Guest Article: ROE vs OSHA

Lt. Michael P. Murphy, SEAL Team 10, Afghnistan

Lt. Michael P. Murphy, SEAL Team 10, Afghnistan

The following is written by Dave LeBlanc

I just recently finished reading “Lone Survivor” by Marcus Luttrell. In this book Luttrell paints a horrific picture of death and survival for a United States Navy SEAL recon team. Luttrell, the lone survivor, discusses tough decisions that were made and their consequences.

The United States Military is bound in its operations by Rules of Engagement (ROE). ROE stipulates when and how a unit will respond to enemy threats. In Afghanistan, US forces operate under a “don’t fire until fired upon” ROE. In other words, the enemy gets the first shot.

Luttrell’s squad, bound by these rules, allowed some native “goatherds” to leave the SEAL’s position and most certainly report the patrol location to the Taliban. This was proven several hours later when the Taliban attacked the SEALs in force.

Luttrell claims in his book, that these rules are inconsistent with winning; Luttrell’s point being that soldiers are trained to fight and win. Furthermore, they are educated and have the skills and knowledge to accomplish their mission without overly restrictive rules that give the advantage to the enemy. That’s right, the ROE gives the advantage to the enemy; they get to shoot first.

As I was reading this book and thinking about the arguments put forth about the Military’s ROE, I began comparing it mentally to the Fire Service’s own ROE. The rule I am referring to is 2 in and 2 out. I began thinking that 2 in / 2 out is another ROE that doesn’t give us the flexibility to operate as we may need to. It restricts and binds us to an unrealistic ideal.

2 in and 2 out gives us a false security that 2 exterior firefighters will be able to save 2 interior firefighters if things go wrong. It also forces us to split a minimal amount of manpower into a less than acceptable level. Often it forces us to allow our enemy to grow stronger.

Wouldn’t it make more sense, if after a good size up is done, that four-man engine companies make a swift and direct attack at the seat of the fire? Moreover, those four fully equipped and trained firefighters rapidly advance an attack line and knock down the fire before it spreads?

2 in / 2 out forces us to compromise our attack force. Rather than using all assets available, we must divide our personnel to maintain our “safety” blanket. We are forced to debate what constitutes “known life hazard”. ”. 2 in 2 out is a crutch that supports the Political decisions of lower staffing levels and fewer companies. We all have read about the Phoenix studies conducted after the tragic death of Bret Tarver. What did those studies prove? It proved that upwards of 12 firefighters were needed to rescue one firefighter. Yet 2 in / 2 out say we can save 2 with 2.Many feel that 2 in / 2 out is a standard we will be judged against when all goes wrong and we fail. A fear many soldiers have, being judged by the rest of the world, that wasn’t present when the aforementioned decision needed to be made.

So what is the answer? Obviously, I am not recommending that we throw caution to the wind and rush blindly into every structure. The answer really is quite simple; although the process of attaining it may not be. TRAINING- that one word solves a multitude of problems. Train our people to make effective decisions. Train our people to make accurate size ups. Train our people to get in and fight. Train our people to know when to get out. Train our people to be accountable. Train, Train, Train. The more sweat on the training ground, the less blood on the fireground.

Training makes more sense to me than one size fits all rules that often cannot be effectively applied to our circumstances. Much like the soldiers being constrained by a ROE thought up by civilians not trained in their craft, we operate in an environment that does not always fits into the little OSHA box of 2 in / 2 out.

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  • Dave,

    I’m going to start by agreeing with you that aggressive interior firefighting is a critical function that too many departments do not train for often enough.

    Here is one of the problems with your argument, though. Two-In/Two-Out wasn’t written specifically with the fire ground in mind. 1910.134, OSHA’s Respiratory Protection Standard, is about wearing an SCBA into an IDLH environment. Interior Operations at a Structure Fire certainly fit that criteria, but they are not what the standard was written for. It was written with HazMat Incidents, and Confined Space in mind.

    The real question comes down to resources? Do you have the resources on scene, or en-route, in case things go to hell? If you have the resources, and the tactical situation that presents itself is winnable then you make the aggressive attack. If you are missing either aspect, you wait until one of those conditions are met.

