If you’ve ever skipped a rock across a still pond, then you’re familiar with the resulting ripples that expand across the water. Well, OSHA’s proposed changes to the Fire Brigades Standard has amounted to a boulder falling off a cliff and striking that pond with enough force to cause a tidal wave. These proposed changes – OSHA’s attempt to modernize a patchwork of related standards, rules and directives – deserve significant review and discussion by all members of the fire service. I’m still reviewing the vast proposal and will share my thoughts in a future piece. In the meantime, debate about our “2-in/2-out” requirements is just one of the waves spreading across our fire service waters.
I took some time to review a position paper recently posted on social media titled “Removing Two-In/Two-Out: A modern, data-supported defense of our core mission.” The paper was authored by Sean Duffy, Nick Ledin, Chris Thompson, J. Scott Thompson and Bill Carey, with the latter hosting the paper on the website, Data Not Drama. (I should also note that Carey serves as an associate editor for FireRescue1; however, the opinions shared on his website do not necessarily reflect those of Lexipol or FireRescue1.)
While the 2-in/2-out topic can prove to be a flashpoint in conversation and in reality for many smaller departments, the hyperbole does deserve some real-world perspective. I spoke with several people – firefighters and NFPA 1500 committee members alike – who were involved in the establishment of NFPA 1500: Standard on Fire Department Occupational Safety, Health, and Wellness Program, all of whom provided “off the record” analysis and discussion following the release of the 2-in/2-out position paper.
2-in/2-out origins
For many years prior to the fire department’s inclusion in this OSHA-related standard, other industries were already held to a “potentially IDLH atmosphere” rescue standard by OSHA and the Department of Labor. Confined space and oil companies, to name two, were required to have personnel “standing outside” who were capable of rescuing those inside. There was no mention of the number of people in either the IDLH or safe environment.
I have a tough time viewing the fire service as functional extensions of these other industries where events are normally scheduled in static environments, where time to plan and obtain resources is not time sensitive. Fire service incidents are usually dynamic from the beginning, with staffing and resources obtained in real time while an incident unfolds, worsening or improving largely based on the tactics we bring to bear.
In the attempt to find compromise and potentially compliant space for the fire service, the first two editions of NFPA 1500, in the 1990s, proposed a requirement for a minimum of three members to be on scene before IDLH operations could ensue – two could go in, one would remain out. The committee members I spoke with considered the “one” as more of an accountability/command function, capable of directing the next arriving to where the initial team of two had gone. The outside person could (at least theoretically) perform any of the functions of the incident commander (IC), pump operator or accountability person. The minimum requirement was simply for at least one person to remain outside (again, for a total of three). The document also referred to a rapid intervention team (RIT) as a requirement once an IC had confirmed a working fire.
At that time, the IAFF, which had several voting members on the 1500 committee, was adamant that NFPA 1500 should require a minimum of four firefighters per unit. The majority of the committee wisdom was that operational safety is governed by what you do and how you do it, not by how many firefighters ride on a truck. This manifested in a contentious vote on the floor of the annual NFPA convention. The IAFF was unable to sway enough votes to pass the “minimum of four” requirement into the standard, at which point the IAFF membership walked out and would not participate further in the codes-development process.
At some later date, lawyers from the Labor Department became engaged with lawyers from the IAFF who convinced the Labor Department that the “1-out” OSHA 1910.134 standard as written for other industries was really meant to be “2-out” from the beginning, as it referred to “men” (plural) being outside and prepared to affect rescue. Hence, “2-in/2-out” was born. The vote passed because OSHA required it, and OSHA formally adopted it because NFPA required it.
Where we stand today
Now, I mostly agree that four on a unit should be the minimum unit staffing target for any fire apparatus. I am 100% on board with creating safer environments for firefighters; however, I will join the chorus of argument that believes the 2-in/2-out requirement in the early stages of an incident is essentially a waste of at least one operational member. I am not aware of a single incident where the “2-out” actually affected an interior rescue when only those four were on scene – not a single incident out of millions of them. If it exists, please share the data.
For nearly 30 years, fire departments around the country have been inventing all kinds of complicated strategies to comply with, or subvert, 2-in/2-out. Some believe the only way to comply is to have four crewmembers on every apparatus. I dare say that most don’t really care if two stay outside, but all kinds of rules and procedures have been invented about who can or cannot be part of the “2-out” group, whether they have to be fully dressed with SCBA on their backs, if the pump operator can leave the panel to rescue a crewmember, and so on. Instead of spinning ideas of how to subvert rules, we need to ensure that we’re focused on safety and efficiency to mitigate incidents and rescue victims.
Data is king
The Data Not Drama position paper uses Project Mayday data as its benchmark for proof that “2-in/2-out” is a waste. Don Abbott founded the Phoenix Command Training Center and Project Mayday, the latter having been originally funded by a 2015 CERT grant specific to Arizona. In 2015 and 2016, I spoke with Abbott about his thought process and trying to help bring his data to a greater awareness. His vision was to educate firefighters and ICs on the causes of maydays and the signs/symptoms of an imminent mayday.
While the data provides a behind-the-curtain look at many critical moments that firefighters tend to miss or ignore, it is disingenuous to cite self-reported, non-peer-reviewed data as proof that “2-in/2-out” is useless. The data does suggest that most maydays were self-rescued or rescued by nearby crews already working inside the structure. My experiences would support that hypothesis; however, more specific and scientific peer review needs to be completed to validate the data.
Final thoughts
The IAFF has made its voice clear on NFPA processes, from the convention walkout in the 1990s to the 2023 lawsuit filed against NFPA related to PFAS in protective gear. Related to the more recent action, the NFPA countered with a statement calling the IAFF’s strategy “misguided and ill-informed.” The public display of our typically behind-the-curtain disagreements seems dysfunctional at best, and only time will tell how contentious the OSHA debates will turn.
In the meantime, considering our real-world experiences related to 2-in/2-out, I agree that we can make better operational use out of that initial fourth person on scene. The notion of 2-out is a great safety step for those non-emergent and scheduled industries that have the luxury of time on their side. For us, RITs should be our focus in development, training, establishment, and deployment. It doesn’t take a war of words to make improvements – it takes firefighters and fire chiefs doing the right thing in the exercise of our responsibility to protect the public and to make sure we do everything we can to ensure “everyone goes home.”
For the 30,000+ departments scattered across the country, the lack of volunteer or paid members is NO EXCUSE to compromise safety in any fashion. You need to find a way to get four personnel operating on your fire units. A work in progress for sure.
Finally, the Project Mayday data was always meant to serve as an educator about signs of a mayday – let’s keep it that way. I trust that firefighters will continue to self-report to the database, and that a proper constituent organization will pick up the effort to make sure data is more than an afterthought – that real and vetted data remains king.
