As discussed, OSHA is making significant revisions to its Fire Brigade standard. And in the DRAFT version, OSHA establishes a minimum staffing level for working/entering an IDLH atmosphere. Many of you who are part of or manage the fire brigade may recall that OSHA has made room for “judgment” regarding staffing available and performing life-saving operations. In fact, this is what OSHA used to say about the 2 in-2 out rule regarding firefighters and rescue…
Nothing in this section is meant to preclude firefighters from performing emergency rescue activities before an entire team has assembled.
This note in 1910.134 opened the door for many leaders to believe that placing FFs in IDLH environments to attempt a rescue of an occupant was an acceptable practice. Here are the full requirements from 1910.134 regarding interior attacks/rescue, as well as the proposed requirements for FFs entering IDLH environments/atmospheres:
(emphasis by me)
Note 2 to paragraph (g): Nothing in this section is meant to preclude firefighters from performing emergency rescue activities before an entire team has assembled.
This is what OSHA is proposing:
To ensure operations at an incident scene are conducted safely, the ESO would be required to: identify minimum staffing requirements to ensure incidents are mitigated safely and effectively, ensure operations are limited to those that can be safely performed by the responders available on the scene; ensure at least four responders are assembled before operations are initiated in an Immediately Dangerous to Life or Health (IDLH) atmosphere, and ensure at least two responders enter the IDLH to operate as a team and at least two responders are present outside the IDLH to provide assistance to, or rescue of, the entry team.
To further ensure responder safety on incident scenes, the ESO would be required to implement the following in accordance with the SOPs established above:
- a responder accountability system;
- a Rapid Intervention Team; medical and rehabilitation procedures; and scene safety (traffic) procedures.
At some incidents, there may be a need for assistance from employers that are typically considered to be outside the emergency response community but who may be called upon to
assist an ESO by providing a service, equipment, or worker. For instance, an ESO may need to remove a heavy object, requiring the use of a crane or other heavy-duty equipment, available through a Skilled Support Employer (SSE). To ensure SSWs are prepared to operate safely on an emergency incident in support of the ESO, the ESO would need to ensure:
- an initial briefing is provided to each Skilled Support Worker (SSW), which includes instruction in the use of appropriate PPE, what hazards are involved, what safety precautions are to be taken, and what duties are to be performed by the SSW;
- an effective means of communication between the IC and the SSW; and
- other appropriate on-scene safety and health precautions provided to ESO responders that are used to ensure the safety and health of the SSW