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Back to the main Respiratory Protection Page
Any employer who requires or permits employees to wear a respirator must have a written respiratory protection program. This is required by OSHA in both of their asbestos standards and their respiratory protection standard (29 CFR 1910.134). The written respirator program establishes standard operating procedures concerning the use and maintenance of respiratory equipment. In addition to having such a written program, the employer must also be able to demonstrate that the program is enforced and updated as necessary.
CPL 02-00-120 - CPL 2-0.120 -
Inspection procedures for the Respiratory Protection Standard.
|
Record Type: | |
Directive Number: | 02-00-120 |
Old Directive Number: | 2-0.120 |
Title: | procedures for the Respiratory Protection Standard. |
Information Date: | |
Standard Number: | 1910.134 |
[This document was edited on 7/14/2004 to strike information that no
longer reflects current OSHA policy. On 12/31/2003, 29 CFR 1910.139 was
revoked and the 1997 proposed standard on Occupational Exposure to
Tuberculosis (TB) was withdrawn in the Federal Register. The changes to
this directive were approved by the Assistant Secretary John Henshaw on
7/13/2004. The added language is marked by an asterisk (*) at the
beginning and the end of the paragraph.]
Charles Jeffress Assistant Secretary ![]() TABLE OF CONTENTS
CHANGE SCHEDULES GUIDE - A LISTING OF METHODS ![]()
|
The program must be tailored to cover the specific work operations and practices in the workplace. The provisions listed in paragraph (c)(1)(i) thru (ix) of the standard must be included in the written program unless it is determined they are not applicable.
These provisions are to be considered when evaluating a written program:
Compliance with the program should be verified during the walkaround by personal observation and employee interviews.
Use of elastomeric or supplied-air respirators, even when voluntary on the part of the employee, will require the employer to include all elements in a written program that will ensure use of these respirators does not create a hazard.
Companies with multiple worksites may have a program administrator at each worksite, as long as this person is qualified and retains the accountability and responsibility for the day-to-day operation of the specific program for that site. Alternatively, a company may opt to have one program administrator for several sites and/or one program for several similar sites as long as the program contains the necessary elements and addresses the hazards at those sites.
In regards to mathematical predictive equations, their
use should be limited to situations where workplace factors,
such as contaminant release and ventilation system
performance, are fairly constant over the work shift and
predictable. The results should incorporate reasonable
safety factors and be interpreted conservatively. CSHO's
must exercise a great deal of professional judgement in
concluding if the mathematical approach provides appropriate
guidance. (e.g., The methylene chloride standard forbids the
use of APR's for protection against methylene chloride and
would supercede any model which predicts a changeout time
for this chemical.) The CSHO should examine the employer's Hazard
Communication Program for further information on existing
respiratory hazards in the workplace. The Hazard Communication Standard requires employers to
inventory the hazardous chemicals in their workplace and to
maintain copies of material safety data sheets (MSDS) for
each hazardous chemical. In a similar manner under the
respirator standard, the employer must examine the workplace
and determine if the quantity, circumstances, and use of the
hazardous chemicals require further evaluation for
respiratory hazards. MSDSs contain information such as
physical and chemical characteristics and hazards, primary
route(s) of entry, and generally applicable control
measures. Some MSDSs include some recommendations on
appropriate respiratory protection. For those chemicals that do present a potential
respiratory hazard, employers can contact the chemical
manufacturer for additional information on predicted
exposure levels and methods to further control worker
exposure. The CSHO should be aware of the potential for an
emergency situation and the type of respirators selected.
