OSHA Releases Statement on Volunteers; Deadline this Week to Request to Testify at OSHA Hearing

September 24, 2024

This week the Occupational Safety and Health Administration (OSHA) released a statement indicating that they are listening to the public comments and the significant concerns the volunteer fire service has shared regarding their proposed Emergency Response Standard. The statement also emphasized the need for further engagement and comments from the volunteer fire service. The next opportunity for the volunteer fire service to do so is at the public hearing, which will begin on November 12 and likely continue on weekdays from 9:30am to 4:30pm ET for a couple of weeks. The deadline to secure a timeslot to testify at this hearing is September 27.

Anyone can testify at the public hearing even if they did not comment on OSHA’s proposed Emergency Response Standard during the public comment period that concluded on July 22. The National Volunteer Fire Council (NVFC) encourages all firefighters to request a timeslot to testify, even if they are unsure that they’ll use it. All those wishing to request a timeslot to testify may do so by submitting a Notice of Intent to Appear (NOITA) before September 27. The NVFC has developed a guide to assist with NOITA submission and development of testimony.

If you have already submitted comments on the proposed rule, it is ok to re-emphasize the points you made during your testimony but don’t make it the primary topic of your testimony. Look at public comments submitted by other stakeholders or organizations (for instance the NVFC, International Association of Fire Chiefs, National Association of Counties, etc.) and tell OSHA what you agree with and disagree with in these comments and why.

All public comments on the proposed rule are available to view in the public docket here. The docket is searchable by topic, organization name, content, author, time period, and other filters. Below are examples of some national associations’ comments in the docket that may be helpful for crafting your testimony:

You can find additional information and resources on the NVFC’s OSHA landing page.