26 Mar 2024

The Occupational Safety and Health Administration (OSHA) is proposing an extensive new safety and health standard, titled “Emergency Response,” to replace the existing “Fire Brigades Standard.”

The Notice of Proposed Rulemaking for the “Emergency Response Standard” was published in the Federal Register on February 5, with the public comment period open until May 6.

updated standard

This proposed updated standard would issue hundreds of new requirements that may be very burdensome, and in many cases impossible, for volunteer fire departments to comply with.

The National Volunteer Fire Council (NVFC) encourages volunteer departments and associations to submit comments on this proposed rule and request a public hearing so OSHA can have the best possible understanding of how this proposed rule would impact volunteer departments. NVFC also encourages users to send a letter to OSHA requesting a 90-day extension to the public comment period on this proposed rule.

comment guide

Additionally, please fill out the survey to assist the NVFC in collecting department data as the NVFC formulates our comments on the proposed rule. To assist users in developing the comments and public comment period extension letters, the NVFC has assembled this comment guide. This guide guides on:

  • Where to find the text of the proposed standard.
  • Where and how to submit the comments on the proposed standard?
  • How to evaluate if the department is covered by the proposed standard.
  • How to develop the comments.
  • What part of the proposed standard will impact volunteer departments the most?

important language

The NVFC’s comment guide also links to a map of states with OSHA plans, a template for comment extension letters, and webinars to further assist in understanding whether or how the proposed rule would impact the department. 

The NVFC has also put together this outline of the proposed standard to further highlight important language and provide additional context to the comment guide.