Attention:
We need everyone’s assistance again to let OSHA know that the proposed amendments to the 1910.156 Emergency Response Standards will place a tremendous strain financially on volunteer, combination, and smaller municipal fire departments.
Just like the comment period that ran from February 5 to July 22, we are asking individuals and departments to submit their own post hearing public comments. We will be submitting a proposal from NCSFA letting them know a better answer is a tiered system based on population that would make the proposal more realistic. Just like the prior comment period, anyone can submit comments. The PDF link below contains everything an individual would need to know to submit their post hearing comments, including a link of where to submit the comments. Here is that link in long form: https://www.regulations.gov/commenton/OSHA-2007-0073-4425.
Please comment on the effect it would have financially on your departments, and ask them to take a more realistic approach, especially for volunteer, combination, and smaller municipal fire departments, that pairs requirements directly to risk, and available resources based on size.
We at NCSFA support specifically defined safety standards tied to risks for personnel that are realistically achievable financially. However, the one size fits all approach that unilaterally adopts multiple standards from NFPA and ANSI, that removes provisions that were originally written into the standards previously with the Local Authority Having Jurisdiction decision capabilities, is not achievable by a majority of departments. We prefer a standard, written with the assistance of a broader range of fire department risks and capabilities in mind, and developed with the assistance of individuals who can represent that spectrum.
Thanks,
NCSFA
