OSHA Proposed Emergency Response Standard
On February 5, the Occupational Safety and Health Administration (OSHA) published a Notice of Proposed Rulemaking (NPRM) to modernize the agency’s “Fire Brigades” standard with a proposed new “Emergency Response Standard.” This NPRM’s publication triggered the beginning of a public comment period that is scheduled to conclude June 21, 2024 (now extended to July 21, 2024).
While many of the proposed provisions would be helpful and improve the safety of emergency responders, many of the new requirements would be very burdensome, and in many cases impossible, for volunteer fire and emergency service departments to comply with. If the standard is adopted in its current form, many departments would be forced to shut their doors or else operate outside of the federal standard, leaving themselves open to fines, citations, and huge civil liability exposure.
Nothing in the proposed standard is final at this stage, so now is the time to take action. It is critical that members of the fire and emergency services submit a public comment explaining what should be changed in the proposed standard and why. Here are resources to help you better understand the standard and how to submit an effective comment.
05/31/2024 Michigan State Firemen’s Association Webinar and Resources
- MSFA Powerpoint presentation (pdf) of OSHA proposed standard
- OSHA Emergency Response Rulemaking
- Compilation of NPRM Issues and Questions
View the Proposed Standard
- Read the proposed standard in the Federal Register and submit a comment
- View an outline of the requirements included in the proposed standard
- View a list of NFPA standards incorporated by reference in the proposed standard
- Get answers to frequently asked questions about the standard
Take Action
- Submit a Comment on the proposed OSHA standard
- Read the National Volunteer Fire Council ‘Call to Action’ on the proposed OSHA standard
- Take the NVFC’s OSHA Preparedness Assessment (10 minute survey)
- Sign Up for the NVFC’s email list to get updates
Additional Resources
- Association of Fire Districts of the State of New York
- South Carolina State Firefighter’s Association
Michigan Resources
- MIOSHA Part 74 Firefighting Standard – 06/22
- MIOSHA Part 74 Agency Enforcement Instruction
- MIOSHA Part 451 Respiratory Protection – 04/21
Sample Letters and Comments
- Letter from West Virginia State Auditor
- Sample letter for agencies from the Oregon State Fire Chief’s Association
For more information including current updates, visit https://www.nvfc.org/osha-standard/
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