OSHA Proposed Emergency Response Standard

Note: This page will be updated as more resources are available.

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.

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.

Proposed Standard

Proposed Standard – Read the proposed Emergency Response Standard in the Federal Register and submit a comment through the public comment portal (the public comment period has been extended from May 6 to June 21).

Outline of Proposed Emergency Response Standard – View a list of requirements that are included in OSHA’s proposed Emergency Response Standard.

Standards Incorporated by Reference – These NFPA Standards are incorporated by reference into the proposed OSHA rule. “Incorporated by Reference” means that the full text of these standards will become law if the proposed OSHA standard is adopted as-is.

Help With Formulating a Comment

Comment Guide – Use this guide to help draft an effective comment telling OSHA what provisions are too burdensome for your department to comply with and why.

How to Submit a Comment for OSHA in the Registry – In this video, Dave Denniston walks through how to submit a comment on the proposed Emergency Response Standard in the Federal Registry.

Small Business Guide to Comment Letter Writing – This resources from the Small Business Administration’s Office of Advocacy explains how to structure an effective comment letter.

OSHA 1910.156 Update: Taking Action – This webinar explains how to formulate and submit a comment on the proposed Emergency Response Standard.

Action Items

NVFC Call to Action on Proposed OSHA Emergency Response Standard

Submit a Comment – Use the public comment portal to submit a comment on the proposed OSHA standard.

Action Alert – Use this NVFC Action Alert to contact your U.S. Representative and ask them to cosign a letter asking OSHA to consider exempting volunteer fire departments from some or all parts of the proposed standard, identify additional areas where financial and logistical burdens could be reduced, and extend the proposed standard’s public comment period by an additional 90 days.

NVFC OSHA Preparedness Assessment – Fill out this NVFC survey to help the NVFC better understand the full impact the proposed standard will have on the volunteer fire service.

Sign Up – Sign up for the NVFC’s email list to receive notifications on the status of the OSHA Emergency Response Standard and any calls to action.



Roundtable Talk: Proposed OSHA Standard Update and Working with Local Government – Join the NVFC on May 23 at 2pm ET for this discussion on how volunteer departments can collaborate with their local government to express these concerns to OSHA regarding the proposed standard.


Roundtable Talk: Proposed OSHA Emergency Response Standard Update and What It Means for Volunteer Fire Departments (March 17) – This discussion highlights the biggest concerns with the proposed standard and best practices for departments to submit a comment to OSHA.

Update from OSHA on the Proposed Emergency Response Standard (May 8) – Hear from representatives from OSHA’s Office of Safety Systems, Directorate of Standards and Guidance as they discuss how volunteers would be impacted by the proposed standard and what you can do to make your voice heard.

OSHA Webinar on Emergency Response Rule (January 31) – This webinar from the OSHA Training Institute  Education Center reviews the proposed standard and how it is different from the previous Fire Brigades Standard.

USFA and OSHA Presentation on the Emergency Response Notice of Proposed Ruling (March 21) – Hear from USFA’s National Fire Academy Superintendent Eriks Gabliks and OSHA’s director of standards and guidance, Andrew Levinson, as they discuss the history of the Fire Brigades Standard and proposed Emergency Response Standard, the process for submitting comments, and the proposed timeline.

OSHA Plan States Proposed 1910.156 Update – This webinar provides an overview of the proposed OSHA Emergency Response standard and how it will apply to OSHA plan states.

EMS and the Proposed Emergency OSHA Response Rule (May 2) – This webinar looks at how the proposed Emergency Response Standard will impact EMS agencies.

Additional Resources

Association of Fire Districts of the State of New York – Find additional resources and webinars regarding the proposed OSHA Emergency Response Standard.

Sample Letters and Comments

Letter from West Virginia State Auditor

Sample letter for agencies from the Oregon State Fire Chief’s Association