Rescue: Are You In Or Out? It’s 2 a.m. and your three-person engine company arrives at scene of a two-story, wood-frame, single-family dwelling. It has fire showing from the first floor of the Alpha/Delta corner, and your next due engine is two minutes out. So 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, the fire service has placed Rescue as the top priority when conducting fire operations. However, for many departments, that all changed in 1998, when Federal OSHA modified the Respiratory Standard (29 CFR, 1910.134) to include structural firefighting. The Respiratory Standard is also known as the Two-in/Two-out Standard. This standard, together with an interpretation of the standard produced jointly by the IAFC/IAFF, has 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 have taken the “R” out of RECEO, by developing policies based on inaccurate information. It’s time we revisit the Respiratory Standard and see what it really says and 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 and territories that have a two in/two out provision include: 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, Virginia, Vermont, Virgin Islands, Washington, and Wyoming. In addition, Florida, Illinois, and Oklahoma have adopted state laws that reference the Federal OSHA regulations. The federal OSHA Standard applies to all private sector firefighters, industrial fire brigades, and federal firefighters. Check with your own state, as many have adopted similar two in/two out regulations. Once the federal standard is adopted, state agencies have six months to adopt a plan that is as effective as the federal standard. Therefore, most state plans should be similar to the federal standard. States are allowed to make their standard more restrictive, but not less restrictive. Regardless, you are strongly encouraged to review your specific plan for accuracy. So what does the standard say? In 1998, the following section, (g)(4), was added to 29 CFR 1910.134:
The Respiratory Standard relating to structural firefighting is pretty straight forward, but let’s take a quick review. The standard outlines the following:
The section that has probably been most inaccurately interpreted is in Note 2 to paragraph (g), which states:
So, why the confusion? Soon after the federal standard was adopted, a joint letter by the IAFF and IAFC was sent to every fire agency in the nation, which attempted to interpret the standard. The IAFF/IAFC interpretation states the following:
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 federal 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. So, 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," even though the term "KNOWN rescue" is not found in any documents published by federal OSHA. In fact, a clarification of the Respiratory Standard by the New Mexico OSHA in response to questions by Senator Jeff Bingaman of New Mexico states: “….[I]t 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.” 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. This is also not supported in OSHA documentation. In the document, “Questions and Answers on The Respiratory Protection Standard,” produced by OSHA in 1998, it is called an exemption. The document states, 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.” 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 and fast rules about saving the lives of others. No federal, state, or local mandate can take the burden off the shoulders of rescuers when making the decision to save another’s life. 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-slc.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 © Copyright Firenuggets.com 2007 • Click here for Terms and Conditions of Use
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