BY BOBBY HALTON
There is a law in South Bend, Indiana, that says it is illegal for monkeys to smoke cigarettes. The problem with old laws is that they are still laws. Sometimes rules are timeless, like “Do unto others …,” but rules that deal with complex and changing operational factors need our constant attention.
In firefighting, where high-velocity human factors play critical roles in the development of our rules, standards, and laws, we need to exercise our responsibility to reexamine the effectiveness and functionality of theses rules periodically. Often, what was originally a rule was a means to an end—albeit with the best of intentions. When trying to solve complicated issues, we sometimes couple legitimate concerns and, in doing so, we can confuse both issues in the process. Such is the case with our current Occupational Safety and Health Administration (OSHA) “two-in/two-out rule” as it relates to staffing and rapid intervention—both important issues and both critical to firefighter safety.
There is no argument that rapid intervention teams (RITs) are necessary at working fires to improve firefighter safety and survival. The evidence is now overwhelming that RITs, when properly staffed and trained, have saved firefighters’ lives. If National Fire Protection Association (NFPA) 1710- and 1720-compliant staffing managed within National Incident Management System (NIMS)-compliant guidelines is the optimum way to ensure safe effective fireground operations, then why is the rate of interior structural firefighting injuries and deaths still rising?
In a perfect world, we all arrive within a window of opportunity to operate effectively with sufficient numbers of properly trained, physically fit, and correctly outfitted firefighters. We’d have correct information regarding the event and sufficient familiarity with the structure on fire to direct operations. We’d have unimpeded communications and total understanding of the strategic, tactical, and task integration needed to accomplish the rapid and complete extinguishment of the fire and the safe removal of any threatened persons.
Unfortunately, neither the world nor we are perfect; life is messy and complicated, often confused; and the fireground is always dynamic. This is the reason laws such as the OSHA two-in/two-out rule are so important and we routinely review and adjust them to the current reality where they are applied. The current OSHA Respiratory Protection Standard CFR 1910.134 was published 10 years ago, at a time when our experience with RIT was limited. Now is the time to reopen the discussion and see how it has been interpreted and adopted in real practice, then direct the right tacticians to rewrite it with greater clarity and inclusiveness to allow greater compliance and effectiveness.
The history of the rule is interesting. There was also a growing recognition more than 10 years ago of the need to formalize rapid intervention crews. In the late 1990s, the NFPA 1500 committee recognized staffing to be paramount to firefighter safety; however, opposition was strong. The committee was also deeply committed to improving firefighter assistance and rescue. With the publication of OSHA 1910.134, both issues were addressed: staffing was addressed, two plus two equals four and firefighter rescue was addressed, and two in/two out became law.
What we have seen since the passage of the OSHA two-in/two-out rule, unfortunately, has been a steady decline in staffing. Couple two in/two out with some organizations’ interpretations of command requirements, and we have crews that are unable to operate in a proactive interior mode until the arrival of the second engine company.
The section of OSHA’s Respiratory Protection Standard that pertains to structural firefighting reads this way:
- 1910.134(g)(4)
- Procedures for interior structural firefighting. In addition to the requirements set forth under paragraph (g) (3), in interior structural fires, the employer shall ensure that:
- 1910.134(g)(4)(i) At least two employees enter the IDLH atmosphere and remain in visual or voice contact with one another at all times;
- 1910.134(g)(4)(ii) At least two employees are located outside the IDLH atmosphere; and
- 1910.134(g)(4)(iii) All employees engaged in interior structural firefighting use SCBAs.
- Note 1 to paragraph (g): One of the two individuals located outside the IDLH atmosphere may be assigned to an additional role, such as incident commander in charge of the emergency or safety officer, so long as this individual is able to perform assistance or rescue activities without jeopardizing the safety or health of any firefighter working at the incident.
- Note 2 to paragraph (g): Nothing in this section is meant to preclude firefighters from performing emergency rescue activities before an entire team has assembled.
The law, which is 154 words of an 18,000-word law, states one firefighter can function outside as command because stopping command to perform firefighter rescue will not jeopardize safety. However, the other firefighters can have no other duties. As I read it, even with a four-person crew, we have a dilemma: If we form the initial RIT in compliance with the two-in/two-out rule, who is going in from a four-person crew? The pump operator cannot be on the team, as leaving the pump unstaffed clearly constitutes “jeopardizing the safety or health of any firefighter working at the incident.” So we are left with one, and one can’t go in because that violates the “buddy rule” (a previous section of the law).
There are tremendous concerns regarding interpretations of this law. Many have sadly chosen to ignore it altogether at tremendous personal risk and exposure. Wouldn’t it serve us better now that we have 10 years of experience and adaptation to rewrite the law? What is a realistic initial rescuer profile for the diversity of response profiles we have in our profession? The discussion must begin here. When this was written, our knowledge of rapid intervention was much less thorough than it is today. Just like the dangers of smoking monkeys, we know a lot more about two in/two out now.
