We are deeply concerned about the proposed rulemaking by the Occupational Safety and Health Administration (OSHA) regarding the replacement of the current “Fire Brigades Standard” and how this would affect first responders in Indiana. This proposed “Emergency Response” standard would impose extensive new regulations on firefighters and emergency responders across Indiana. We fear these new requirements could lead to closures, thus jeopardizing public safety and leaving many rural communities without vital emergency services.

Volunteer departments in Indiana are not immune to the financial and personnel constraints the rest of the industry is facing. Most of these departments operate on small budgets or rely on self-fundraising efforts. Volunteers dedicate their time and resources to ensure communities have access to emergency services, often serving as the sole source of assistance for miles around. Implementing these new requirements, such as additional training and fitness standards, increased written emergency response plans, increased hazard vulnerability assessments, additional medical screenings and mental health services, while well intentioned, would pose significant challenges for our small and volunteer fire departments that lack the economic resources to comply with your proposed standards.

During OSHA’s Small Business Advisory Review (SBAR) panel in Fall 2021, stakeholders highlighted the economic feasibility issues faced by smaller, particularly volunteer, fire departments. The SBAR recommended exemptions for volunteer departments from certain aspects of the standard and suggested identifying areas where financial and logistical burdens could be reduced. However, this proposed standard does not align with SBAR’s recommendations, raising concerns from the local public safety officials we represent.

We write to you to ask that you extend the comment period to gain more input from small and volunteer firefighters in order to obtain a more accurate understanding of the standard’s potential adverse impacts on Indiana’s fire service. We believe that the proposed “Emergency Standard” could compromise the safety of both our departments and communities in Indiana and urge OSHA to reconsider the unique circumstances of volunteer departments and ensure they can continue to operate and provide life-saving services.

Sincerely,