The employer must provide the appropriate emergency escape
respirator in the immediate work area for employee use and
address emergency use respirators in the written respirator
program. The CSHO should also investigate, through routine
employee interviews, what actions the employer has taken to
re-evaluate employee exposure when employees have made
health complaints to determine if appropriate action has
been taken to address a respiratory hazard. Respirators required to be used in the workplace must be
NIOSH-approved and appropriate for the hazard. Part 84
respirators with an "N" designation should not be used in
work settings where oil aerosols are generated, while those
with an "R" designation should be used for only one shift
when oil is present. Respirators with a "P" designation may
be used for more than one work shift, even when oil is
present. Employers must follow respirator manufacturer's
recommendations. Inappropriate respirators [(d)(1)(i)] should be cited
when the CSHO documents an overexposure is possible, and a
suitable respirator is not being used for protection against
that exposure . Unapproved [(d)(1)(ii)] respirators can be
cited even where an overexposure has not been established.
Change schedules for all other gases and vapors must be
established and implemented by the employer. OSHA has stated
in the preamble to the final rule that the employer is not
required to research and analyze experimental breakthrough
data, but may obtain information from sources who have
expertise and knowledge that can help the employer to
develop reasonable change schedules. The new standard
prohibits the use of warning properties as the sole basis
for determining change schedules. However respirator users
should be trained to understand that abnormal odor or
irritation is evidence that respirator cartridges need to be
replaced. Where an effective change schedule is implemented,
air-purifying gas and vapor respirators may be used for
hazardous chemicals, including those with few or no warning
properties.
The change schedule for a mixture should be based on
reasonable assumptions that include a margin of safety
for the worker wearing the respirator. Where the
individual compounds in the mixture have similar
breakthrough times (i.e. within one order of magnitude),
service life of the cartridge should be established
assuming the mixture stream behaves as a pure system of
the most rapidly migrating component or compound with
the shortest breakthrough time (i.e., sum up the
concentration of the components). Where the individual
compounds in the mixture vary by 2 orders of magnitude
or greater, the service life may be based on the
contaminant with the shortest breakthrough time. OSHA
believes that an approach such as this reflects good
health and safety practice where neither objective or
experimental data is available for the mixture. OSHA believes that change schedule information will
become more available to the respirator user community
and will evolve in quality. The CSHO should review the
written respiratory protection program to ensure that it
describes the information and data relied upon and the
basis for the canister and cartridge change schedule and
the basis for reliance on the data as required by the
standard. Again, CSHOs should exercise judgement in
evaluating mathematical models, rules of thumb,
experimental data, use of analogous chemical structures,
and other reasoned approaches.
Where employers use a transient workforce, (e.g., temporary
or construction workers), the employer may accept the written
medical recommendation of the employee's ability to use a
respirator as determined by their previous employer's PLCHP only
if the work conditions and type and weight of the respirator
remains the same and appropriate for use at their new work site.
In this situation, the employer must obtain from the previous
employer a copy of the PLCHPs written recommendation. Section (e)(2)(ii) requires the employer to obtain the
information required in the questionnaire or provide the initial
examination prior to performing fit testing of employees and
prior to requiring the employee to wear the respirator in the
workplace. When using the questionnaire, the employer may not
change the wording of questions in Part A , if the form is being
used as the sole means to evaluate employees. The Physician or
other Licensed Health Care Professional (PLHCP) may add
questions to the questionnaire that could assist in determining
whether the employee can perform the work while wearing
respiratory protection. In order to maintain strict confidentiality of the
information obtained in the questionnaire, the employer's role
is limited to distributing the blank questionnaire to the
employee for him or her to fill out, or providing it to the
PLHCP, who will administer the questionnaire to the employee. If
the employer provides the questionnaire to the employee, an
addressed and postage-paid envelope should also be provided for
the employee to mail it to the PLHCP. The questionnaire and
findings may also be maintained by the employer's medical
office, if the health office is administratively separate from
the employer's central administration offices. If the employer does not have or chooses not to use an
in-house medical staff, arrangements must be made for a
physician or other licensed healthcare professional (PLHCP) to
perform the medical evaluations. The PLHCP may be a physician, a
registered nurse, a nurse practitioner, a physician assistant,
or other licensed health care professional acting within the
scope of his or her state license, registration, or
certification. The PLCHP must be legally permitted by his or her
professional license to conduct the type of medical evaluation
required by the respirator standard. Scope of practice for
non-physician PLCHPs will vary from state to state. All PLCHPs
who participate in any aspect of the medical evaluation must be
practicing within the scope of their license. For assistance in
determining which state licensing board or agency to contact to
determine a PLCHP's legally permitted scope of practice, the
CSHO can contact the Directorate of Technical Support in OSHA's
National Office. The employer must ensure that the questionnaire is
administered in such a manner that employees can understand the
content and the confidentiality of the record is maintained.