    Just my two cents, Brother. Great points. Be safe.

  • Dave LeBlanc says:


    I relaize 2 in 2out was not written with the fireground in mind. That is one of the issues I have with it. Just like the ROE our military uses are not written with winning in mind. They handicap our armed forces by making them wait to be attacked until they can fight back.

    It comes down to resources and training and experience, but while you wait for the “numbers” how much more control is our enemy getting over the building? How much harder are the initial 2 firefighters going to have to work while there “2 out” stay out?

  • Jeremy Black says:

    Hi Dave, another great post.

    Let me add that training must continue to EVOLVE to reflect that we are doing more with less. Every department that has suffered a funding/staffing cutback needs to take a new look at the way they attack. The taxpayers have spoken, they want to spend less, so we need to revisit our strategies to accomplish what we need to without having all the resources we used to have.

    You are 100% correct- Training is key, but now it is also dynamic. The old rules just don’t apply anymore with less resources to take into battle.

  • Ron Ayotte says:

    Dave.. your assessment of the Fire Service’s ROE is balls on accurate. The military does threat assessments and reconnaissance before undertaking a mission. Our version is preplanning and site visits to learn what is in out response districts.

    To paraphrase Lt. Ray McCormack of the FDNY, the way to make the fireground safer is to use what we learned in threat assessment and recon and attack the fire with full force and put the GPM on the BTUs before the defacation hits the oscillation.

    There are many fire officers who are afraid to call for help because they are afraid they will be perceived as unable to handle a small room and contents fire without help.

    There are fire officers who refuse to call for help because they feel like they and their crews are superjakes and feel that they can do it all by themselves.

    As is is with the military, fire service leaders are hampered by the ROE put forth by the politicians in the form of budgetary constraints… closing stations, laying off personnel and doing more with less, despite the fact that when the economy tanks, the runs do not decrease.

  • Jeff Schwering says:

    Dave,In our job, there is no such thing as routine. Many of us are pulling up to everything with 3 members on a rig. Calling for help is something that has to be done, simply, for our safety and the civilians we protect. The last thing any of us wants is to be tied by OSHA and lose someone we could have gotten to, with a quick attack. Training is our friend and enemy at times. We all must be on the same page, to be effective.

  • Dave LeBlanc says:

    Jeremy, I agree with what you are saying. Training has to be dynamic. To quote Ray McCormack “The three r’s. Relevant, Realistic and Repetitive”. The Relevant covers the part to which you speak, dynamic and reflective of our ever changing world.

    However the reality is, as Tom Brennan once said, “there are very few new things in the Fire Service.” That isn’t an old school, dinosaur thought process. It is an acceptance that no matter how much time goes by, the basics are still required and we must master the basic in order to complete our mission.

    Along with our commitment to the three r of training, has to be the freedom to operate as our training dictates. To me that is where the conflict with 2 in 2 occurs. Especially because the standard wasn’t specifically written for fireground operations.

  • Tim Linke says:

    I agree…very good correlation!

  • Chief Reason says:


    Another thoughtful and insightful topic for discussion.

    Rules of Engagement. Honestly; I don’t think that the rules have changed so much. Nor do I believe that the objectives have changed all that much. That would depend on the resources responding to the initial call. If we could stand outside of ourselves and look at what we do, what has really changed? I think that our killer instinct and take no prisoners attitude has changed where property alone is at stake.

    It’s as if we believe that, if we drive fast enough over a land mine, there is a delay in the explosion and we will not blow up. Maybe in the movies, but in real life; once it trips, that’s it.

    I think a similar analogy can be applied to our tactics, whereby we believe that we are so good and so fast that we can get into a building before it flashes, knock down the fire and get out before the trusses or floor collapses. In some cases we have and in others, we lost. This is where I think our assessment of the value of the building vs. value of our resources (firefighters) has started to change.

    Our mission to save life is unchanged. The Rules of Engagement here are still what they are and that is; if it is highly probable that someone is in the structure, a search and rescue will be done after due consideration of the conditions at the time. The amount of on scene resources including manpower will not change the ROE here. The 2 in/2 out is exceptioned where there is an imminent threat to life. And I agree to a degree with the lunacy as the rule applies to the fire service.

