Dear Assistant Secretary Parker,
On behalf of the Employers Emergency Response Rulemaking Coalition (“Coalition”), I am submitting the following comments on the Occupational Safety and Health Administration’s (“OSHA”) Notice of Proposed Rulemaking (“NPRM”) for a new “Emergency Response Standard,” to replace the existing “Fire Brigades Standard,” 29 C.F.R. § 1910.156, Docket No. OSHA-2007-0073, published in the Federal Register on February 5, 2024.
INTRODUCTION
The Employers Emergency Response Rulemaking Coalition is composed of a broad array of industries impacted by OSHA’s proposed rule. The Coalition is comprised of multiple organizations, including trade associations, representing thousands of facilities located across the United States. Included among its members are companies in petroleum refining, chemical and petrochemical manufacturing, liquid terminal operations, agriculture, aerospace and defense, and other industries. Coalition members are leaders in safety and privately embedded emergency response programs that have a substantial interest in the outcome of OSHA’s rulemaking, as it will have a significant impact on how they manage such programs.
For years, Coalition members have voluntarily implemented effective emergency response programs. In that time, our members learned valuable lessons about the practices and policies that most effectively prevent and mitigate risks to our emergency responders. The comments we share represent the collective wisdom of employers and the employees who respond to emergencies. Our objective is to ensure that OSHA’s Emergency Response Standard effectively protects the safety and health of employees, volunteers, and the surrounding community, utilizing the most reasonable set of requirements possible.
Attached below is a copy of the full comments.