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Section 6-4 of the standard addresses operations at emergency incidents with several pages of detailed language. It requires that fire departments provide an "adequate number" of personnel to safely conduct on-scene operations. Members operating in hazardous areas at emergency incidents must operate in teams of two or more. In the initial stages of an incident, a minimum of four persons is required two inside and two outside the structure. But the standard allows one of the two standby members to perform other duties, such as technician or incident commander.
There also is an appendix that addresses apparatus staffing levels. It recommends four personnel for an engine or truck; in "high-risk areas," it recommends five people for engines and six for trucks. Notably, these recommendations are not contained in the language of the standard itself.
On May 1, 1995, OSHA issued a compliance memo regarding the minimum staffing required for emergency response operations where there are substances that are "immediately dangerous to life and health" (IDLH). Although written specifically to respond to the many requests for clarification that OSHA had received, there has continued to be considerable confusion and misunderstanding.
The OSHA memo parallels the NFPA standards, and takes notice of them. It also calls for a minimum of four personnel to conduct operations: two inside and two standby backup personnel. One of the members of the standby team may be assigned another role, such as incident commander or apparatus operator. Incipient fires which do not create a hazardous atmosphere or require the use of SCBA (or exterior operations) are not covered. Failure to follow this standard is a violation of the general duty clause.
But these guidelines didn't resolve the controversy. A year later (May 1996), OSHA again was issuing guidance. It noted that the matter had "generated considerable interest" (one way of saying it was controversial). Among the claims made were that OSHA had exceeded existing industry standards and thereby engaged in back-door rulemaking activity. It also was charged that the interpretation represented an unfunded mandate on certain states by increasing personnel requirements.
In response, OSHA has tried to make clear that the guidelines apply only to major high-hazard fires within a structure, not to minor interior fires. It also emphasized that the policy addresses personnel requirements only when firefighters are entering a structure, and not apparatus staffing requirements. It specifically cites the example of a three-person crew that could enter the building for lifesaving rescue or could undertake exterior operations. OSHA recognizes that there is support for a two-in/one-out rule. The controversy continues. Regardless of which policy is adopted, it will be subject to both political pressure and likely litigation.
Safety, for ourselves as firefighters and rescue workers as well as the citizens we serve, is the fire service's top priority. Anyone who ever has had to deal with a fatality or serious injury knows that the cost of prevention is far less than the emotional and financial costs associated with such a tragedy. It should be a part of the firehouse culture and not a matter of merely trying to follow a set of complicated rules. It requires a commitment at every level, from raw recruit to seasoned veteran to the department chief.