THE “FINAL RULE”: IDEAL COLLIDES WITH REALITY
BY BILL MANNING
You`re the officer of Engine 1. At 2 a.m., you receive a report of a house fire. You arrive and find a large 212-story wood-frame private dwelling well-involved. Fire is blowing out of windows on the second floor, and smoke is belching from the attic. There`s no sign of the occupants, but there`s a car in the driveway and a bike on the lawn. And you know you have to conduct a legal fire operation.
If customers were hanging out of second-floor windows, you could effect immediate rescue legally with a three-man crew. However, in this case there are no occupants at the windows. Perhaps they`re inside, but you don`t know–you couldn`t legally justify an interior search operation on a hunch.
You think to yourself, Damn! If we had a fourth person I could send him to perform quick searches of the second-floor bedrooms behind the fire by way of a portable ladder. Then you realize VES (vent-enter-search) now is illegal–it violates the buddy system.
Of course, you want to get water on the seat of the fire–that handline will work wonders for customers who may be inhaling the products of combustion. But you`re “America`s fire company”–you run with a driver/engineer and a firefighter. The engineer connects to the nearest hydrant, then works the pump panel. The firefighter pulls the preconnect up the front walk. You walk quickly around the building performing your size-up. Charge that line, but wait just a minute! You can`t go in because it`s illegal to initiate an interior attack unless you have two firefighters outside to rescue you if you get in trouble–and right now, you have only one, the pump operator, and he doesn`t count because he can`t leave the pump panel without compromising fireground safety!
You`ll have to wait for the next-in apparatus. It should be here in about two or three minutes. If people are in the building, you hope they can wait that long. Some of the neighbors have come to watch. One of the customers asks you why you`re not doing anything to put out the fire. You say, “What, and make this an illegal operation?”
Meanwhile, the fire is growing. You radio for second-alarm mutual-aid companies to respond. You`ll get two more engines and a quint in about 10 minutes, or a little more.
The second pumper, Engine 2, arrives. It`s staffed identically to Engine 1. You have a quick face-to-face with the second-in company officer and pass command to him. You and your firefighter stretch the line in the front door and up the stairs to begin your attack, now that it`s legal to do so.
Outside, the commanding officer directs Engine 2`s driver and firefighter to stretch a backup line from Engine 1. The line is charged. Suddenly, the officer calls them back–if he doesn`t keep them outside and ready for firefighter rescue purposes, he`ll have an illegal operation on his hands. He wonders if it`s legal to detail his outside firefighters to horizontal ventilation; after giving some thought to legalities, he decides to do so.
You radio from inside that there`s heavy fire and you`re taking a beating. You need a vent, and that second line needs to be put into operation.
The chief arrives. Command is passed properly. Engine 2 tells the chief that Engine 1 needs help on the second floor and above. Primary search has not been initiated.
The chief orders Engine 2 and his personnel, after they complete horizontal ventilation, to stand fast at the command post. He explains that neither he nor the pump operator could effect an interior firefighter rescue without jeopardizing fireground safety. It would be illegal to stretch in the second line at this time–we need at least two firefighter rescuers at the command post. The firefighter from Engine 2 can`t go in by himself–it`s illegal.
Truck 1 arrives. It is staffed by a driver/operator.
You (Engine 1) radio that you`ve knocked down most of the fire on the second floor. In a few minutes you`ll be moving up the stairs to attack the heavy fire in the attic.
To keep this a legal operation, the chief will have to choose between primary search and vertical ventilation: Doing both would leave him short one firefighter rescuer. The chief would like to direct the truckman to raise the aerial to the roof and cut a vent hole, but he knows the truckie then wouldn`t be in position to effect firefighter rescue if needed, making this an illegal fireground. He orders Engine 2 and the truckman to conduct a primary search on the second floor. The driver and firefighter from Engine 2 still stand fast at the command post. Everything still is legal.
Even with the horizontal vent, it`s still smoky on the second floor. The search team makes its way down the hallway. They split up to search two large bedrooms on the uninvolved west side of the house. It`s a legal procedure because they maintain voice contact with each other.
The first mutual-aid unit arrives. The second line is stretched up the stairs and the initial-attack team is relieved.
The search team radios command that it`s bringing out two victims from the west bedrooms ….
The Occupational Safety and Health Administration`s final ruling on its revised federal regulation on respiratory protection, 29 CFR 1910.134, is being touted by OSHA and some in the fire service as an important step toward improving firefighter safety. An OSHA press release trumpets, “Firefighters battling indoor blazes are among the more than 900 workers annually whose lives can be saved” by the new regulation.
The final rule says that an interior attack on a building fire (in an immediately-dangerous-to-life-and-health environment, defined by OSHA as anything larger than an incipient fire) cannot begin unless at least two firefighters are on the line and at least two firefighters are outside to effect a firefighter rescue should it become necessary. This is the well-known and well-debated “Two In-Two Out” rule. In addition, interior search must be accomplished in teams of two.
For fire departments that send a rapid intervention team as part of the regular first-alarm assignment to all working fires, a practice that has become more common, the Two In-Two Out rule is almost a nonissue. But there are many, many fire departments of every shape and size throughout the country that are not assembling or are incapable of assembling the proper numbers needed to perform an “OSHA-legal” interior attack immediately upon arrival at a structure fire.
Fireground staffing in many towns and cities is a disgrace, an insult to firefighters and the public. Hopefully, the final rule will arouse fire departments–and the city fathers (and mothers)–to change their attitudes about acceptable levels of human resources required at the outset of a working structure fire–a level that far exceeds the additional staffing requirements established by OSHA in this regulation.
Until that time, however, many fire departments will be caught in the inevitable collision between the ideal of regulations and the reality of the fireground.
