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Serious Concerns From Volunteer Fire Service with OSHA’s Proposed Updates to Their Emergency Response Standard

Serious Concerns From Volunteer Fire Service with OSHA’s Proposed Updates to Their Emergency Response Standard

This change in federal rules has wide-ranging implications for all emergency services providers.  Yes, Federal OSHA does not have jurisdiction over local government employees.  This will affect us through the state agreements with Federal OSHA that will require the state to adopt rules that are “as effective as” the Federal rules.

Please take the time to read over the documents and links, along with sharing this information with neighboring agencies.

We are hoping for a Zoom meeting that will help us understand this large proposed change to the fire service.  This will affect us all at one level or another.

We would like all those who can send letters to OSHA during the comment period to share why this won't work for your department.

If you have questions, please reach out to Andrew Schaffran WSFFA 360.264.3473 or Steve Wright WFC 360.352.0161


Link to NVFC Documents

On February 5 the Occupational Safety and Health Administration (OSHA) published a notice of proposed rulemaking (NPRM) in the Federal Register proposing a new safety and health standard, titled “Emergency Response,” to replace the existing “Fire Brigades Standard.” This is the first major update to OSHA’s “Fire Brigades Standard” since it was issued in 1980. The new standard would address a broader scope of emergency responders and would include programmatic elements to protect emergency responders from a variety of occupational hazards. The public comment period for the proposed rule runs between now and June 21. The NPRM can be found below.

Volunteer Fire Service Position:
The volunteer fire service believes this proposed rule would provide many important provisions that would do a great deal to improve firefighter safety, however, we also see many requirements in this proposed rule that are economically infeasible for volunteer departments to comply with. This proposed standard suggests numerous staffing and reporting requirements that would be impossible for many small fire departments to comply with. Small rural communities are almost exclusively protected by volunteers. Fire protection services are funded at the local level, as a result the resources available to each department are often dependent on the local tax bases. These tax bases can be very restrictive in small and rural communities. Many small volunteer departments still lack running water and operate on annual budgets of $5,000 to $10,000. Additionally, some departments totally self-fund with fundraising efforts like pancake breakfasts, chicken dinners, and bingo nights. These efforts are often labor intensive with low yields. Federal grants and national organizations like the National Volunteer Fire Council (NVFC) have done a great deal to assist volunteer departments in receiving the resources they need, but there is still a large unfulfilled need for these resources. The most important federal grant programs that assist fire departments in achieving a baseline level of readiness are the Assistance to Firefighters Grant (AFG) and Staffing for Adequate Fire and Emergency Response (SAFER) grants. While AFG and SAFER grants have been very successful, there is not enough funding available for these programs to adequately address the fire service’s need for equipment, training and staffing. In FY 2022 FEMA received approximately $2.4 billion in AFG funding applications for $324 million in available funding and approximately $2.8 billion in SAFER funding applications for $360 million in available funding. The NPRM estimates the average annual cost of this proposed rule to a volunteer fire department would be $14, 551. With our understanding of the nation’s volunteer fire service and the data provided above the NVFC strongly believes that many volunteer fire departments throughout the country will not be able to comply with OSHA’s proposed emergency response standard. This lack of compliance will not be due to inconvenience or a lack of desire. The staffing and funding availability for many volunteer departments to do so just doesn’t exist. Additionally, the small departments referenced above are often the only emergency responders within miles, or hours of response time away. More firefighters and communities will be placed at risk if they are required to comply with this prohibitively difficult standard in order to operate.


The NVFC asks that Congress monitor this proposed emergency response standard as it moves through the rulemaking process due to its potentially serious impact on small fire departments. If possible, the NVFC requests that Members of Congress comment on this proposed rule and requests that relevant committees hold hearings on the potential impacts of this proposed rule. For more information or questions please contact the NVFC’s Chief of Legislative and Regulatory Affairs, Ryan Woodward at

Serious Concerns From Volunteer Fire Service with OSHA’s Proposed Updates to Their Emergency Response Standard

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