On July 11, the International Association of Fire Chiefs filed comments to Docket No. OSHA-2007-0073 in response to the draft Emergency Response Standard that was released by the U.S. Occupational Safety and Health Administration.
The IAFC has been involved in the OSHA process since it began in 2007. The IAFC answered a request for information about updating the OSHA Fire Brigade standard (29 CFR 1910.156). Also, IAFC members participated in the National Advisory Committee on Occupational Safety and Health’s subcommittee, which made recommendations about updating the standard, and the Small Business Administration’s small entity review process.
When the new draft standard was released, the IAFC assembled a team of approximately 30 fire chiefs to review the 250-page document and develop comments on it. The IAFC also retained the law firm of Jackson Lewis to address legal issues relating to the draft standard and draft the IAFC’s comments.
In its comments, the IAFC highlights the need to protect firefighter safety and reduce deaths and injuries. It also discusses the risks of heart attacks, strokes, cancer, and threats like exposure to fires involving lithium-ion batteries and exposure to potentially harmful chemicals like PFAS.
The IAFC’s comments also address several issues including:
- Consolidation of The National Fire Protection Association’s standards
- Requirements of NFPA 1582 physicals, including requesting Congressional funding to help pay the cost
- Incorporation of wildland fire fighting standards developed by the National Wildfire Coordinating Group for wildland fire operations
- Potential costs and other challenges of implementing the new draft standard on volunteer fire departments
- Feasibility and applicability of the new draft standard to volunteer fire departments, including exemptions to some or all parts
- Equivalent or more effective means to achieve the goals of the draft Emergency Response standard
- A staggered 10-year timeline for compliance as a replacement for the proposed two-year timeline
The proposed OSHA Emergency Response standard is not imminent. OSHA will review all comments it received in response to the proposed draft Emergency Response standard and decide whether to incorporate them. It also may hold an administrative hearing to review aspects of the draft regulations.
IAFC's Comments
The IAFC will keep its members informed as the OSHA process continues.
Ken LaSala is the IAFC’s Director of Government Relations & Policy.