What is the effect of the "fireman's rule" on a tow truck operator?

Holland was a tow truck driver who stopped to help the drivers of three cars who got into an accident. One of the drivers, Tufenkian, began walking towards Holland on the "freeway side" of his tow truck and Holland went towards him, to warn him to walk on the other side. A passing car killed Tufenkian and hurt Holland. (Holland, supra, 26 Cal.App.4th at pp. 1848-1849.) The Holland decision addressed two theories, whether the firefighter's rule applied and whether the rescue doctrine applied. (Id. at p. 1847.) The firefighter's rule generally holds a public safety officer may not recover from a person whose negligence causes the emergency requiring his aid. Holland extended that rule to a private tow-truck operator. This portion of Holland has been disapproved. (Neighbarger v. Irwin Industries, Inc. (1994) 8 Cal.4th 532, 545, fn. 4 (Neighbarger).)