Comment Period Extended for OSHA’s Updated Emergency Response Standard

April 9, 2024

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 was initially scheduled to conclude on May 6. Thanks to feedback from the emergency services community, OSHA has extended this public comment period to June 21, 2024.

The proposed updated standard would issue several new requirements that would be very burdensome, and in many cases impossible, for volunteer fire departments to comply with. Specifically, there would be prohibitively restrictive standards on physical exams, the purchase of new equipment, and the formation of emergency plans that exceed the staffing capabilities of many volunteer departments.

Any individual or organization can submit comments to OSHA regarding this proposed standard during the public comment period. It is important that OSHA receive the most detailed picture possible of how difficult it would be for volunteer departments to comply with this proposed standard. The National Volunteer Fire Council (NVFC) encourages volunteer departments to submit detailed comments to OSHA regarding how this proposed standard would impact their agency and operations. The more information OSHA receives from volunteer departments, the more compelling the case will be for OSHA to change this standard to better serve volunteers before it is adopted. This comment guide and supplementary outline provide suggestions on how to draft effective comments as well as instructions on how to submit these comments to OSHA.

Additionally, the NVFC is in the process of drafting our own comments on OSHA’s proposed Emergency Response Standard. Please fill out this survey so we can submit the most informed comments possible to OSHA.