Where the employee cannot understand English, the employer must
have the questionnaire translated into the employee's language
either through a translator or a translated written copy. The
questionnaire has been translated into Spanish and is available
on OSHA's homepage (www.osha.gov) in the Respirator Q & A
Document. In cases where the employee cannot read, the employee
can request someone other than the employer to orally read them
the questionnaire or the PLHCP may obtain through an interview
or examination the same information requested on the medical
questionnaire. The CSHO should determine what supplemental information
was given to the PLHCP by the employer. This can be done
through interviewing the PLHCP or reviewing documentation
from the employer. If the employer is relying on a medical
evaluation for the employee from a previous employer (which
is allowed only when the employer uses a transient
workforce), the CSHO should determine that the work
conditions and respirator remained the same. If the CSHO suspects the employee(s) did not receive a
medical evaluation or have not answered the questionnaire
honestly (e.g., been "coached" by the employer on how to
respond to the mandatory questions from Appendix C), then
the CSHO should ask to interview the PLHCP. If this
interview still results in questions, the CSHO may wish to
obtain a Medical Access Order and review the actual medical
questionnaire and/or the physical examination records where
necessitated by this paragraph of the rule. The CSHO should also ensure that any required physical
examinations have in fact been conducted, as per (e)(3) and
(e)(7). A positive answer to any question in Part A, Section
2, Questions 1-8 (also questions 10-15 for SCBA and
full-face respirator users) requires a follow-up by the
PLCHP. The PLCHP may evaluate positive responses through
consultation with the employee to determine if the positive
response is not relevant to the employee's ability to wear a
respirator or if further physical examination is necessary
(e.g., brief smoking history in the past, as compared to
current heavy smoker status). If questions arise regarding the issue of qualifications
of the PLHCP, the CSHO should inquire with the state
licensing board or the applicable registration or
certification agencies in that state to ensure that the
PLCHP is acting within the scope of his or her practice. The fit test must be performed before the respirator is used
in the workplace. It must be repeated at least annually and
whenever a different respirator facepiece is used or a change in
the employee's physical condition could affect respirator fit.
If the respirator subsequently becomes unacceptable (i.e.,
causes irritation or pain to the employee) to the employee, the
employee must be given the opportunity to select a different
respirator facepiece and be retested. Qualitative Fit-Testing (QLFT) may be used to fit test
negative pressure air-purifying respirators, if they will only
be used in atmospheres less than ten times the PEL, since
existing evidence only validates the QLFT protocols listed in
Appendix A to identify respirators that achieve a fit factor of
100. For greater concentrations, Quantitative Fit-Testing (QNFT)
must be used. When quantitative fit-testing is used, all
full-facepiece respirators must meet or exceed a fit factor of
500, while quarter - and half-mask respirators must meet or
exceed 100. For all positive pressure, atmosphere-supplying
respirators, either qualitative or quantitative fit testing may
be used. While atmosphere-supplying respirators are fit-tested
in the negative pressure mode, these respirators are most often
used as positive pressure respirators in the workplace. Positive
pressure atmosphere-supplying respirators that pass the QLFT or
QNFT fit test may be used at the higher protection factors
assigned these respirators. See Table 1 for a summary. Acceptable Fit-Testing Methods
Employees should be observed to determine if the seal
check procedures are being performed each time the
respirator is donned. The procedure used must be one
listed in Appendix B-1 or recommended by the
manufacturer if the employer demonstrates it is as
effective as those listed in Appendix B-1. Alternative
seal checks must be based on scientific studies. [The
face fit is considered satisfactory if a slight positive
pressure can be built up inside the facepiece when the
exhalation valve or surface is covered, the user exhales
gently, and there is no evidence of outward leakage at
the seal. The negative check requires covering the inlet
opening or surface, inhaling gently, and having the
facepiece remain in a slightly collapsed condition with
no inward leakage of air detected.] Section (g)(2)(ii) requires that employers ensure
that employees leave the respirator-use area to correct
certain problems associated with respirator use,
including the detection of contaminant breakthrough, and
to replace the respirator or its filters or cartridges.
