Fire brigade duties, respirators, and rescue

APR 9 1990

MEMORANDUM FOR: Michael G Connors

Regional Administrator

THROUGH: Leo Carey, Director Office of Field Programs

FROM: Patricia K. Clark Director Designate Directorate of Compliance Programs

Subject: Interpretation of OSHA's Fire Brigade Standard

This is in response to your memorandum of December 26, 1989, in which you requested, on behalf of Mr. William Savka of the American Fire Protection Consultants, Inc., interpretations of several sections of OSHA's Fire Brigade Standard (29 CFR 1910.156) concerning the use of self-contained breathing apparatus (SCBA) as they relate to the National Fire Protection Association (NFPA) 1500 standard (Fire Department Occupational Safety and Health Program). His questions specifically concern the activities of an incipient stage fire brigade. OSHA defines an incipient stage fire, as found in 29 CFR 1910.155(c)(26), as a "fire which is in the initial or beginning stage and which can be controlled or extinguished by portable fire extinguishers, Class II standpipe or small hose systems without the need for protective clothing or breathing apparatus."

On the basis of this definition, in answer to Mr. Savka's first question concerning search and rescue, incipient stage fire brigade members are not to enter environments such as smoke-filled and toxic-filled environments where protective clothing or breathing apparatus are required. The search and rescue operations involving the fire department and other safety personnel are to be performed by personnel trained in emergency operations, such as members of an interior structural fire brigade, or an equivalent unit. Section 3-3.1 of National Fire Protection Association (NFPA) 1500 requires that brigade members be "provided with training and education appropriate for the duties and responsibilities before being permitted to be engaged in emergency operations." Mr. Savka further questions the propriety of protective clothing for brigade members in his second question concerning infringement on structural brigade guidelines Incipient stage members would be infringing on the guidelines for an interior structural fire brigade by engaging in search and rescue activities similar to those addressed above, even if they were to wear protective clothing.

Mr. Savka's third question concerning the wearing of SCBA by incipient stage fire brigade members has been partially answered in paragraph 2 above. It would not be appropriate for members of an incipient fire brigade to lead fire department personnel trained in emergency operations into smoke or toxic filled areas.

Mr. Savka's fourth question concerns the provision of protective equipment for post-fire operations. Though not an OSHA requirement, the employer may furnish to his incipient fire brigade members, SCBA's and other protective equipment for their use during cleanup and overhaul operations after the fire is out. However, the employer shall comply with the Protective Clothing and the Respiratory Protection Devices sections of 29 CFR 1910.156(e) and (f), respectively.

In response to question #5, it has been established that incipient stage fire brigades may not conduct search and rescue work. Where structural fire brigades are engaged in search and rescue work, and where a need arises for the use of life lines, the employer should comply with NFPA 1500, Section 5-5 (Life Safety Ropes, Harnesses, and Hardware).

Questions #6 and #7 concern training of fire brigade members, and participation in confined space rescue. SCBA-trained members can be trained for structural fire brigade work and the rest of the team trained as incipient stage members. Additionally, an incipient stage brigade member, fully trained on the proper use of a SCBA and other confined space entry and rescue procedures, may participate in confined space rescues. The need for protective clothing must be based on specific factors associated with the rescue itself.

Mr. Savka asks in his final question whether procedures in the earlier questions should be included in the written procedures plan. OSHA requires under 1910.156(b) that the employer prepare and maintain a written policy that addresses many of the issues listed above. This organizational statement or policy must address the existence of the brigade, its structure, its training requirements, and its work functions.

Mr. Savka also requests an OSHA opinion on the toxicity of small fires. Where small fires have the capacity to emit toxic fumes, the employer may go beyond OSHA requirements and provide his incipient fire brigade members training and protective equipment equal to or greater than that which is required by the members of a structural fire brigade.

Finally, Mr. Savka requests a copy of our new confined space entry requirements. The Agency has not finalized the adoption of its proposed confined space standard. We anticipate the adoption of this standard sometime around February of 1991.

If you have additional questions concerning this matter, please call James C. Dillard of my staff, at FTS 523-8041.

[Requester letter reproduced on OSHA page; omitted here.]