By TJ Welch
It’s 2 a.m. and your three-person engine company arrives at the scene of a two-story, wood frame, single-family dwelling. There is fire showing from the first floor of the Alpha/Delta corner, and your next due engine is two minutes out. The question for you is, do you go in or stay out?
Since 1952, when Lloyd Layman outlined the basic divisions of fire tactics through RECEO (Rescue, Exposures, Confinement, Extinguishment, and Overhaul), the fire service has placed rescue as the top priority when conducting fire operations. This changed in 1998 for many departments, however, when the Occupational Safety and Health Administration (OSHA) modified the Respiratory Protection Standard (29 CFR, 1910.134) to include structural firefighting. The respiratory standard is also commonly known as the Two-in/Two-out Standard. This standard, together with an interpretation of the standard produced jointly by the International Association of Fire Chiefs and International Association of Fire Fighters, changed firefighting operations across the country.
Did the new respiratory standard have an affect on the way your fire department establishes tactical priorities? If so, you’re not alone. Many departments took the “R” out of RECEO when they developed policies based on inaccurate information. I think it’s time we revisit the respiratory standard and see what it really says about two in/two out so we can put the “R” back in RECEO.
First, we need to establish who is required to have a two in/two out policy. If you’re a municipal firefighter, the federal Standard may not apply to you unless you work in an OSHA state. The OSHA States that have a two in/two out provision are Alaska, Arizona, California, Connecticut, Hawaii, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Nevada, New Mexico, New York, North Carolina, Oregon, Puerto Rico, South Carolina, Tennessee, Utah, Vermont, Virginia, Virgin Islands, Washington, and Wyoming.
In addition, Florida, Illinois, and Oklahoma have adopted State Law that references the OSHA regulations. The federal OSHA Standard applies to all private sector firefighters, industrial fire brigades, and federal firefighters. Check with your own state since many have adopted similar two in/two out regulations.
Once a federal standard is adopted, OSHA state agencies have six months to adopt a plan that is as effective as the federal standard, making most state plans similar to the federal standard. Since states are allowed to make their standard more but not less restrictive, it is important that you review your specific plan.
In 1998, OSHA added the following section, (g)(4), regarding Structural Firefighting in 29 CFR 1910.134.
Excerpt from Standard–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 Respiratory Standard relating to structural firefighting is pretty straightforward, but let’s take a quick review.
- Buddy system: There must be at least two members when entering an IDLH atmosphere and all interior members must be in visual or voice contact at all times, meaning radios are not acceptable for interior crews communicating with each other. The fire service has been practicing the buddy system for over 35 years. I hope it doesn’t take a law for your department to understand the significance of working in pairs.
- Two out: There must be at least two members outside of the IDLH atmosphere. This is where Note 1 comes in. It clarifies who the two members outside can be. It can be the IC, Safety Officer, or other member as long as it does not put the members inside the IDLH atmosphere in jeopardy by leaving their assignment. This is open for debate, because some agencies use a very liberal interpretation. (Further explanation can be found in the OSHA Q & A document).
Important: Two out does not constitute a Rapid Intervention Team (RIT). It is the very minimum number of personnel required to enter the IDLH atmosphere. On the other hand, RIT does meet the requirements for two out. - SCBA–All members inside the IDLH atmosphere shall use a SCBA. Common sense should prevail here and full personal protective equipment should always be worn.
The section that has probably been most inaccurately interpreted is in Note 2 to paragraph (g) above.
So, where is the confusion? Soon after the federal Standard was adopted, a joint letter by the IAFF and IAFC was sent to fire agencies across the nation, which attempted to interpret the standard. The IAFF/IAFC interpretation states the following,
Does OSHA recognize any exceptions to this regulation?
OSHA regulations recognize deviations to regulations in an emergency operation where immediate action is necessary to save a life. For fire department employers, initial attack operations must be organized to ensure that adequate personnel are at the emergency scene prior to any interior attack at a structural fire. If initial attack personnel find a known lifehazard situation where immediate action could prevent the loss of life, deviation from the two-in/two-out standard may be permitted, as an exception to the fire department’s organizational plan.
However, such deviations from the regulations must be exceptions and not de facto standard practices. In fact, OSHA may still issue “de minimis” citations for such deviations from the standard, meaning that the citation will not require monetary penalties or corrective action. The exception is for a known life rescue only, not for standard search and rescue activities. When the exception becomes the practice, OSHA citations are authorized. [29 CFR 1910.134(g)(4)(Note 2)]
When comparing the respiratory standard and the interpretation by the IAFC/IAFF, there are some marked differences. Especially, in regards to making entry for rescue prior to two-out being established. It’s no wonder that departments developing policy based on the IAFF/IAFC document have concluded that no one should enter an IDLH atmosphere prior to establishing two out, unless there is a “known” rescue. The term “known” rescue is not found in any OSHA documents that I could find.
In fact, a clarification of the respiratory standard by New Mexico OSHA in response to questions by Senator Jeff Bingaman of New Mexico states “….it also does not prohibit firefighters from entering a burning structure to perform rescue operations when there is a reasonable belief that victims may be inside.” There is a big difference between “reasonable belief” and “known” rescue.
To cause further confusion, the IAFF/IAFC document uses the term “exception” in regard to Note 2, stating that when exception becomes practice, OSHA citations are authorized. Sounds serious, but I could not find any OSHA documentation that supported the statement. In the document, “Questions and Answers on The Respiratory Protection Standard” produced by OSHA in 1998, it is called an exemption. That document states the following:
Question: “Must firefighters wait until four workers are assembled before attempting to rescue victims inside the burning structure?
Answer: “No. There is an explicit exemption in the respiratory protection standard that if life is in jeopardy, the two-in, two-out requirement is waived. The incident commander and the firefighters at scene must decide whether the risks posed by entering an interior structural fire prior to the assembly of at least four firefighters is outweighed by the need to rescue victims who are at risk of death or serious harm. There is no violation of the standard under rescue circumstances.”
I encourage you to read the material for yourself. There is a lot of documentation out there to wade through, but the last thing we need is enforcement agencies telling us how to take care of our own, or creating hard, fast rules about saving the lives of others.
After you’ve had a read, decide for yourself: are you going in, or staying out?
References
The Federal Standard, 29 CFR, 1910.134, http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=12716&p_table=STANDARDS
OSHA “Questions and Answers On The Respiratory Protection Standard”
http://www.osha.gov/qna.pdf
OSHA response to Senator Bingaman
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22665
The IAFF/IAFC document
http://www.iaff.org/hs/PDF/2in2out.pdf
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TJ Welch is a battalion chief with the Alameda County (CA) Fire Department. He has served on the Board of Directors for the Cal Chief Training School-Northern Division for 13 years. He has been an FDIC advisory board member and HOT class instructor, and has been in the fire service for 26 years. |