Employees should be interviewed [e.g., What do you do if
you notice a leak? ] to determine whether there are any
policies or actions which would prohibit or impede them
from leaving the area should they have significant
problems with their respirators or which impede the
replacing of filters or cartridges. Paragraph
(g)(2)(iii) is designed to prevent employees from
reentering a workplace after leaving because of a
significant respirator failure without first assuring
the proper functioning of the respirator. For work performed outside of visual contact, voice,
radio or signal line are permitted. CSHOs should
specifically review protocols for communication, rescue,
and notification for employees entering IDLH
atmospheres. Communication protocols must be established
that allow the standby person to monitor entrant status
and enable the standby(s) to alert entrants of the need
to evacuate the area. It is not sufficient to rely on
the employees in the IDLH area to call for help when
needed. Paragraph (g)(3) does not apply to IDLH atmospheres
in a permit-required confined space (PRCS) or to
environments in which there is an uncontrolled release
of a hazardous substance. IDLH atmospheres in a PRCS are
specifically addressed in the PRCS standard, 1910.146,
and its accompanying directive, CPL 2.100. Environments
in which there is an emergency release of a hazardous
substance are addressed in paragraph (q) of OSHA's
HAZWOPER standard, 1910.120 or 1926.65, and its
accompanying directive, CPL 2-2.59A. In facilities where
an uncontrolled release of a hazardous substance could
create an emergency IDLH atmosphere, employers must
follow the requirements of HAZWOPER paragraph (q). These
situations must be addressed in the employer's emergency
response plan and the response procedures must be
consistent with that standard. The provision is limited to workers performing an
interior attack on an interior structural fire. In Subpart L
( 1910.155), OSHA has defined "interior structural fire
fighting" to mean: "the physical activity of fire
suppression, rescue or both, inside of buildings or enclosed
structures which are beyond the incipient stage." This is
firefighting to control or extinguish a fire in an advanced
stage of burning, producing large amounts of smoke, heat and
toxic products of combustion. Firefighter exposure during
this activity is extremely hazardous. The atmosphere is
considered IDLH and the use of Self Contained Breathing
Apparatus is required. By contrast, incipient stage fire
fighting involves the control or extinguishment of a fire in
the initial or beginning stage, using portable fire
extinguishers or small hose lines without the need for
personal protective equipment. It is the incident
commander's responsibility, based on training and
experience, to judge whether a fire is an interior
structural fire, and how it will be attacked. OSHA has discussed this provision in a number of
documents.
The employer must ensure that respirators are inspected
before each use and during cleaning. The CSHO should observe
the condition of the respirators being used in the
workplace. One or more respirators should be checked before
employees enter, or as they leave the respirator area. A
minimally acceptable inspection procedure for ALL
respirators includes a check of respirator function,
tightness of connections and the condition of the various
parts, including but not limited to, the face piece, head
straps, valves, connecting tube, and cartridges, canisters,
or filters, and a check of the respirator's elastomer parts
for pliability and signs of deterioration. SCBA's also require an inspection of the air and oxygen
cylinders to assure that the cylinder pressure is maintained
at 90% of the manufacturer's recommended pressure level and
that the regulator and low pressure warning devices function
properly. To assure that both the regulator and low pressure
warning devices function properly the warning device must be
activated and heard by the person performing the inspection.
