Since the publishing of the Two-In/Two-Out position paper there have been a few comments in various online discussions that presume to incorrectly believe what the paper calls for. Here are replies to some of those comments.
“- the [paper] consistently appears to advocate for the elimination/obsolescence of “two in, two out.” 1910.134(g)(4)(i) states, “At least two employees enter the IDLH atmosphere and remain in visual or voice contact with one another at all times.” This language prohibits interior firefighters from operating alone.”
The position paper and its authors do not advocate for firefighters to operate alone in regards to the context of the OSHA standard. The assumption that it does is illogical. The paper contends that having three or four firefighters inside instead of two is better as supported by the referenced firefighter mayday data and victim rescue data. The authors also do not advocate for freelancing on the fireground and believe that reasoning assumes firefighters and fire departments can be easily swayed to lessen safety by an online article, thus highlighting a greater problem than wanting to increase the number of firefighters initially working inside a structure.
“If you start chipping away at things like this, in our current staffing climate, departments will soon be back to single man engines just to keep a house open and look good “for the public. Keep your safeguards in place and use your manpower however you need to use your manpower.”
This is a lazy comment. Staffing across the country has been an issue for as long as Two-In/Two-Out has existed, if not longer. Staffing is a budget issue first and and an operational issue second. Wanting to keep the standard just so your department won’t have the outside firefighters cut comes from some irrational fear. The position paper contends that putting the outside firefighters to work inside reduces time-oriented tasks such as stretching the initial hoseline, starting the fire attack, starting the search, removing victims and having a quicker reaction time to assist a downed firefighter. Keeping the standard to avoid being a driver-only department is a weak support of personnel.
“I prefer to work with some one and not alone. More eyes and ears and better chance I get to go home to see my kids.”
See the earlier response mentioning freelancing. Two-In/Two-Out is not a hand-holding operation for the interior firefighters. You should not be crawling while holding onto the other firefighter’s boot. More firefighters inside positively effects fire attack, search and victim removal.
“It’s one of those things where it’s a waste of manpower until it isn’t. Then you will be begging And wishing you had people outside JUST FOR YOU. It’s a double edged sword.”
The mayday data and line-of-duty-death data in the position paper refutes this ‘what if’ belief.
“– going back on this one will lead to a force reduction agencies don’t see coming.”
The position paper contends that increasing the number of firefighters working inside a structure has a positive effect of time-critical tasks. See again the earlier response that keeping two firefighters outside as a protection for your department’s staffing is a poor defense of your personnel.
There are several comments online similar to these. A general idea among them is a fear that if Two-In/Two-Out is removed then staffing will be reduced. There are existing NFPA standards that address minimum staffing. Another idea is that removing Two-In/Two-Out will lead to firefighters everywhere suddenly losing their minds and operating inside exclusively alone, freelancing, for considerable amounts of time. This is simply ludicrous.
After the position paper was released the authors were invited to participate in discussions about removing the standard. You can listen to these discussions below.
FireNuggets Podcast – 048 – Removing Two-In/Two-Out
Code 3 Podcast – Two-In/Two-Out: An Idea Whose Time Has Passed with Sean Duffy
To make your voice heard, scan the QR code below, or click on the link here, and submit a public comment to OSHA on the proposed changes to two in/two out and the Emergency Response Standard (The majority of the Two-In/Two-Out language is on page 64 of the proposed standard). Public comments are only open until July 21, 2024. If we don’t make our voices heard, we could be stuck with a policy that we know doesn’t work, and data demonstrates that will cause more deaths. We need your help, and so do the civilians we’re sworn to protect.


QR codes to public comments for OSHA’s proposed Emergency Response Standard (left), and to the current proposed version of the Emergency Response Standard (right) (The majority of the Two-In/Two-Out language is on page 64 of the proposed standard).