October 2025 Update

Joe Palmer, OSHA Ad-hoc Committee chair, provides an in-depth background on the development of the proposed OSHA 1910.156 Emergency Response Standard, the anticipated changes at the federal level, and how South Carolina is getting ahead of the curve. Contact Chief Palmer at [email protected] with questions.

Proposed Standard– Read the proposed Emergency Response Standard in the Federal Register and submit a comment through the public comment portal (deadline was July 22, 2024).

The South Carolina Plan Document

The below attached document represents the latest draft of the proposed South Carolina response to the federal Emergency Response Regulation 29 CFR 1910.156 that was released in December 2023. A great deal work, by hundreds of persons statewide, has gone in to formulating this South Carolina regulation. As South Carolina is a “State Plan” OSHA program, we have a unique opportunity to meet or exceed federal standards in and through the creation of our own plan document which will be certainly more economically and technically feasible than the federal proposal. This represents a draft, drafts change daily. Please download, read, and familiarize yourself with the contents of the applicable subpart for your organization. The intent going forward is to continue to perfect this document, with your help; and ultimately present this the SC LLR/OSHA in late 2026. The state will then begin its own adoption process as regulated by state law.

Read the draft South Carolina State Plan

Timeline

January 2024 — Department of Labor releases the proposed standard

March 2024 — The Executive Committee of the SC Association assigns authors of a position paper

April 2024 — The Executive Committee approves the position paper

April 2024 — The Executive Committee takes the position paper to the federal elected delegation in Washington DC

• Association submitted Position Paper and Formal Response To The Proposed Ruling and Comment Period for the OSHA Regulation

May 2024 — Creation of the web site and education of the membership

May 2024 — The Association creates a fire service study ad-hoc committee from around the state to prepare and respond

June 2024 — The issue is offered at South Carolina Fire-Rescue

July 19, 2024 — The Association posted its official comments

July 22, 2024 — US DOL OSHA public comment period ends

Fall 2024 — The Association enlarges the Ad-Hoc group to include partner/affiliated agencies and organizations

November 7, 2024 — Federal OSHA regulation 1910.156 Statewide Stakeholders Meeting

November 12 through December 4, 2024 — Public testimony on the regulation

• November 19, 2024 - Association provides testimony

January 15, 2025 — Association submitted written reply to public testimony

January 24, 2025 — Stakeholders group meeting during Fire Service Improvement Conference

• State plan is in development

January 29, 2025 — Association submitted Department of Labor Secretary confirmation hearing letter to Senators Graham and Scott

Spring 2025 — The Association's OSHA Ad-Hoc Committee divided into working groups to start a state plan draft. The working groups meet regularly to address the needs of fire, EMS, and private industry in the state plan draft.

August 5-9, 2025 — The OSHA Ad-Hoc Committee held a beta test for Subpart A (fire) to get input from members of the fire service.

Fall 2025 — The beta tests for Subpart B (EMS) are in development.

Winter 2025-26 — Special Operations Subpart C developed and beta tested

Spring 2026 — WERE/Industrial Subpart E developed

South Carolina State Firefighters' Association Action

Our Ad-Hoc Committee and Mission

Our Partner's Position

• NVFC
  • NVFC's website on the subject
  • NVFC 2024 Spring Board meeting minutes
  • NVFC Webinar: Update from OSHA on the Proposed Emergency Response Standard
    • Recording of the webinar in the NVFC Virtual Classroom
    • More comprehensive webinar that OSHA did with the U.S. Fire Administration
  • The Testimony on the Regulation

  • Frequently Asked Questions about the OSHA Proposed Rule

• A Subcommittee on Emergency Management and Technology hearing entitled, “Stakeholder Perspectives on OSHA’s Proposed Rule to Update the Fire Brigades Standard” was held on June 4, 2024. To view this hearing, click HERE. 

What you can do

OSHA's proposed Emergency Response Standard is here, and understanding it is crucial for your safety and  department operations. By staying informed and getting involved, you're able to influence policy that impacts you.

Here are a few steps you can take.

1. Read the proposed standard

First, read the standard. Dive into the details and grasp the full scope of these proposed protocols. Knowledge is power, and being informed empowers you to make a difference.

2. Read the comments

Next, read the comments. See what experts and peers are saying. This is your opportunity to gain insights and perspectives that can shape your understanding and inform your next steps.

3. Contact your state and federal representatives

Then, contact your state and federal representatives. Your voice matters—it can influence policy and ensure that the best practices are implemented. Don't underestimate the power of your advocacy.

Questions?

The hard-working members of the Association's OSHA Ad-Hoc Committee and subcommittees are informed, engaged, and eager to share about the proposed OSHA ruling and what we're doing in South Carolina. These committee members are subject matter experts in their fields and will be who assists in drafting a state plan to address the OSHA changes. We extend an enormous thank you to the OSHA Ad-Hoc Committee for your dedication to the health and safety of South Carolina firefighters.

Members of the OSHA Ad-Hoc Fire Subcommittee:

• Joe Palmer
• Doug Cline
• Charlie King
• Billy Gibson
• Jack Kirlin
• Rick Dangerfield
• Jonathan Jones (or designee)
• Rick Dunn – Staff Liaison