IFA OSHA Response
The Iowa Firefighter Association (IFA) is a non-profit association that was organized in 1879. It represents and advocates for the improvement of the Iowa Fire Service to improve protection of the public in our communities. We do this through legislation, better training, minimum standards for apparatus and equipment, fire prevention, public relations, and information programs.
The IFA would like to take this opportunity to comment on behalf of its members, generally, in opposition, regarding the proposed OSHA regulations for fire service. The call/volunteer fire departments, and many combination fire departments (especially those in small towns that are still predominately volunteer organizations) lack the resources in money, staff, and administrative capabilities to implement most of the proposal.
Iowa has approximately 850 fire departments statewide. Of those; 92% are volunteer departments, much higher than the national average of 70%, according to the U.S. Fire Administration. Of these departments, approximately 68 of them are career fire departments, 782 of them are volunteer or a combination fire department (using both paid on call/volunteers).
The volunteer departments of Iowa serve the small communities that have a population of less the 2500 people and are largely a rural community. These comments will focus mainly on how the proposed rules will impact those departments; however, the comments will have varying levels of applicability to the larger volunteer and combination departments. The profile of a typical call/volunteer fire department in Iowa rural town of 2500 people or less is as follows:
20 Call or Volunteer Firefighters on Staff
0 Part-Time Firefighters on Staff
0 Career Firefighters on Staff
Has an annual budget of $74,932.
Spends $2926 per year on training.
Provides EMS First Response/First Aid – Provides no Ambulance.
Lack of Financial Resources:
Operating with an average total budget of about $75,000 per year, all these fire departments barely subsist and have no financial capacity to do anything more than what they did in the prior year. These departments struggle to pay for fuel, maintain their trucks and building, and purchase basic replacement gear and supplies to provide protection for our responders.
Departments are funded by townships by the Iowa Code §359.43. Where township has a fire protection service or emergency medical service agreement or both service agreements with a special charter city or independent fire department may levy an annual tax not exceeding $0.54 cents per $1,000 of assessed value of the taxable property. This funding was created in the 1970s and has not been adjusted since that legislation was passed not keeping up with inflation.
A typical fire department budget from a town of 1500 residents would look like this:
Utilities $18,130 (Heat, Electric, Water, Propane, Etc.)
Office Expenses $7720
Gasoline/Diesel $4000
Fire Equipment $12,000 (Repairs, Replacement & Maintenance)
Radio System $4500
Total $108,000
All of these small departments attempt to supplement their budgets through fundraising activities such as pancake breakfast, spaghetti suppers, chicken barbeques, fishing derbies, car shows, raffles, and boot drives (begging on the side of the road). Unfortunately, these efforts consume enormous amounts of time by the volunteers and generate small sums of money. The cost in effort doesn’t warrant the benefit in terms of extra money, but they are left with no real alternative. (In a town of 1000 people, a spaghetti supper might have a net profit of $500 – not enough money to purchase two fire helmets.) These fire departments can barely afford to maintain an inventory of structural firefighting Personal Protective Equipment (PPE) for 15 to 20 firefighters. The cost of PPE is the same for a volunteer firefighter in a town of 500 people as it is for a career department firefighter. The lowest cost structural PPE ensemble we can find today in Iowa is as follows:
Helmet: $327
Structural FF Coat/Pants $3500
Suspenders $41
Structural FF Boots $550
Firefighting Hood X2 $52 ($26 each)
Structural FF Gloves X2 $136 ($68 each)
Personal Pass $600.00
SCBA $9000
Total Structural PPE Ensemble Cost: $ 14138.00 per firefighter
The cost of a single set of structural PPE is roughly 200% of what these fire departments are receiving in annual budget increases. Many departments are spending about $6000 per year or 8% of a typical small town fire department budget to replace two sets of structural FF Coat /Paints each year, and maintain an inventory of 20 sets of PPE that are less than 10 years old and in compliance with all the applicable NFPA standards. Small department budgets are thrown into a chaos when a new person joins the volunteer department, and the department doesn’t happen to have a set of PPE that fits them. They must purchase new PPE; with money they can’t afford to spend. And the delivery time for new structural firefighting coats and pants is running 6 to 12 months. On-boarding one new volunteer is a financial crisis. And this comes at a time when call/volunteer fire departments are struggling to recruit new members. All of these small departments are understaffed and need new members. The worst position they can be in is to have new members and not have the money to equip and train them. The impact of these proposed OSHA regulations will do just this kind of damage to these departments. An important point of this example is that having NFPA compliant PPE for each firefighter is important and something all of the fire departments strive to do. If the proposed OSHA rules simply incorporated having compliant PPE (per NFPA standards) into our work rules, while it would cause some financial difficulties in the smallest departments, it would be something we (as an industry) could figure out and make work to protect our communities . The problem is that everything else proposed in the rules cost even more, and there is no money to pay for it.
