Two In – Two Out. Friend or Foe?

PART 1

As most firefighters are now aware, the Federal Occupational Safety and Health Administration (OSHA) released the revised respiratory standard 28 CFR Parts 1910 and 1926, Respiratory Protection, on January 8, 1998, was effective on April 8, 1998, and has been in effect since then. This new mandate is commonly referred to as the 2-in/2-out rule, is a federal mandate, and has the potential to dramatically affect every public and private firefighter in the United States. As this regulation is being billed as “the most important advance in firefighter safety in decades”, and “a regulation that goes a long way in making one of the most dangerous professions safer”, let’s briefly review some of its highlights:

The standard applies to all private sector personnel engaged in fire suppression operations through industrial fire brigades, private incorporated fire companies (including the personnel of incorporated volunteer companies and private fire departments contracting to public jurisdictions), federal firefighters, and professional career firefighters in any state where an OSHA state plan agreement is in effect. Any state that is a “state plan” state is responsible to implement their own enforcement program and ensure that any state regulations are at least as stringent as the federal OSHA regulation.
Federal OSHA has no direct enforcement authority over states that do not have state OSHA plans (approximately 25 states). However, the two in/two out rule will be considered the minimum acceptable standard for firefighters engaged in fireground operations that require the use of breathing apparatus, and these states will still be affected by the “standard of care” the rule presents.
Once firefighters initiate an interior attack on a structure fire, OSHA considers the interior environment to be IDLH (immediately dangerous to life and health). Any structure fire beyond the incipient stage is considered to be an IDLH atmosphere by OSHA.
All personnel engaged in interior structural suppression operations beyond the incipient stage must use SCBA’s, work in teams of two or more, and maintain voice or visual contact with one another at all times. Although portable radios can be used for fireground communications, radio contact is not acceptable to replace visual or voice contact between team members due to the potential of mechanical or reception failure.
OSHA requires at least one team of two properly equipped and trained personnel be present outside a structure before any team or teams of personnel enter a structure fire. The exterior team of two personnel must be able to account for the interior teams(s) and be capable of rapid rescue of the interior team(s). The exterior team shall be comprised of one member who is specifically responsible for accountability of the interior team(s), and if necessary, initiate a rescue. The other designated person of the exterior team can perform other roles (i.e., Incident Commander, etc) as long as those roles can be immediately abandoned without placing any personnel at additional risk if a rescue or other assistance is necessary. Therefore, an initial interior attack on a structure fire requires a minimum of four personnel before an interior attack can be initiated.
If an incident escalates and accountability cannot be properly maintained from a single vantage point, additional exterior rescue teams are necessary. As an example, if a structure is large enough to require entry at different locations or levels, additional exterior rescue teams would be required.
If an immediate action is necessary to save a life, an exception or deviation to the 2-in/2-out rule is permissible. If initial attack personnel are aware of an known life hazard that can be alleviated by immediate action, deviation from the 2-in/2-out rule may be permitted as an exception to a fire department operational plan. However, such deviations can result in OSHA issuing a “de minimis” citation. A “de minimis” citation does not require a monetary penalty or corrective action, but any actions taken in accordance with this exception provision require an investigation by the concerned fire department with a written report to the Fire Chief.
Personnel must adhere to the 2-in/2-out regulation for other emergency response operations in any IDLH, potential IDLH, or unknown atmosphere.

As with any new regulation, any modification to the “status-quo” can result in positive and negative considerations. This is particularly true when the 2-in/2-out rule is applied to fireground operations. The obvious benefit is staffing levels and standards. In an era of continual monetary constraints and reduced staffing levels, a “recognized national standard” is a major consideration when applied to justifying or maintaining a minimum staffing level of four when most fire departments are forced to staff their apparatus with three personnel, and some apparatus are staffed with two personnel. In the area of standards, one would assume that the use of SCBA in contaminated environments and the principle of accountability in fireground operations would be a standard operational procedure. Unfortunately, this is not the case and can be easily verified when current statistics indicate that 30% of firefighter deaths occur to “lone rangers.” Additionally, a quick review of any national fire service magazine readily indicates that all fire suppression personnel do not wear full SCBA in contaminated environments. Therefore, as the influence of regulatory standards increases, the lack of fireground accountability and inappropriate use of full SCBA should decrease.

However, when customer service, practicality, and fireground safety are considered, the 2-in/2-out regulation can lose some of its apparent luster when fire departments respond (current tense) or may respond (future tense) to a structure fire with an initial response of less than four personnel. In part 2, we will consider customer service and some additional considerations from another perspective.