Changes to the OSHA Fire Brigade Standard (1910.156) Will Impact Your Department

The Federal Occupational Safety and Health Administration (OSHA) recently proposed significant changes to the OSHA Fire Brigade Standard (1910.156). The new OSHA 1910.156 rule (Emergency Response Standard), if approved in its current form, will dramatically change the face of the fire service in New York and across the nation. The tumultuous impact created by these changes will be felt by volunteer, combination and career departments alike.

While the goal of the new rule is to further protect the safety of emergency responders, it was crafted in a vacuum and does not reflect the challenges that emergency response agencies face in the real world.  While the fire service fully agrees that responder safety is of paramount importance, that goal must be balanced with the abilities and resources of the agencies responsible for those individuals. After careful review, it is apparent that many of the changes and new requirements will negatively impact already struggling response agencies. In fact, the new standard could hamper recruitment and retention efforts and even cause many current firefighters to leave the service. Despite its bureaucratic “good intentions”, this new rule could actually decrease firefighter health and safety.

The 608-page document published by OSHA contains data and stories as to why the changes are needed. Based on our real-world experience, we question the reliability of some of the data and theories used to produce this proposal. Rather, there are less intrusive actions that fire service organizations could take that would have immediate positive impacts on firefighter safety and create little or no additional burdens. 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. Twenty-two National Fire Protection Association (NFPA) standards have been fully incorporated into the new OSHA standard by reference, with another fourteen included in part. This means that any place the NFPA standard says “shall” or “must” the AHJ would be responsible to adhere to them.

These changes will have major implications on every AHJ, fire officer and firefighter. Our concern here is not merely that they are unfunded mandates. The unattainable nature of this proposed standard virtually ensures that many departments will be in non-compliance.  

The proposed changes have been published in the Federal Register and are currently in a 90-day comment period that concludes on May 6. The fire service must be united in their response to this potentially devastating governmental action. This includes involvement by your fire service organization. We need you to inform your department of this situation and ask them to request that the comment period be extended for an additional 60 days. They should also request that OSHA hold an “in person” hearing where testimony can be presented. Further, every AHJ should review the proposed rulemaking and submit comments on how it would negatively impact their organization. The importance of immediate action by every AHJ cannot be overstated.

The OSHA document can be found here: Emergency Response Standard; Proposed Rule | Occupational Safety and Health Administration (

The heart of the proposed regulation is here: Section 1910.156, Emergency Response (

Additional US Department of Labor resources: Emergency Response Rulemaking | Occupational Safety and Health Administration (

Informational webinar by OSHA Training Institute: