headfirst and do a somersault on the other side of the wall. Again, 
evidence is compelling that such an exercise would be extremely dangerous on the 
fire ground, is not a realistic approximation of actual practice and is not 
taught to either new or experienced firefighters. 

Other individual components of the test which were not representative of common 
work activities are the "hose pull" using a hose roller, and the obstacle 
course. One fire captain also criticized the run up five stories carrying a hose 
bundle, stating it "is not only a safety hazard but [is] often impractical or 
counterproductive since resulting fatigue may impair ability once there." 

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4. The Respondent's "job analysis" is inadequate for purposes of validating the 
physical test. While the job study was presumably based upon actual observation 
at fire scenes, the person conducting the study did not observe either 
residential or commercial fire suppression work; rather, he viewed a practice 
exercise involving a gas fire set at an oil refinery. 

In addition, nothing in the job analysis was designed to gather crucial 
information necessary to guide the test developers in establishing 
"representativeness" in the duration of the individual tasks or the sequencing 
of tasks. 

5. Some irregularities in the administration of the test itself adversely 
affected women who participated. Although somewhat adjustable, the airpacks used 
in the test did not fit all of the women. The Respondent discovered this problem 
and offered pieces of foam rubber to the women. In spite of the foam, or because 
of it, the airpacks were "very loose and slipped and flopped around affecting 
balance and speed." 

Another problem was differing levels of encouragement given applicants. One 
woman said a fire service employee shouted to her, "Hey, I wouldn't even bother 
taking it [the test] if I were you, I saw two women go through it this morning! 
One dropped out in the middle and the other did worse than seven minutes." She 
states that the man laughed out loud after making the remark. 

6. There is no evidence that a person's score on the physical test is predictive 
of his/ her future performance as a firefighter. Just as the cut-off score set 
by the City failed to distinguish those applicants who could perform job tasks 
from those who could not, the ranking of scores fails to distinguish those who 
can perform job tasks better than others. One of the Respondent's test 
developers testified that the ranking of the City's test assumes that the higher 
ranked applicants would better perform the responsibilities of firefighting than 
those applicants lower on the list; however, he admitted that no studies have 
been done on the individuals in the norming group to determine whether there was 
a correlation between their job performance and their test score. This witness 
ultimately admitted that to assume that a person with a score of 75 would not 
perform the job as well as a person with a score of 77 is "probably a weak 
assumption." 

The use of ranking in a selection procedure when the ranking fails to identify 
those who can better perform the task violates the federal Uniform Guidelines 
for Employee Selection. According to the Uniform Guidelines, the use of ranking 
in a content valid selection procedure " ... should measure those aspects of 
performance which differentiate among levels of job performance." Uniform 
Guidelines for Employee Selection, 29 C. F. R. 1607.14( c)( 9). The City cannot 
establish that ranking serves to measure aspects of job performance because the 
City has no job performance data. Furthermore, when the use of ranking in a 
selection procedure has a greater adverse impact than use of the same selection 
procedure on a pass/ fail basis, the Uniform Guidelines require that "... the 
user should have sufficient evidence of validity and utility to support the use 
of a ranking basis." 29 C. F. R. 1607.5( G). Review of the scores on the 
physical test establishes that, no matter where the cut-off score is set, 
ranking has an adverse impact on female applicants. As noted earlier, the City's 
support for the use of ranking is based only on the admittedly "weak assumption" 
that a person with a lower score would not perform as well as a person with a 
higher score. 

7. Because of the very small number of things tested for and the brief total 
time needed to be selected for an offer of employment, each of these weaknesses 
in the test looms large even when taken alone, but when cumulated devastate any 
claim of the test's validity. 

III. Modifications of the City's Own Test or Alternatives Used in Other 
Jurisdictions Would increase the Validity of the Selection Process and Reduce 
Adverse Impact. 

Even if the City could show that the Phase II elements of its test, as well as 
its cut-off score and ranking procedures are job-related, it may still be deemed 
to be in violation of the law if the evidence establishes that other selection 
devices without a similar discriminatory effect could also serve the employer's 
legitimate interests. Dothard, 433 U. S. at 329. By analyzing the City's test 
and by surveying U. S. cities with (comparable populations), the Department has 
found a number of ways (this) test could be modified or replaced -all to the 
effect of increasing job-relatedness and decreasing adverse impact. 

Shortcomings found in the Respondent's testing procedure suggest a number of 
alternatives which would make the physical exam methodology more job-related and 
hence more fair to both men and women, e. g.: (i) obtain a random selection of 
firefighters to norm the test, including firefighters in the "good" fitness 
category which is the Respondent's established standard; (ii) set a realistic 
cut-off score which does not eliminate qualified normers or exclude applicants 
capable of performing at levels of acceptable proficiency; (iii) utilize a 
"pass/ fail" rating system in the absence of a valid ranking system; (iv) review 
the test components and identify changes which could result in increased aerobic 
capacity validity and lowered adverse impact; (v) add or increase aerobic 
capacity measures; (vi) include qualified female normers... identify procedures 
or shortcomings which unnecessarily impede female applicants; (vii) develop a 
more complete job analysis which more accurately establishes acceptable levels 
of performance. 

