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As a firefighter in South Carolina, what are the OSHA requirements on “Two-in and Two-out”?

The Federal Office of Occupational Safety and Health (OSHA) adopted in 1998 a revised safety standard on respirator protection, 29 CFR 1910.134 (http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=12716). This standard, commonly referred to as the “two-in and two-out” regulation, included provisions concerning procedures for interior structural firefighting. “Two-in and two-out” is also the law in South Carolina.

The South Carolina Department of Labor, Licensing and Regulation, Office of Occupational Safety and Health (S.C. OSHA) operates an approved State Plan which must be "as effective as" the Federal OSHA program, including enforcement of standards. However, Federal OSHA does not cover public sector employees, such as firefighters, but state plans must include both private and public employees.

S.C. OSHA recognized 1) the special needs facing the public sector firefighters in urban and rural settings, and 2) the effectiveness of the South Carolina Fire Academy training program for firefighters and made a decision to adopt a limited amendment to section 1910.134(g)(4)(ii) of the respirator protection standard. The amendment was promulgated in 1998, approved by the General Assembly on May 19, 1999, and published in the State Register on June 25, 1999. (Document No. 2343 pdf )

S.C. OSHA standards require that whenever firefighters enter a burning structure that is immediately dangerous to life and health (IDLH), they must do so in teams of at least two that operate in direct visual or voice contact. Additionally, there must be at least two fully equipped and trained firefighters who remain outside the structure, who are capable of rescuing the firefighters inside should they become disoriented, trapped or injured. This is the “two-in and two-out” standard.

There is an explicit exemption in the standard, adopted by both federal OSHA and S.C. OSHA, that if human life is in jeopardy, firefighters can perform a rescue without following the "two-in and two-out" requirement.

In recognition that many fire departments have chosen to emphasize rapid response and in recognition that firefighters’ safety is improved by preventing the full involvement of a structure by fire, South Carolina also allows a limited short-time deviation when the following five conditions are met:

1. the incident commander has completed the Incident Command System course or its equivalent as certified by the South Carolina Fire Academy;

2. the employees who enter the IDLH atmosphere have completed the Basic Firefighter course or its equivalent as certified by the South Carolina Fire Academy;

3. the incident commander has determined that the standard staffing pattern is not feasible;

4. the incident commander has determined that entry can be made safely with the personnel on-site; and

5. arrival of additional employees to complete the standard staffing pattern is imminent.

S.C. OSHA has determined that the “two-in and two-out” rule is in effect for every fire department at any fire which is beyond the initial or beginning stage and which cannot be controlled or extinguished immediately. Any fire beyond this stage is considered by S.C. OSHA to be “immediately dangerous to life and health” (IDLH).

The “two-in and two-out” rule, like all OSHA standards, states a minimum requirement. Employers should continuously strive to exceed the OSHA standards.

For more information about the S.C. OSHA program.

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