As you may have seen, OSHA issued an unusual statement on Monday about the proposed 1910.156 rule. Many are asking what this all means. Having been involved in this process now for months, I offer my opinion on the statement. This is purely my opinion and may not reflect that of any organizations that I am currently working with.
OSHA is feeling a great deal of pressure from our elected officials. They have been questioned on their process, their proposal as written, and their understanding of what they have created. OSHA is attempting to defend what they have produced and preparing for the battle ahead. They have basically thrown down the gauntlet here and challenged us to engage. They will use this to either make the needed changes in the proposal, or to defend that they have asked us for details, and we have failed to deliver.
Please sign up to testify. We have got to deliver on this. Every department that will be impacted by this needs one person to tell your story. It is easy to tell your story and we can help you with that. Tell why the standard as written is economically infeasible. Tell them to remove the incorporated NFPA standards and replace them with plain text that we can follow and understand. Tell them your officers will no longer meet the qualifications to be officers. Tell them that weekly and 24 hours following a run truck checks are difficult for our organizations. Tell them NFPA 1582 physicals are concerning in price. Tell them you don't have qualifications for physical trainers. Tell them you don't have time to complete the required documentation, preplans, and community assessments. Tell them there is a lot we can do to provide emergency responder safety, which they have failed to even address. Tell them they failed to use the full negotiated rulemaking process. Tell them our communities cannot support or afford this proposal as written. Tell them we are willing to work with them to develop a standard that will be good for all of us.
There are many organizations working overtime to get this message across, but OSHA needs to hear from you. There are also organizations lined up to tell OSHA why this is the greatest thing since sliced bread. They have already provided both written and verbal testimony. If we fail to tell our story, theirs will overshadow us.
We are all for reasonable, necessary, well negotiated, changes to emergency service. It is time we roll up our sleeves, do some serious work, and make things safer for everyone. What is currently on the table is a good foundation to start from, but it needs modifications to have the desired outcome.
We cannot stress the importance of taking this opportunity to be heard.
The deadline to sign up to testify during the OSHA informal hearing in November is quickly approaching. You only have until September 27th to reserve your spot. Many concerns have been expressed by the nearly 4000 written comments that were submitted during the written comment period. So, if the concerns are already on the table in writing why is it important for us testify virtually? It is important because written words are just that, written. We now have the opportunity to add faces and emotions to the words. We need OSHA to look us in the eyes and understand we are real humans, and these are real concerns. We are asking every fire department, EMS agency and municipality to sign up at least one person to give either 5 or 10 minutes of testimony. Surely each of us has one person in our organization that is well spoken and can speak on your behalf. Find that person and get them registered. We will be hosting a number of webinars prior to November to help them organize their thoughts, but they can’t testify if they don’t sign up by September 27th.
Here are some major concerns:
Please sign up to testify and let OSHA know that we are we are 100% in favor of emergency responder safety, but we feel that as written, this proposal is not the answer and we are willing to help produce a better alternative,