--89--

A specific concern in reviewing (this) test was that the only exercises scored 
"pass/ fail" were the ladder climb and blind maze, both of which are important 
tests. Neither activity would appear to have a significantly adverse impact upon 
women. Timing these events would make the test even more competitive and 
simultaneously reduce impact on women. One study found that female firefighters 
out-performed males in the ladder climb. 

In addition to those modifications set forth in the previous paragraphs, there 
are a large number of alternative selection procedures being used throughout the 
country to pick firefighter candidates. Among those available are "construct-
based" tests. According to witnesses, the City rejected such tests out-of-hand 
because of a fear they would be rejected by the firefighters union. Because of 
this concern, the City automatically excluded many alternatives available and in 
use in other jurisdictions. 

This Department sent out a survey instrument to fire departments in 53 American 
cities with (comparable) populations... Thus far (after two weeks), over 50% 
have responded. Despite selection procedures that vary one from another, every 
city responding has been able to develop selection methods which are less 
burdensome on female applicants than this test. It is beyond comprehension that 
not one alternative is suitable for use in the Respondent city. 

Note: 

The Administrative Law Judge who later heard this case found for the plaintiffs 
(the women challenging the test). His decision stated that the test had been 
improperly normed (and therefore the test's cut-off point was not valid), that 
it did not adequately represent the job of firefighting, and that the City's 
validity study did not justify rank ordering of candidates. The judge did not 
find that there had been intentional discrimination against the women 
applicants. He ordered the City not to hire from the resulting list, mandating 
it instead to develop a new test that would measure aerobic as well as anaerobic 
capacity, and to score the test on a pass-fail basis unless rank ordering could 
be specifically justified. Part of his conclusions: 

On the basis of the entire record it is concluded that the City has failed to 
establish that (the test) is content valid and contains a representative sample 
of important or frequently performed job tasks... There is evidence in this case 
that tasks were selected because they were tough and not because they were 
representative of typical, important or critical job behaviors. Although the 
normers who were surveyed indicated that the test was representative of their 
duties, the Administrative Law Judge does not believe that content validity 
questionnaires they completed have any significant persuasive value. The record 
suggests that the normers would have endorsed any test that was difficult. 

--90--

Films and videotapes: 

"Intent vs. Impact, "Sexual harassment prevention videotape. Available from 
Anderson Davis, BNA Communications Inc., 9439 Key West Ave., Rockville, MD 
20850. 

"The Job Interview," 11-minute videotape presenting fire departent gender 
stereotypes in a humorous (role-reversal) scenario. Available from Women in the 
Fire Service. 

"Trade Secrets: Blue Collar Women Speak Out," 23-minute film on women working in 
the trades. Available on loan from Chicago Women in Trades, 37 S. Ashland St., 
Chicago IL 60607; 312/ 942-1444. 

"Valuing Diversity," 5-part videotape series. Available from Copeland and Griggs 
Productions, 302 23rd Ave., San Francisco, CA 94121. Includes titles such as 
"Managing Differences," "Diversity at Work," "Communicating Across Cultures," 
etc. 

"What About You?/ A toi de choisir!" 19-Pminute videotape profiling six women 
working in non-traditional occupations, including a firefighter. Available from 
Women's Bureau, Labour Canada, Ottawa, Ontario KlA 0J2, Canada; 819/ 953-0055. 

"Would You Let Someone Do This to Your Sister?" 33-minute film on sexual 
harassment, also available in videotape. United Auto Workers Women's Department, 
8000 E. Jefferson; Detroit, MI 48214; 313/ 926-5212. 

Books and other print resources: 

Devlin and Associates, Employment Equity Reference Manual for Ontario Municipal 
Fire Departments, prepared for the Office of the Fire Marshal, Ministry of the 
Solicitor General, 1991. 

FEMA/ USFA, Physical Fitness Coordinator's Manual for Fire Departments, 1990. 

FEMA/ USFA, Stress Management: Model Program for Maintaining Firefighter Well-
Being, 1991. 

Loden, Marilyn, Workforce America! Managing Employee Diversity as a Vital 
Resource, Business One Irwin, 1991. 

MacKinnon, Catherine A., Sexual Harassment of Working Women, Yale University 
Press, 1979. 

Martin, Molly, ed., Hard-Hatted Women, Seal Press, 1989. 

Petrocelli, William, and B. K. Repo, Sexual Harassment on the Job, Nolo Press, 
1992. 