The CSHO should interview the individual who is inspecting
SCBA's to determine if these regulator and low pressure
warning devices are being activated according to the
respirator manufacturer's instructions. The CSHO should also observe how respirators are stored
in the workplace. Respirators must be properly stored to
protect them against physical damage, contamination,
excessive moisture, extreme temperatures, sunlight, and
damaging chemicals. Emergency use respirators must be stored
in compartments OR in covers, both of which must be clearly
marked as containing the emergency respirators. For air compressors that are not oil lubricated, a
CO alarm is not required. However, the employer is required
to ensure that carbon monoxide levels in the breathing air
do not exceed 10 ppm. Some practical methods for ensuring
that the carbon monoxide level does not exceed 10 ppm
include; placing the air intake for the compressor in an
area that the employer knows is free from contaminants;
frequent or continuous monitoring of the breathing air
supply; the use of carbon monoxide filters; or the use of a
high temperature alarm or shut off devices. If the employer is using an oil-lubricated air
compressor, it must have either a carbon monoxide alarm,
high temperature alarm, or both. If only a high temperature
alarm is used, then the breathing air must be tested for the
presence of carbon monoxide at intervals sufficient to
ensure that carbon monoxide levels do not exceed 10 ppm. The
alarm must be able to alert the users or another employee
who knows to alert any respirator users. If cylinders are used they must be marked with a NIOSH
approval label. Cylinders of purchased breathing air must
have a certificate of analysis from the supplier that the
breathing air meets the required Grade D air and moisture
content. If compressed or liquid oxygen is used, it must meet the
specifications for breathing oxygen outlined by the United
States Pharmacopoeia (USP). Compressed oxygen must not be
used for any respirators that previously used compressed
air. All breathing air couplings must be incompatible with
those of non-respirable air or other gases used at the site
to prevent inadvertent servicing of air line respirators
with non-respirable gases or oxygen. Employees should be interviewed to determine if they have
received the required training and the extent of that
training. If the CSHO detects a trend in employee responses
that indicate training is not being conducted, or is
conducted in a cursory manner, a closer review of the
training program is necessary. Employees who voluntarily wear respirators must, at
least, be given the information in Appendix D. Fit test records must be kept until the next fit test is
administered. Each fit test record must contain the employee
identification, type of fit test, date last tested, the
results of the test, and the make, model and size of the
respirator tested. The CSHO should review these records to
verify that fit-testing is being done annually and confirm
that the fit-tested respirators are the same models and
sizes as those observed in the workplace. The CSHO should also check on the availability of the
written program. Lack of a fit test record or lack of information on a fit
test record would be cited under (m)(2). If an employee is
wearing a respirator different from that found in his fit
test records then (f)(2) should be cited. Improper fit
testing procedures would similarly be cited under the
appropriate subparagraph in (f).
Instructions for the use of respiratory protection by
CSHO's are contained in OSHA Instruction CPL 2-2.54. The
CSHO should closely review and examine all the data
available on site concerning the exposures or potential
exposures in this particular location. If the employer
cannot supply adequate data to support the selection of the
types of respirators that are in use, the CSHO must not
enter the areas where respirators are in use. If the hazard
determination performed by the employer has been completed
in accordance with the standard, the CSHO must don the
appropriate respirator required in that work-site prior to
the walkaround in areas where respirators are required. CHANGE SCHEDULES GUIDE - A LISTING OF METHODS A brief description of some currently available approaches or methods
for respirator cartridge change schedules is presented below. The CSHO
should assess the "Good Faith" efforts of the employer on a case by case
basis and contact appropriate regional OR National office staff for
guidance, as necessary. This is not intended to be an exhaustive list,
but a summary of some reasonable methods that an employer may take in
creating a change schedule. No matter which method is used, the employer
must maintain any data used in making their decision as part of their
program. Manufacturers Objective Data: Respirator cartridge
model-specific objective data that is available from the manufacturer or
through a distributor may be used to establish change schedules.
