National Volunteer Fire Council’s Post

OSHA PAIN POINT #10: Let OSHA know how the proposed Emergency Response Standard will impact your department! Here is one ‘pain point’ that you can address in your comment. OSHA’s Proposed Rule: All fire chiefs must receive NFPA1021 Fire Officer III training. The Pain Point: The Fire Officer III certification is only offered in approximately 25 states. Chief officers would face significant hardship in getting the required training and certification. Unpaid volunteer chiefs or part-time chiefs would be required to take classes on weekdays when they have to take time off from their full-time jobs, or they would have to travel long distances to night and weekend classes. Tell OSHA: The cost of accessing NFPA1021 Fire Officer III training will place a financial burden on volunteers. In most cases, this class is not offered on a schedule that is friendly for volunteers. Many volunteer officers will be required to travel to a state where they can receive training, taking time away from their primary job and requiring funds that are often not available. All required training must be widely accessible and, when possible, virtually available. Find more resources, including a template comment letter, at: www.nvfc.org/osha-standard Submit your comments by July 22 here: https://bit.ly/3KTKqTD

Firefighter Deaths Fell Slightly in 2023 but Remain High: NFPA Report The National Fire Protection Association (NFPA) has released a report indicating that firefighter deaths have decreased slightly in 2023. Despite this reduction, the numbers remain high, highlighting the persistent dangers faced by firefighters. The report emphasizes the critical need for ongoing improvements in safety measures and training programs to protect these essential workers. Firefighters continue to encounter significant risks in their line of duty, from hazardous environments to unpredictable fire behavior. The slight decline in fatalities is a positive sign, but it also serves as a reminder that more work is needed. Enhancing safety protocols, providing comprehensive training, and ensuring access to the latest safety equipment are crucial steps in reducing the number of firefighter deaths. The NFPA report calls for a renewed focus on addressing the underlying causes of these fatalities. This includes not only physical safety measures but also addressing factors such as mental health support and fatigue management. The high-stress nature of firefighting can take a toll on mental health, and providing resources to support firefighters' psychological well-being is essential. Overall, while the slight decrease in firefighter deaths in 2023 is encouraging, it is clear that the fight to protect those who protect us is far from over. Continued vigilance, investment in safety, and a commitment to supporting firefighters in every aspect of their work are necessary to bring these numbers down further. #FirefighterSafety #WorkplaceSafety #NASP #NFPA #SafetyProfessionals #FirefighterDeaths #SafetyMeasures #MentalHealth #Training #SafetyEquipment

OSHA PAIN POINT #17: Let OSHA know how the proposed Emergency Response Standard will impact your department! Here is one ‘pain point’ that you can address in your comment. OSHA’s Proposed Rule: OSHA estimates that the annual cost for a volunteer fire department to comply with this standard would be approximately $14,000. The Pain Point: Due to the costs of physicals, needed administrative staff, and equipment, among other provisions within the proposed standard, the NVFC believes the cost of compliance would be much greater. Tell OSHA: What your department’s budget is and whether you could absorb this expense. If possible, tell OSHA what you think it would cost your department to implement this proposed Emergency Response Standard. You can use this one pager to assist you in understanding some of the requirements in OSHA’s proposed standard. Find more resources, including a template comment letter, at: https://bit.ly/3WA6JEQ Submit your comments by July 22 here: https://bit.ly/3KTKqTD

OSHA PAIN POINT #15: Let OSHA know how the proposed Emergency Response Standard will impact your department! Here is one ‘pain point’ that you can address in your comment. OSHA’s Proposed Rule: Twenty-one NFPA standards are incorporated in OSHA’s proposed rules. The Pain Point: Most of these standards are updated every three to five years and if a current standard is incorporated by reference into the proposed standard, it will remain fixed and require a Federal Register notice to be updated within the Emergency Response Standard. Second, NFPA is in the process of consolidating many of its standards and it is not clear how these standards would be impacted if they are incorporated by reference and are consolidated into other standards afterwards. Tell OSHA: That NFPA standards are not static and are updated every few years. If these standards are incorporated by reference, fire departments could be mandated to comply with outdated or non-existent standards. Find more resources, including a template comment letter, at: https://bit.ly/3WA6JEQ Submit your comments by July 22 here: https://bit.ly/3KTKqTD

OSHA PAIN POINT #4: Let OSHA know how the proposed Emergency Response Standard will impact your department! Here is one ‘pain point’ that you can address in your comment. OSHA’s Proposed Rule: OSHA’s Proposed Rule is seeking input on whether the proposed rule should specify retirement ages for personal protective equipment (PPE). Current NFPA standards call for 10 years. The Pain Point: Are all your firefighters using gear under 10 years of age? Can you afford to replace gear older than 10 years of age? Tell OSHA: While 10 years seems reasonable for firefighters actively engaged in structural firefighting, do we rule out or discard gear 11 years of age even though it shows minimal signs of wear? How about others who perform support functions, or extrication, etc.? Some firefighters wear the same structural fire helmet for their entire career spanning 20 – 30 years. Is there statistical evidence by OSHA that helmets over 10 years of age are causing head injuries or burns? Gear that is used to run 600 calls per year doesn’t have the same wear and tear as gear that is used to run 85 calls per year. Find more resources, including a template comment letter, at: www.nvfc.org/osha-standard Submit your comments by July 22 here: https://bit.ly/3KTKqTD

