OSHA Needs to Hear from You Regarding Their Proposed Emergency Response Standard

April 23, 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 is scheduled to conclude June 21, 2024.

Anyone, organization or individual, is encouraged to submit comments to OSHA during this this public comment period (ignore the May 6 deadline as it has been extended to June 21). Reading through the NPRM, it is clear OSHA does not have an accurate understanding of the nation’s volunteer fire service and there are several new requirements that would be very burdensome, and in many cases impossible, for volunteer fire departments to comply with in this proposed standard. Nothing in this proposed standard is final at this stage, and now is your opportunity to explain to OSHA what you believe should be changed in the proposed standard and why.

As of April 22, there have been 692 comments submitted to OSHA regarding the proposed Emergency Response Standard; however, many of these comments are ineffective and will likely not do anything to encourage OSHA to change this proposed standard. The reason for this is many of the submitted comments are form letters or simply state that the proposed standard is too burdensome with no information or context explaining why.

To be effective, your comments need to explain to OSHA exactly what provisions in the proposed standard are too burdensome and why. Your comments should also describe your department to OSHA: How many people are in your department? What’s your budget? What’s the area you serve like? Do you have the funds to comply with this proposed standard? Do you have the staffing to comply with this proposed standard? How would your area be negatively impacted if your department had to shut down due to this standard? Does your department rely on fundraising for much of your income? If so, how many pancake breakfasts, raffles, or spaghetti dinners would you need to hold to comply with this proposed standard? Would your municipality be able to assist you in covering the costs of this proposed standard? If not, why? What alternatives to this proposed standard should OSHA consider to improve the safety of volunteer departments? Is your department a nonprofit department?

The National Volunteer Fire Council (NVFC) understands that this NPRM is long and very time consuming to understand, that is why we have assembled a comment guide and accompanying outline to provide you with guidance on how to draft effective comments. The comment guide also contains links to other helpful resources like a Roundtable Talk the NVFC did regarding the proposed Emergency Response Standard.

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.