Objective data may be presented in tabular or graphical format or simply
provided verbally over a manufacturer's telephone help line. Some
manufacturers have developed elaborate computer programs available on
the Internet that provide the necessary objective data to the user. Experimental Methods: Experimental breakthrough-time data from
a laboratory based on worst case testing of simulated workplace
conditions. This method can provide fairly accurate service life data
compared to other available methods. Mathematical Predictive Modeling: One tool that has
demonstrated value is the use of mathematical modeling based on
predictive equations. These models are typically complex and require
considerable expertise to apply. They also require some proprietary
information from the respirator manufacturer. OSHA fully supports the
further development and validation of these models. The agency believes
that respirator manufacturers may be in the best position to apply them
to their products. Analogous Chemical Structures: Employer would rely on service
life values from other chemicals having analogous chemical structure to
the contaminant under evaluation for breakthrough. Or in some cases a
chemical with known migration may reasonably be anticipated to act as a
surrogate for a similar chemical that would have less rapid migration
(e.g., an employer could assume that a heavier, less volatile compound
than another in the same chemical series that had been tested for
breakthrough would breakthrough no faster than the latter compound, such
as benzene versus toluene.) The use of this method requires a
substantial amount of judgement and assumption of similar chemical
properties. The use of analogous chemical structures should be
infallible as long as objective data or information for lower molecular
weight compounds is used to predict the breakthrough times for higher
molecular weight analogues containing only additional methyl or phenyl
groups. Data from higher molecular weight groups should not be used to
predict the behavior of analogous substances with lower molecular
weight. This approach relies heavily on experimental data and expert
analysis. This method may be less accurate than others and should be
used only when better information is not available. Workplace Simulations: Unvalidated methods exist or are under
development where the respirator cartridge is tested in the workplace in
"real time" and under actual conditions of use. Simple designs have been
informally described to the agency. Workplace air during representative
conditions is drawn over the cartridge at a rate approximating normal
breathing at a higher work rate. An air sampling/analytic device would
be placed on the other side of the filter to measure the time of
breakthrough. Employers could incorporate this type of testing into
their air monitoring program using sampling strategies established in
their workplace. In theory, these approaches should be an accurate
method for determining change schedules and could accommodate
fluctuating conditions of humidity, concentration, etc., to allow less
conservative schedules that utilize a larger fraction of the true
service life. Rules of Thumb: Generalized rules or guidance can be generated
from experimental work. Presented below is a rule of thumb for
estimating organic vapor service life found in Chapter 36 of the
American Industrial Hygiene Association publication "The Occupational Environment Evaluation and Control". *If a chemical's boiling point is >70 C and the concentration is
less than 200 ppm you can expect a service life of 8 hours at a
normal work rate. * Service life is inversely proportional to work rate. * Reducing concentration by a factor of ten will increase service
life by a factor of five. * Humidity above 85% will reduce service life by 50%. If you need help developing a respiratory protection program, call EHSO at 770-645-0788! of objective data - this is the use of data obtained
from industry studies, trade associations, or from tests
conducted by chemical manufacturers which demonstrate that
air contaminants cannot be released in the workplace in
airborne concentrations that are IDLH. The objective data
shall represent the highest contaminant exposures likely to
occur under reasonably foreseeable conditions of processing,
use, or handling. The employer must document the use of
objective data as part of their written program.
of mathematical approaches - the preamble to
the final rule (p. 1199) states that employers can use data
on the physical and chemical properties of air contaminants,
combined with information on room dimensions, air exchange
rates, contaminant release rates, and other pertinent data
including exposure patterns and work practices to estimate
the maximum exposure that could be anticipated in the
workplace.
a continuing practice, employers are required to
identify hazards as a result of changes in the workplace
such as a change in equipment, process, products, or control
measures that could result in new exposures. Appropriate
respirators should be provided as necessary.