OSHA PAIN POINT #8: Let OSHA know how the proposed Emergency Response Standard will impact your department! Here is one ‘pain point’ that you can address in your comment. OSHA’s Proposed Rule: The proposed OSHA rules incorporate by reference 21 NFPA standards. This adds about 3000 pages of text to the rules. The Pain Point: Small fire departments don’t have the legal or administrative capabilities to read, interpret, and comply with this much new regulation. Tell OSHA: Tell OSHA that there is no administrative or legal staff available at your fire department to read, interpret, and comply with 3000 pages of NFPA standards. Tell OSHA how small or non-existent your administrative staff and budget is. Find more resources, including a template comment letter, at: www.nvfc.org/osha-standard Submit your comments by July 22 here: https://bit.ly/3KTKqTD

OSHA PAIN POINT #5: Let OSHA know how the proposed Emergency Response Standard will impact your department! Here is one ‘pain point’ that you can address in your comment. OSHA’s Proposed Rule: If approved, the new OSHA rules would require your fire department to conduct annual fitness for duty testing, essentially an annual physical ability test that includes dragging dummies, hitting targets with axes, and forcing a door or breaching a wall. The Pain Point: Most small fire departments have no training props. They have no facility for conducting a fitness for duty test, especially one that meets many legal requirements of consistency and fairness for all participants. This means hiring vendors to do the test or having firefighters drive hours to a test. Tell OSHA: If your fire department can conduct a physical ability test each year. Tell them how far away the nearest facility for a test is. Tell them what props or facilities you have and don’t have. Tell them your budget and what this will cost. Find more resources, including a template comment letter, at: www.nvfc.org/osha-standard Submit your comments by July 22 here: https://bit.ly/3KTKqTD

OSHA PAIN POINT #12: Let OSHA know how the proposed Emergency Response Standard will impact your department! Here is one ‘pain point’ that you can address in your comment. OSHA’s Proposed Rule: The proposed OSHA rules add up to about 3000 pages of text when you include the 21 NFPA standards that are incorporated by reference into the proposed rules. The Pain Point: Reading this much legal text and trying to understand it by July 22 is a massive task that many will not be able to accomplish. Tell OSHA: You need more time to read, understand, and comment on the proposed Emergency Response Standard because of its length and complexity. Find more resources, including a template comment letter, at: www.nvfc.org/osha-standard Submit your comments by July 22 here: https://bit.ly/3KTKqTD

OSHA PAIN POINT #7: Let OSHA know how the proposed Emergency Response Standard will impact your department! Here is one ‘pain point’ that you can address in your comment. OSHA’s Proposed Rule: At least 21 NFPA standards are incorporated in OSHA’s proposed rules. The Pain Point: While NFPA standards are available to view for free online, printed copies of these standards are not free. An $11.99 a month NFPA membership would be required to print these standards, plus the cost of ink and paper. The NFPA also sells printed copies of their standards. For example, a printed copy of NFPA 1021 costs $149.00. This limited access to printed NFPA standards is particularly problematic since many volunteer fire departments in rural areas lack reliable internet access or funding to purchase printed copies. Tell OSHA: Let OSHA know what your department budget is and the burden it would be to purchase NFPA standards. Also let OSHA know if your department does not have reliable internet access to view these standards. It is wrong for OSHA to mandate standards that are not reasonably available to view for free. Find more resources, including a template comment letter, at: www.nvfc.org/osha-standard Submit your comments by July 22 here: https://bit.ly/3KTKqTD

OSHA PAIN POINT #1: Let OSHA know how the proposed Emergency Response Standard will impact your department! Here is one ‘pain point’ that you can address in your comment. OSHA’s Proposed Rule: All Emergency Service Organizations shall conduct a community or facility vulnerability and risk assessment for its service area, for the purpose of establishing its standards of response and determining the ability to match the community or facility’s risks with available resources. The Pain Point: Does your fire department conduct hazard assessments (or pre-plans) to all commercial businesses? Does your department conduct hazard assessments to all vacant structures? Does your department pre-plan facilities that are subject to reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA)? Does your department have an incident plan for each of the hazard assessments for an emergency incident? If not, then you will not be compliant with the OSHA Proposed Ruling. Tell OSHA: This is economically infeasible and there is no local funding for the hazard assessments of all buildings in your area. Let OSHA know what the cost would be to add one or more employees to be able to comply with conducting the yearly assessments. Be blunt – tell them you have no administrative staff to do this. Find more resources, including a template comment letter, at: www.nvfc.org/osha-standard Submit your comments before July 22 here: https://bit.ly/3KTKqTD