OSHA Proposed Emergency Response Standard
About the Proposed Standard
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 concluded on July 22, 2024. An informal public hearing was then held from November 12 to December 4, 2024. A second public comment period is now open through January 17, 2025.
While many of the proposed provisions in the Emergency Response Standard 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.
This page contains resources to help you better understand the standard and what you can do. Sign up to the NVFC’s email list to stay informed of updates.
View and Understand the Proposed Standard
- Read the proposed standard in the Federal Register.
- View the Emergency Response Rulemaking webpage.
- Read a one-page summary of some of the requirements the proposed standard would place on fire departments.
- View a full outline of the requirements included in the proposed standard.
- View a list of NFPA standards incorporated by reference in the proposed standard.
- Get answers to frequently asked questions about the standard.
- Read OSHA’s Statement on the Emergency Response Rulemaking and Volunteer Emergency Responders
Submit a Comment
- Submit a comment by January 17, 2025.
- View the NVFC’s template to help you prepare your comments.
- Read the NVFC’s comments to OSHA, submitted on July 16, 2024, to understand the organization’s concerns about the proposed standard’s impact on the volunteer fire service.
- View the docket of all public comments submitted to OSHA during the public comment periods regarding the proposed standard.
- View pain points to consider including as to how the proposed standard would impact your department.
Learn More About OSHA’s Public Hearing
- Read the NVFC’s written testimony.
- Read the NVFC’s Q&A Guide for the OSHA’s Virtual Public Hearing.
- Read the Notice of Informal Hearing in the Federal Register.
- Use the NVFC’s guide to prepare to testify at the hearing.
- Watch the webinar OSHA’s Proposed Emergency Response Standard Update: What Comes Next?
- Watch the webinar Preparing Your Public Hearing Testimony on the Proposed Emergency Response Standard.
Congressional Action
- Use this Advocacy One-Pager to inform your Representative and Senators of the concerns with the proposed OSHA standard.
- The House Education and Workforce Committee’s Subcommittee on Workforce Protections held a hearing on OSHA on July 24. Watch the recording of the hearing and read the written testimony of NVFC North Carolina Director Chief Tim Bradley.
- The House Homeland Security Subcommittee on Emergency Management and Technology held a hearing on OSHA’s proposed Emergency Response Standard on June 4. Watch the recording of the hearing of the hearing and read the written testimony of NVFC Massachusetts Director Joe Maruca.
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
