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Message from IAFC President John Butler re: OSHA Draft Emergency Response Standard

Dear IAFC Members:

As you may be aware, the U.S. Occupational Safety and Health Administration (OSHA) has released draft regulations focused on firefighter health, safety, and wellness. These proposed rules have the potential to transform the American Fire Service, and the IAFC is on the frontline, recognizing its unique role as the only organization representing the leadership of America’s career, volunteer, and combination fire and emergency services. As such, the IAFC is actively engaged in a deliberate process to review and provide comment on these draft regulations.

On December 22, 2023, OSHA pre-released its draft of its new Emergency Response standards. These draft standards are a result of a process that started during the administration of President George W. Bush in the wake of 9/11. The IAFC has been continuously involved throughout the process by responding to requests to provide written comment; participating in a subcommittee of the National Advisory Committee on Occupational Safety and Health that drafted an early version of the draft standard; and engaging in the Small Business Administration’s Small Entity Review process.

The draft standards cover a broad range of issues including medical screening and surveillance; personal protective equipment; training; staffing; apparatus; incident management; wildland firefighting; and even portable fire extinguishers. The draft standard would incorporate by reference more than 20 NFPA standards. It is important for all members to educate themselves about who may and may not be impacted by the draft regulations, particularly in states where federal OSHA does not apply to public sector employees or volunteers operating as instrumentalities of state or local government. States with OSHA- approved state plans would be required to treat public-sector employees the same as they do private-sector employees. Even in state-plan states, the impact on volunteer emergency responders will be determined by that state based on its unique scoping language.

In direct response to OSHA’s request for comment, the IAFC developed a working group composed of representatives from our Sections and Committees to review these draft regulations. The working group is examining issues such as the impact on volunteer fire departments; the ramifications of incorporating NFPA standards by reference; and the cost of complying with these new draft regulations. The IAFC will be providing comments to OSHA by the June 21, 2024, due date. OSHA has also requested responses to more than 40 questions presented in the draft regulations.

We want our members to know that we are dedicated to supporting the health, safety, and wellness of emergency responders. We are also sensitive to the impact that the draft regulations may have and are committed to ensuring that any final regulations include a reasonable timetable for implementation. It is also important to communicate clearly that this is just the first step in what will be at least a two-year process of evaluation, review, and revision. We recommend that our members carefully review these draft OSHA regulations; examine how they would affect their organizations; and provide comments to OSHA. We will keep our members updated on the status of the draft regulations and the IAFC’s involvement in this interactive process.


Chief John Butler

Fire Chief John S. Bulter
President and Board Chair

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