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Deadline to submit comments on proposed OSHA Emergency Response Standard is today

July 22, 2024

IAFC comments on OSHA Emergency Response Standard

The deadline for submitting comments on the proposed Emergency Response Standard to the Occupational Safety and Health Administration (OSHA) is today, July 22.

Comments can be submitted here.

The International Association of Fire Chiefs (IAFC) submitted its comments on July 11, in response to Docket No. OSHA-2007-0073.

The draft standard aims to update and expand regulations concerning emergency responders, replacing the outdated Fire Brigades standard.

Since the process began in 2007, the IAFC has been actively involved.

They participated in various advisory committees and reviews.

To address the new draft, the IAFC assembled a team of 30 fire chiefs and retained the law firm Jackson Lewis for legal consultation.

Their comments emphasized the need to protect firefighter safety, addressing risks such as heart attacks, strokes, cancer, and exposure to hazardous materials like lithium-ion batteries and PFAS.

Key issues raised by IAFC

The IAFC’s comments also highlighted several important issues:

  • Consolidation of National Fire Protection Association (NFPA) standards.
  • Requirement of NFPA 1582 physicals and a request for Congressional funding to cover the costs.
  • Inclusion of wildland firefighting standards from the National Wildfire Coordinating Group.
  • Potential costs and challenges for volunteer fire departments.
  • Proposing a staggered 10-year compliance timeline instead of the proposed two-year timeline.

NVFC’s position on the proposed standard

The National Volunteer Fire Council (NVFC) also provided feedback, noting that while many provisions could improve safety, others would impose significant burdens on volunteer departments.

Compliance with the current form of the standard could lead to operational difficulties or closures, exposing departments to fines and liability.

The NVFC emphasized the importance of submitting comments to influence the standard’s final form.

They encouraged stakeholders to explain the practical challenges and provide suggestions for improvement.

What happens next?

After the comment period ends, OSHA will review all submitted comments and may incorporate the feedback into the final standard.

The agency has also indicated that it might hold a public hearing to further review the draft regulations.

This process ensures that stakeholders have additional opportunities to influence the final rules.

The timeline for the final implementation of the standard is yet to be determined, and it will depend on the outcomes of the review and hearing processes​ (OSHA)​​ (OSHA)​​ (JD Supra)​​ (IAFF)​.

Comments can be submitted here.

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