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Proposed Changes to the OSHA Standard – Comment Period Opens February 5th

Dear AHJ,

The proposed changes in the OSHA 1910.156 standard are being published and we have a 90 day comment period to respond. If you are unaware of the changes, there are several links below to bring you up to speed. We need to take immediate action to voice our concerns and try to at least make this achievable for our fire service organizations. We have gathered a group of NY and US fire service officials and organizations to try and address these changes. WE NEED YOUR HELP!

Attached please find the actual proposed standard without all the explanation, fluff, etc. I would suggest that each AHJ read this document in its entirety (about 40 pages) and do the following. Take out three highlighters and mark up the document as follows:

Don’t color things you are already doing. (you may find more of this than you expect)
Use the First color to highlight things that you aren’t doing completely now, but with honest evaluation you probably could do without a ton of burden.
Use the Second color to highlight those things that you feel you could do, but would come with a healthy price tag such as additional admin staff, equipment purchase, etc.
Use the Third color to highlight things you feel would be impossible to implement, or simply do not make sense.

From this document, develop list of bullet points and concerns that your AHJ would like to see addressed. Then put the bullet points in order from 1 – most important to higher numbers for items of less importance. Place an * next to all of those items with upmost concern.

Please keep in mind the following as we complete this exercise:

We can bitch and moan all we want, but that is not going to stop the train that is rolling.
There are things all of us can, and should, do to keep our firefighters protected. Their families deserve it. Figure out what we can live with.
If we do not prioritize our battles, we are going to be left on the outside looking in.
TOGETHER – we can make this a more usable standard to lower firefighter injury and line of duty deaths.

Please send your lists to me and we will compile all of these thoughts as we work towards next steps. We will forward the compiled lists to the NYS fire service organizations as they prepare their talking points. We need to compile as many of these as possible by 2/8/24. They will still be valuable after that date, but as many as we can get now would be helpful.

I get it folks, I don’t like it, you don’t like it, and it probably isn’t fair. Neither are half the calls we go to. We can turn the pager off and roll over, or we can respond to this emergency, complete our 360, and use everything in our toolbox to try and get this thing under control. The future of the fire service as we know it is at stake here. We need to dig deep and hit this thing head on. The clock is ticking, we have 90 days to respond.

Please reach out if you have questions.


David C Denniston



[email protected]

Proposed Standard – RAW No Fluff At this LINK : OSHA 1910.156 Proposed Standard – RAW – No Fluff

Here are the Three links for the resources as Dave promised: Click on the titles and the links will appear:

  1. Webinar: Emergency Response Rule | Oshaedne
  2. OSHA’s NEW Proposed Rule 1910.156 Emergency Response rule on Vimeo
  3. Microsoft PowerPoint – 1910.156 Webinar 1-31-2024 draft 2.pptx (