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 July 22, 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. This page contains resources to help you better understand the standard and how to submit an effective comment.

Submit a Comment Now

NVFC’s Perspective

Read the NVFC’s comments to OSHA, submitted on July 16, 2024

Help Desk

Want to speak with someone at the NVFC regarding the proposed standard or how to write an effective comment? Join Ryan Woodward, NVFC’s chief of legislative and regulatory affairs, for a Help Desk on the following dates/times. These are not webinars – join whenever you can during the specified times to ask your questions and to hear what others are saying.

View and Understand the Proposed Standard

Formulate an Effective Comment

Take Action

Watch a Webinar

NVFC Roundtable Talk: Proposed OSHA Standard Update and Working with Local Government (May 23) – Learn how volunteer departments can collaborate with their local government to express concerns to OSHA regarding the proposed standard.

NVFC Webinar: Proposed OSHA Standard and What it Means for Volunteer Departments (May 16) – Learn the biggest concerns with the proposed standard and best practices for submitting a comment.

NVFC Webinar: Update from OSHA on the Proposed Emergency Response Standard (May 8) – Hear from OSHA representatives as they discuss how volunteers would be impacted by the proposed standard and what you can do to make your voice heard.

NVFC 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.

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) – Learn about 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 – Get an overview of the proposed standard and how it will apply to OSHA plan states.

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

Additional Resources

Sample Letters and Comments

Congressional Testimony

On June 4, NVFC board member Joe Maruca and 2nd VP of the Association of Fire Districts of the State of New York Dave Denniston were among those who testified at the House Homeland Security Subcommittee on Emergency Management and Technology’s hearing on OSHA’s proposed Emergency Response Standard.