    Should we have a one for one rule instead? If we have 6 people inside, should we have a RIT of 6 people outside? Do we really understand the OSHA standard? The whole concept of the rule was so that, where someone entered a confined space or an IDLH area, there would be SOMEONE there to get help if needed. Too many people were dying because they would enter a space, get into trouble and would only be discovered-in many cases, dead-after the boss thought they were doggin’ it. And if anyone remembers the supermarket fire in Phoenix (, I believe that Lasky stated that it would have taken approximately 13 firefighters to rescue ONE.

    Among firefighters of Christmas Past, there was this crazy notion that if we got into trouble, we would get ourselves out of trouble. Now; this is where you might think the ROE has changed. In the old days, we would commit EVERYTHING and EVERYONE to the battle. No one would be standing next to the IC as RIT awaiting instructions. Everyone would be involved in the fight, so yes; this is where it has changed from a tactical standpoint.

    I have to wonder if we have taken the time to “revise” our SOPs with regards to our pre-planning of buildings in our response areas to reflect the Rules of Engagement? In other words; we go to a commercial building and do our inspection and update their file if something has changed. Well, nothing on their end has changed, but it certainly has on our end. We no longer carry 4 man truck crews. We now carry 3 men per unit. A couple of stations have been closed, so that quick 2nd alarm response just got longer. So, the worst case “what if” just got cooked because of our available resources.

    Our Rules of Engagement didn’t change. We see the enemy-fire and we are going to engage and at some point defeat it. Where we have had a whole division in the past, we may now have only a battalion now or in some cases a platoon.

    You draw an interesting correlation between military and fire ground Rules of Engagement.

  • Dave LeBlanc says:

    Art, our rules dictate when we will engage. And those rules bind the hands of the Officer in many instances. Instances where a rapid fire attck with 4 may be the best course of action. The delay also means that fire has more time to burn, to reach flashover, for those trusses to deteriorate.

    The Military’s rules dictate when they can shoot back. They say you have been fired upon. Now I have never been shot at, and never served in the Military, but I am thinking the last thing I want the bad guy to do is shoot first. So why give him the advantage?

    Why give the building the advantage?

    I understand less manpower. But that shouldn’t be the excuse for everything. Better training, better size ups, and the freedom to react to the incident before as you see fit. 2 in / 2 out may not bind us as much as the Military. But I do see a similarity between the two sets of rules. I an understand the frustration of having decisions made for you – or perhaps taken from you.

  • ChiefReason says:

    So, then; you believe that your “local” situation is affecting your Rules of Engagement or at the very least, are handcuffing you?
    Because I was basically agreeing with you, but wondering aloud why we wouldn’t go back to SOPs and inspections of buildings and revise the documents to reflect the change in response, in terms of manpower, equipment and the urgency of additional resources by whatever means (second/third alarm or mutual aid).
    Again; I believe that 2 in/2 out is silly in mathematical terms. The concept of having a rescue team prepared if needed is not far fetched. However, that is a rescue team in the classical sense and not one conjured up and anointed RIT at the incident. Seems too “spontaneous”. You know?

  • Dave LeBlanc says:

    Yeah I agree with your thoughts on SOPs and Pre Plans. Even increasing alarms assignments so you have the right tools coming.

    Ensuring that enough help is responding may eliminate those handcuffs, orat least make them more workable.

  • backstepfirefighter says:

    Each of you should read Life Under The Lights’ latest post about his own close call; seemingly routine fire, staffing of four between two units. Well written and prompting more discussion.

  • Art Goodrich says:

    I read Under The Lights close call.
    And I think: no communication because they had no radios. Tanker task didn’t require one. This one brings back memories to when our department didn’t even HAVE a handheld radio. This was 1980.
    No accountability system. Good job on UTL’s concern for the three going downstairs to the basement fire. Too bad they didn’t tell him that they went out the walk in door.
    I wonder what happened to the hose they were pulling?
    No one stationed at the first floor front door. Would have made UTL’s escape from Hell a little easier.
    Manpower; being unprepared for the emergency; no communication tools; no IC?; yeah; this is a perfect example of what Dave is talking in his guest blog.
    Oh and basement fires suck.

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