Firefighter Two-In, Two-Out Rule: OSHA Standards Explained

Introduction

The "two in, two out" procedure is one of the most significant safety protocols employed by firefighters. This report defines the "two in, two out" procedure, explains why it is important, and examines how it is applied in practice. It also summarizes interviews with two firefighters of sufficient rank and experience to speak to compliance within their departments. Beyond that, the report offers a personal perspective on the practice within fire departments and draws on external sources that review and analyze the topic. While many rules and procedures may seem unnecessary to some, anything that pertains to safety in a hazardous occupation should not be taken lightly — and the "two in, two out" procedure is certainly emblematic of that principle.

Two In, Two Out Defined

The "two in, two out" standard was developed and refined by the Occupational Safety and Health Administration (OSHA). The standard protocol is essentially as follows: when there is a team of firefighters inside a structure engulfed in flames, there must be at least two team members inside. Those two team members must have direct visual or voice contact with each other, and voice or radio contact with firefighters positioned outside that same structure. The International Association of Firefighters and the International Association of Fire Chiefs jointly published a frequently asked questions document for those seeking to understand the law.

Part of the standards relating to the "two in, two out" protocol have been in place for some time. Since 1971, OSHA has required a respiratory protection standard, which mandates that employers establish and maintain a respiratory protection plan for employees who wear respirators — a category that clearly includes firefighters. A 1971 update strengthened certain requirements while loosening others that were considered duplicative of prior rules. The revised standard specifically addresses the use of respirators in atmospheres that are immediately dangerous to life or health, commonly abbreviated as IDLH. OSHA defines any structure involved in a fire beyond the "incipient" stage as an IDLH atmosphere by default. Consequently, OSHA requires that personnel operating in those areas use self-contained breathing apparatus (SCBA) devices. The "two in, two out" element of the standard specifies that when two firefighters are inside a structure actively fighting a fire, at least two more firefighters must be positioned immediately outside and ready to provide assistance or perform rescue as needed.

There is little question that the standard is critically important to firefighters. As noted in the frequently asked questions document, "this standard, with its two-in/two-out provision, may be one of the most important safety advances for firefighters in this decade." The document further notes that too many firefighters have died as a result of insufficient accountability and poor communications between team members. OSHA asserts that the "two in, two out" standard addresses both the communication problem and the overall accountability problem simultaneously. In the words of the relevant guidance, "the standard addresses both and leaves no doubt that two-in/two-out requirements must be followed for firefighter safety and compliance with the law."

Scope of Enforcement and State Compliance

The federal OSHA standard applies to all private-sector workers engaged in firefighting activities through industrial fire brigades, private incorporated fire companies (including the employees of incorporated volunteer companies and private fire departments contracting to public jurisdictions), and federal firefighters. In a total of twenty-three states and two territories, the state — rather than the federal government — holds primary responsibility for enforcing worker health and safety regulations as enacted by OSHA. To exercise that authority, states must establish and maintain occupational safety and health programs for all public employees, and those programs must be at least as effective as the federal standards that apply to private employees. It is also noted that federal OSHA has no direct enforcement authority over state and local governments in states that do not have state OSHA plans.

The states and territories that have approved "two in, two out" protocols and enforce them accordingly 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, Vermont, Virginia, the Virgin Islands, Washington State, and Wyoming. Some states have taken an intermediate step by adopting the OSHA "two in, two out" regulations specifically for public employee firefighters; these include Florida, Illinois, and Oklahoma. In such states, the regulations carry the force of law and must be complied with on that basis alone.

A separate set of standards also exists, known as the NFPA standards, published by the National Fire Protection Association. The NFPA published a relevant set of standards in 1997 under the designation NFPA 1500, and a number of states have adopted those regulations as well. The 1997 document mirrors the OSHA respiratory standards in many respects. However, it is important to note that the NFPA is a private consensus standards organization, and its recommendations are always superseded by OSHA standards when the OSHA version is more stringent. Regardless of which standard is followed, it is the view of many experts and regulators that the "two in, two out" standard should represent the bare minimum for all fire departments — both in the United States and in Canada — without exception.

Conclusion

The material covered in this report may seem straightforward, but there are certainly shades of gray. When it comes to fire mitigation and human life, following the rules exactly as written may not always feel like the best or most humane course of action. However, the rules should be followed in the vast majority of circumstances, because they exist for good reason — and the "two in, two out" standard is no exception.

References

Fire Engineering. (2010). Time to clarify "two in/two out." Fireengineering.com. Retrieved 21 July 2015, from http://www.fireengineering.com/articles/print/volume-163/issue-4/departments/letters-to_the_editor/time-to-clarify-two-in-two-out.html

OSHA. (1999, March 12). Complying with the "two-in, two-out" policy for interior structural firefighting. United States Department of Labor. Retrieved 21 July 2015, from https://www.osha.gov/pls/oshaweb/owadisp.show_document-p_table=INTERPRETATIONS&p_id=22711

[University]. (2015). United States Department of Labor Occupational Safety and Health Administration fire fighters' two-in/two-out regulation. Retrieved 21 July 2015, from