Sanders, Jo Schuchat, The Nuts and Bolts of NTO: How to Help Women Enter Non-
Traditional Occupations, Scarecrow Press, 1986. 

Siegel, Deborah L., Sexual Harassment: Research and Resources, National Council 
for Research on Women, 1991. (40-page handbook) 

Simons, George, Working Together: How to Become More Effective in a 
Multicultural Organization, Crisp Publications, 1989. 

Simons, George, and D. Weissman, Men and Women: Partners at Work, Crisp 
Publications, 1990. 

Tannen, Deborah, You Just Don't Understand: Women and Men in Conversation, 
Ballantine Books, 1990. 

Women's Bureau, Work and Family Resource Kit, U. S. Department of Labor, 200 
Constitution Ave. NW, Room S-331, Washington, D. C. 20210. (Single copies 
available free.) 

Women's Issues Advisory Committee, Guidelines for Integration of Women into the 
California Fire Service, California Fire Fighter Joint Apprenticeship Program, 
1990. 

Organizations and their publications: 

International Association of Black Professional Fire Fighters, 1025 Connecticut 
Ave. NW, Suite 610; Washington DC 20036; 202/ 296-0157. The IABPFF has national, 
regional and chapter committees on Black Women in the Fire Service. 

International Association of Fire Fighters, 1750 New York Ave., NW, Washington, 
DC 20006; 202/ 737-8484. The IAFF makes available to its members the IAFF Manual 
on Human Relations, a "Hair Kit" on fire department 
grooming standards, the original IAFF/ USFA manual, Managing the Entry of Women 
in the Fire Service, and a synopsis of information on Pregnancy and Collective 
Bargaining. 

9 to 5, National Association of Working Women, 614 Superior Ave., NW; Cleveland 
OH 44113; 216/ 566-9308. Job Problem Hotline: 800/ 522-0925 (from Ohio: 216/ 
621-9449). Resources and guidance for women on sexual harassment and other work-
related concerns. 

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NOW Legal Defense and Education Fund, 99 Hudson St., New York NY 10013; 212/ 
925-6635. Information on sexual harassment; guidance on anti-harassment policy 
development. 

Women in the Fire Service, P. O. Box 5446, Madison WI 53705; 608/ 233-4768. WFS 
publishes a quarterly periodical on fire service women's issues; information 
packets and sample policy language on sexual harassment, maternity/ reproductive 
issues, and other topics; and recruitment brochures and recruitment/ orientation 
information packets aimed at women candidates for firefighter jobs. WFS also 
holds biennial conferences on fire service women's issues. 

Women's Legal Defense Fund, 1875 Connecticut Ave. NW, Suite 710; Washington DC 
20009; 202/ 986-2600. Information on sexual harassment; advocacy on harassment 
and other sex discrimination issues. 

In June of 1992, the U. S. Fire Administration and Women in the Fire Service 
convened a symposium at the National Fire Academy entitled "The Changing Face of 
the Fire Service." The symposium brought together fire service leaders and 
others from all over the U. S. to review the draft of this manual. 

USFA Administrator Olin Greene and FEMA Director Wallace Stickney were present 
to welcome the group. Both stated their support for FEMA/ USFA' s recent 
initiatives regarding fire service women, and encouraged the participants to 
share their ideas about the manual. 

Copies of the manual were sent to participants before the symposium. The 
material was divided into four subject areas, and each person was assigned to 
attend work sessions on two of the four areas. These work sessions generated 
valuable discussion and input into the various topics; many of the suggestions 
received were incorporated into the final version of the manual. 

Symposium attendees also reviewed many of the videotapes that the manual lists 
as resources for fire departments in the areas of sexual harassment and cultural 
diversity training. The symposium adjourned following a closing session that 
provided summaries from the work sessions and final discussion of the manual. 
Feedback from the participants was universally positive about both the manual 
and the symposium. Many attendees recommended that the USFA update the manual on 
a regular basis and hold annual symposia at the National Fire Academy on fire 
service women's issues. 

The authors of the manual sincerely thank all of the symposium attendees for 
contributing their time and ideas. We also thank the U. S. Fire Administration 
for making both the manual and the symposium possible. 

Photo credits: 

Pages 4-5: Women in the Fire Service 
Page 7: Vic Nicastro 
Page 8: Women in the Fire Service 
Page 18: Women in the Fire Service 
Page 21: Women in the Fire Service 
Page 33: Women in the Fire Service 
Page 39: Black & White Studios 
Page 47: Women in the Fire Service 
Page 52: Women in the Fire Service 
Page 68: Dan Jones 
Page 71: Women in the Fire Service 
Page 75: Women in the Fire Service 

All illustrations by Patricia Henry. 

*U. S. Government Printing Office: 1993 --717-207/ 80981 

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