OSHA’s Proposed Emergency Response Rule

What can you do? Get involved! 

Latest Update: May 19, 2024

The information being provided here is a collection from other agencies and the FFAM Magazine Articles on OSHA’s New “Emergency Response Rule”

Full disclosure, this currently involves 29 OSHA States (State Plans) which Missouri is not one. Missouri one of 21 States which have deferred to Federal OSHA for Work Place Safety Management. The comment period closes June 21, 2021. The main concern is what ever is concluded as the new law/standard in those 29 OSHA States WILL eventually be applied to the other 21 (Missouri) as OSHA’s Core Operational Procedure since 1972 is > “Equal to or Greater” on Federal Standards and therefore will be applied in the remaining 21 States.

What can you do? Get involved! The Federal e-Rulmaking Portal can be accessed at www.regulations.gov  From there all submissions must include the agency name and Docket No. which is OSHA-2007-0073. You may submit comments and attachments identified by this docket number. Please try to follow the recommended approach, but going to the link and just venting is better than not responding at all. They will likely file it to the side, but they must still record it as a comment for total numbers and a negative opinion.

What should be your approach to this? Your comment needs to be in fact and numbers and especially the $$$ impact. ESPECAILLY FROM VOLUNTEER DEPARTMENTS >>> Describe your department to OSHA: How many people are in your department? What’s your budget? What is the makeup and challenges of your service area? Do you have the funds to comply with any of this proposed standard? Do you have the staffing to comply with this proposed standard? How would your area be negatively impacted if your department had to shut down due to this standard? Does your department rely on fundraising for much of your income? If so, how many pancake breakfasts, raffles, or spaghetti dinners would you need to hold to comply with this proposed rule? Would your municipality be able to assist you in covering the costs of this proposed rule? If not, why? What specific provisions of this proposed rule are the most difficult for your department to comply with? Why are they difficult? What alternatives to this proposed rule should OSHA consider improving the safety of firefighters. They will not accept leave things as they are unless congress sends that message, but this is not the portal for that argument. This is being approached on multiple fronts.

Information is being provided as updates and new information as received.

Download NVFC Outline (Detailed) 05-19-24 - PDF Download NVFC Comment Guide 05-19-24 - PDF Download NVFC Statement (Brief) 05-19-24 - PDF Download McNeil & Co Statment Q&A 05-19-24 - PDF Download Article Update 04-27-24 - PDF Download Article Update 02-27-24 - PDF

If you have questions, NVFC State Director Keith Smith will try to assist or get it answered by one of the NVFC Task Force members. You may call Keith at 314 709 0760 or email him at keith.smith@warrenton-fire.org