Two In/Two Out: Increasing the Safety Margin for Industrial Fire Brigades

OSHA's respirator standard introduces new requirements for fire brigade members entering dangerous situations.

The OSHA Respiratory Protection standard (29 CFR sections 1910 and 1926) is an extensive document that applies to all private sector workers engaged in firefighting activities with industrial fire brigades. Employer compliance became effective Oct. 5, 1998.

The standard, in 29 CFR 1910.134(g)(4), specifically addresses the need for the safety of firefighters engaged in interior structural firefighting. This provision requires that at least two employees enter an Immediately Dangerous to Life and Health (IDLH) atmosphere and remain in visual or voice contact with each other at all times. It also requires that at least two employees be located outside the IDLH atmosphere, thus the term, "two in/two out."

The changes affect those fire brigades that conform to OSHA"s definition of an interior attack team. Members of an interior structural team are trained and equipped to function as firefighters during all fire situations in the plant. However, an organizational statement must be in place and must be commensurate with the expected functions.

Interior attack can be defined as the physical activity of fire suppression, rescue or both, inside of a building or enclosed structure in which the fire is beyond the incipient stage. Firefighter exposure during this activity is extremely hazardous. Typically, those hazards that an interior brigade member may encounter include elevated temperatures (ceiling temperatures can reach or exceed 1,200 F), flame, reduced visibility, unfamiliar settings, physical stresses and entering into a hazardous situation from which others are fleeing. It is considered IDLH and the use of self-contained breathing apparatus (SCBA) is required. The incident commander shall judge whether a fire is an interior structural fire and how it will be attacked.

The OSHA standard requires having at least two firefighters stationed outside during interior structural firefighting. They must be trained, equipped and prepared to enter, if necessary, to rescue the firefighters inside. An explicit exemption in the standard states that if life is in jeopardy, firefighters have the discretion to perform the rescue, and the two in/two out requirement is waived. This is not a violation of the standard under such circumstances.

The standard is not intended as a staffing requirement. While waiting for additional firefighters to arrive, the fire may be attacked only from the outside.

Facilities may consider forming a Rapid Intervention Team (RIT). Its primary function is to respond to firefighters in distress. While this concept may be new to industrial brigades, some municipal departments have dedicated RITs. The formation of RITs allows at least two members to stay outside before initiating the interior attack. One can serve in an accountability function, monitoring the safety of the interior forces. The second member must be in communication with the first and may participate in other functions so long as abandoning such other function will not jeopardize any firefighter working at the incident. RIT shall report directly to the incident commander.

If accountability cannot be maintained with a single team, or if rapid rescue becomes infeasible, additional outside personnel must be added. An example would be if the structure were large enough to require entry at different locations, then additional RIT would be required for each point of entry.

Likely situations that may require activating RIT include firefighters trapped in a structural collapse, or who are injured or lost and unable to get to an area of safety outside the structure. Additional events include rollover, flashover, backdraft and an explosion.

To assist in compliance, managers should support RIT by assisting them in developing size-up and preplans of buildings or process units. Preplans could include building size, type of situations that may be encountered (e.g., fires, explosions, hazardous materials incidents), type of fixed fire protection equipment in place, and the number of people working. OSHA requires preplans in 1910.38, Employee Emergency Plans. Additionally, equipment needs such as personal alert safety system (PASS) devices, axes, pike poles, circular saws, ladders, ropes and additional air supply may need to be purchased. Communication equipment includes the use of radios, hand signals and tag lines. Fire brigade training time will depend on the size of the brigade, its level of experience, and the size of the property it is expected to protect.

The "two in/two out" standard is expected to be referenced in NFPA 1081, "Proposed Standard for Industrial Fire Brigade Member Professional Qualification." This document is scheduled for a fall 2001 release.

According to the National Fire Protection Association, 85,400 firefighters were injured in the line of duty last year in the United States. Of these, an estimated 4,750 had to be hospitalized 12.3 percent more than were hospitalized the year before. Some were hurt so severely that they can never return to work. With the concept of the Rapid Intervention Team, and by efficient training, planning and teamwork, only then can we begin to decrease those numbers.

Michael J. Curtis, M.S., is interim assistant director of the Louisiana State University Industrial Fire and Emergency Training Institute, Baton Rouge, La. Mr. Curtis has 16 years' experience in industrial emergency response. He serves on the National Fire Protection Association"s Technical Committee, NFPA 1081, Standard for Industrial Fire Brigade Member Professional Qualification, and is chair of NFPA's Lodging Industry Section, which addresses fire safety issues in the hotel-motel industry. He is a certified educator with the Emergency Management and Accreditation and Certification System, and holds a master's degree in fire safety management. He can be reached at (800) 256-3473 or via e-mail at [email protected]

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