1910.1045(h)(2)(ii)
life or end of shift
(whichever occurs first)
1910.1028(g)(2)(ii)
life or beginning of
shift (whichever occurs first)
1910.1051
(h)(2)(ii)
1, 2 or 4 hours dependent on
concentration according to Table 1 and at beginning
of each shift
1910.1048
(g)(2)(ii) -
cartridges every three hours or
end of shift (whichever is sooner); for canisters,
every 2 or 4 hours according to the schedule in
(g)(3)(iv)
chloride
1910.1017(g)(3)(ii)
life or end of shift
in which they are first used (whichever occurs
first)
chloride -
1910.1052 (g)(2)(ii) may only be used for
emergency escape and must be replaced after use.
1
QLFT
QNFT
Negative Pressure, APR (<100 fit factor)
Negative Pressure, APR (<100 fit factor)
used in atmospheres up to 10 times the PEL
Negative Pressure, APR (>100 fit factor)
Respirators (SAR), or SCBA used in
Negative Pressure (Demand Mode) (>100 fit factor)
Respirators (SAR), or SCBA used in
Positive Pressure (Pressure Demand Mode)
- Structural Fire Fighting, Positive Pressure
- IDLH, Positive Pressure
Respirators
Not Required
Respirators (e.g., hoods, helmets)
must always be at least two firefighters
stationed outside during interior structural
firefighting, and they must be trained, equipped and
prepared to enter if necessary to rescue the
firefighters inside. However, the incident commander
has the responsibility and flexibility to determine
when more than two outside firefighters are
necessary given the circumstances of the fire. The
two-in/two-out rule does not require an arithmetic
progression for every firefighter inside, i.e. the
rule should not be interpreted as 4-in-4-out,
8-in-8-out, etc.
is important that the CSHO recognize that
life-saving activities in interior structural fire
fighting are not precluded by the standard. There is
an explicit exemption in the standard that if life
is in jeopardy, firefighters have the discretion to
perform the rescue, and the "two-in/two-out"
requirement is waived. There is no violation of the
standard under such life-saving rescue
circumstances.
two-in/two-out provision is not intended as
a staffing requirement. It does not require fire
departments to hire additional firefighters; it does
not require four-person fire companies; it does not
require four persons on a fire truck. Most fire
departments have more than four firefighters and can
assemble the numbers required on the scene by
waiting for others to arrive. During this time the
fire may be attacked only from the outside,
sizing-up operations may occur, and emergency rescue
necessary to save lives may take place as discussed
above. The "two-in/two-out" rule is a worker safety
practice requirement, not a staffing requirement.
standard allows one of the standby
firefighters to have other duties such as serving as
the incident commander, safety officer, or operator
of fire apparatus. However, one of the outside
firefighters must actively monitor the status of the
inside firefighters and may not be assigned
additional duties. The second outside firefighter
may be involved in a wide variety of activities.
Both of the outside personnel must be able to
provide support and assistance to the two interior
firefighters; any assignment of additional duties
for one of the outside firefighters must be weighed
against the potential for interference with this
requirement. Proper assignment of firefighting
activities at an interior structural fire must be
determined on a case-by-case basis and is dependent
on the existing firefighting situation. Compliance
will always depend on consideration of all the
worksite variables and conditions, and the judgement
of the incident commander is critical in meeting
this performance standard.
two firefighters (buddies) entering an IDLH
atmosphere to perform interior structural
firefighting must maintain visual or voice
communication at all times. Electronic methods of
communication such as the use of radios shall not be
substituted for direct visual contact between the
team members in the danger area. However, reliable
electronic communication devices are not prohibited
and certainly have value in augmenting communication
and may be used to communicate between inside team
members and outside standby personnel.
further explanation refer to the preamble of
the Respiratory Protection standard (vol. 63, No. 5,
1245-1248) and the Respirator Question and Answer
document (August 3, 1998). Both documents can be
found at OSHA's Homepage -
www.osha.gov.
Note: This first rule of thumb needs further review.