Open the draft document at this link:
#1. Post Hearing Comments on Behalf of FASNY
#2. April 2025 Proposed OSHA 1910.156
In an earlier post on this web site the position of FASNY was misunderstood and incorrectly stated, to be clear it is FASNY’s position that if and only if the Proposed OSHA ER Standard were adopted “as written” then volunteer firefighters should be exempt. A copy of FASNY’s position on replacing the current standard are published with the thanks to FASNY’s Legal Council Tim Hannigan. Please take the time to read it (#1)
Highlights of the April 2025 proposal (#2), is a wish list of negotiable items. Understand that since the comment period is OVER, these wish list items could only come to reality if the construct of the Proposed Standard started all over again.
1) Remove the incorporated by reference NFPA standards. Place appropriate wording directly into the rule itself. Reference the NFPA (and other) standards as industry best practices and encourage their use in the required AHJ policies and procedures.
2) Use the proposed rule below for combination and career departments with populations greater than 25,000.
3) For populations greater than 100,000 use the current OSHA proposal, the proposed standard below or a combination of the 2.
4) Develop a reasonable timeline to phase in the new rule
5) Require a periodic review of the new standard to ensure current best practices and technologies are incorporated.
It is unknown with the appointment of the new Labor Secretary what the next steps in this process are, we can only hope that reason and common sense will prevail.