[Chiefs] Fwd: Significant Changes to OSHA Fire Brigade Standard 1910.156 - Immediate Attention Required

[Jeffrey Prescott]

I guess this is a really significant change they are proposing.  Chief Abel
is signed up for the Saturday webinar related to it.

Jeff

---------- Forwarded message ---------
From: Association of Fire Districts of the State of New York <
ddenniston at afdsny.org>
Date: Thu, Feb 22, 2024 at 12:38 PM
Subject: Significant Changes to OSHA Fire Brigade Standard 1910.156 -
Immediate Attention Required
To: Jeffrey Prescott <egfd3treasurer at gmail.com>




Jeffrey,

Hello

OSHA recently published significant changes to OHSA 1910.156 which has the
potential to dramatically change the face of the US and NYS Fire Service.
The proposed changes are in a 90 day (ends May 6th) comment period and
require immediate action by your fire service organization. The 608 page
document published by OSHA contains data and compelling stories as to why
the changes are needed. While we 100% agree with firefighter safety and
everything that can be done to improve it, we feel the financial and time
consuming changes in the standard will have negative impacts on the fire
service organizations and will actually decrease the already struggling
number of firefighters and may force many to leave the service. We also
question the reliability of some of the data and theories used to produce
this proposal. There are immediate actions that all fire service
organizations could take that would have immediate impacts on firefighter
safety and be of little or no expense to the AHJ. Several of these areas
have been untouched by the proposed standard while costly and time
consuming requirements have made their way into the proposed regulation. 22
NFPA standards are now included in the proposed OSHA standard by reference.
This means that anyplace the NVFA standard says “shall” or “must” the AHJ
would be responsible to include them. There are another 14 NFPA standards
that are included in part. Bottom line is these changes would have major
implications on every AHJ, Officer and firefighter in NYS. Our concern here
is not unfunded mandates and possible fines, our biggest concern is the
liability this will now place on organizations that have a firefighter
death or injury. This proposed standard leaves the doors wide open for
litigation and settlements at a level we have never seen.

AFDSNY is hosting a webinar on Saturday morning 2/22/24 to explain the
process and shed some light on the changes. The webinar is limited to 500
participants and registration is near 400 at this point. We encourage you
to both register and log in early to get a spot. We are attempting to
increase the number of seats if we get closer to that 500 number. We will
also make a recording available after the webinar for anyone that might
have a conflict or can not get in.

Webinar registration link:

https://archcapgroup.zoom.us/webinar/register/WN_4pKiYkIcSEW1FFIRl6yVJg


We are asking that every AHJ in NYS assign someone to start reading the
proposed standard and that every AHJ file a comment with specific
information on financial burden and hardships that would create for your
municipality. This week alone, I have had conversations with
representatives from USSBA, FEMA, PESH, state and local fire service
organizations, and both NYS State and Federal elected officials. ALL of
these have expressed concerns that this would have major impacts on how
fire service is delivered here in NYS. The clock is ticking and we only
have until May 6th to have our voices heard. The importance of immediate
action of every AHJ can simply not be overstated. Both your boards and
legal council should be included in your conversations.

The document can be found here: Emergency Response Standard; Proposed Rule
| Occupational Safety and Health Administration (osha.gov)
<https://www.osha.gov/laws-regs/federalregister/2024-02-05>

The heart of the proposed regulation is here: Section 1910.156, Emergency
Response (osha.gov)
<https://www.osha.gov/sites/default/files/erp-draft-reg.pdf>

Additional US Department of Labor resources: Emergency Response Rulemaking
| Occupational Safety and Health Administration (osha.gov)
<https://www.osha.gov/emergency-response/rulemaking?trk=public_post_comment-text>

Informational webinar by OSHA Training Institute:
https://oshaedne.com/webinar-emergency-response-rule/

Additional information at:  Home - Association of Fire Districts of the
State of New York (afdsny.org) <https://afdsny.org/>


David C. Denniston

Vice President

AFDSNY

607-423-1636



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Message sent by David Denniston, ddenniston at afdsny.org
Association of Fire Districts of the State of New York | PO Box 496 |
Selkirk, NY 12158


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