According to the Occupational Safety and Health Administration (OSHA), regulations mandate the minimum number of workers required for operations in environments that are immediately dangerous to life and health (IDLH). These minimum personnel requirements numbers should be reflected in fire emergency planning and training.
Numerous standards apply, and should be reviewed for employees who work in IDLH conditions. OSHA refers to the following standards:
1. Hazardous Waste Operations and Emergency Response (HAZWOPER), 29 CFR 1910.120
HAZWOPER requires that operations in hazardous areas shall be performed using the buddy system in groups of two or more. (1910.120(q)(3)(v)). In addition, paragraph 1910.120(q)(3)(vi) states that "back up personnel (at least two or more) shall stand by with equipment ready to provide assistance or rescue." Thus, there must be at least four individuals at the site. One of the two individuals outside the hazard area can be assigned to another task, provided that the second assignment does not interfere with the performance of the standby role.
HAZWOPER standard defines the buddy system and IDLH as follows:
Buddy system means a system of organizing employees into work groups in such a manner that each employee of the work group is designated to be observed by at least one other employee in the work group. The purpose of the buddy system is to provide rapid assistance to employees in the event of an emergency.
IDLH or Immediately dangerous to life or health means an atmospheric concentration of any toxic, corrosive or asphyxiant substance that poses an immediate threat to life or would cause irreversible or delayed adverse health effects or would interfere with an individual's ability to escape from a dangerous atmosphere.
The Fire Brigade regulation covers emergency operations involving interior structural fire fighting. According to OSHA, it is universally recognized that conditions present during an advanced interior structural fire create an IDLH. Because fire brigades vary in type, function and size, the OSHA requirements are performance oriented to provide enough flexibility for the employer to organize a fire brigade which best reflects the needs of the workplace. The Fire Brigade regulation does not directly address the minimum number of fire fighters required when engaged in operations presenting an IDLH atmosphere. However, the Respiratory Protection standard states that failure to have four employees at an interior structural fire, would be a violation of 1910.134(g)(4).
3. NFPA Standards: 1500-1992, Fire Department Occupational Safety and Health Program and 600-1992, Standard on Industrial Fire Brigades
Amendment 6-4.1.1 of the NFPA 1500-1992 states: "At least four members shall be assembled before initiating interior fire fighting operations at a working structural fire."
A working structural fire is defined as follows: Any fire that requires the use of a 1 and 1/2 inch or larger fire attack hose line and that also requires tee use of self-contained breathing apparatus for members entering the hazardous area."
OSHA states that the terms interior structural fire fighting and working structural fire are similar in nature. Consequently, four persons (two inside and two outside), each with protective clothing and respiratory protection are essential for the safety of those performing this work inside a structure.
Chapter 5-3.5 of the NFPA 600-1992, specifies requirements for the number of members to be involved at the scene. Requirements in chapter 5-3.5 are similar to those in NFPA 1500-1992, Sections 6-4.3 and 6-4.4, and states a minimum of four members on the scene before beginning to fight interior structural fires: two inside as a team, operating in the hazardous area; two outside the hazardous area, where one is standing by and another may be performing another function, such as managing the incident, as long as its performance does not interfere with the second outside person's ability to assist in the event of an emergency.
NOTE: This standard does not address the number of persons necessary to staff a fire apparatus leaving a station before on-scene evaluation has occurred. That is a matter to be determined by each local fire fighting unit.
4. Section 5(a)(1) of the Occupational Safety and Health Act of 1970 which is intended to apply to operations where IDLH conditions exist or potentially exist in the following situations:
a. Emergency response to uncontrolled releases of a hazardous substance or substances;
b. Emergency operations covering interior structural fire fighting.
Any citation or Section 5(a)(1) must meet the requirements outlined in the Field Inspection Reference Manual (FIRM), Chapter III, and may be issued where there is a hazard which cannot be abated by compliance with a specific OSHA standard.
The NFPA national consensus standards serves as guidance as to what is generally recognized as hazardous in the industry. Therefore, a citation for violation of the General Duty Clause shall be issued when it is documented that only one person conducted interior structural fire fighting operations or when less than two persons were standing by when interior structural fire fighting operations were being conducted. A Section 5(a)(1) citation may not be issued for incipient stage interior fires or for exterior fire fighting operations conducted during advanced interior structural fires.
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