A second important point to remember is that small and very small towns need the same number of firefighters to fight a fire as big suburban towns. In order to initiate fire attack on a small fire in a bedroom, you need six firefighters as follows:
Two Firefighters on the Attack Team (advancing the hose & extinguishing the fire).
Two Firefighters on the “Two-Out” Safety Team (or Initial RIC/RIT).
A pump operator (aka engineer or driver-operator).
An Incident Commander (IC).
It doesn’t matter if you are in a town of 500 people or a town of 50,000 people. The cost of training and equipping those six firefighters are the same. No vender or manufacture gives you a break because your town has only 500 people in it. Both the volunteer fire department serving the town of 500 people and the career fire department serving the town of 50,000 are likely to both have twenty-four firefighters to train and equip. The problem arises when you divide the cost of PPE for twenty firefighters among 500 residents, verses 50,000 residents. For example:
Twenty-Four (20) Sets of PPE = $ 282760
Divided by 500 residents = $565 per resident
Divided by 50000 residents = $5.65 per resident
The impact of the proposed OSHA rules financially burdens small towns to a much greater degree that larger communities. The difference in the financial burden is extreme. Many of the small departments that it will be affected are in the rural area supporting the agricultural industry. The people living in these small and very small towns cannot afford more taxes for their fire departments (or anything else). OSHA’s proposal estimates that the cost of implementing the medical exams for firefighters is about $629 per firefighter. Even spread over two years (as many of these small departments may be allowed to do under the proposed rules) the cost for a department with 20 volunteers is $12,580 per year. This is duplicating a process that many people have physicals with their own doctor supported by their employer or insurance.
Setting aside the financial costs of implementing the proposed rules, there is also an administrative burden that cannot be met by these fire departments. None of these small and very small-town call/volunteer fire departments have any administrative staff whatsoever. These departments are led by a volunteer, or part-time fire chief who does most of his/her administrative work at their kitchen table, after having worked at their full-time, primary job. These chiefs are overwhelmed with administrative work and a close look at many of these departments finds they are routinely behind on administrative matters, or simply don’t do any administrative work beyond such tasks as paying the bills, scheduling training, and writing fire reports.
These departments do not have access to planning staff, data analytics, financial managers, file clerks, and IT staff. This means that strategic planning is almost impossible. It means that any comprehensive use of data is almost impossible. Unlike large suburban and urban organizations, these departments generally lack the ability to conduct a community risk analysis, generate a critical task analysis for incidents in their town, or develop standards of cover. It is not that they don’t want to be able to do these things, but they have no staff to do it. Instead, these departments are forced to rely upon generic plans. They must forego anything but the minimum required incident reporting. And it not just a fire department problem. The towns themselves have limited and sometimes no resources. These towns are run by volunteer elected officials and part-time staff. The typical town hall is maybe open 20 or 25 hours a week.
The town has a part-time administrator town clerk that could be full time but most cases they are part time clerk with no skill set in analyzing fire risk. This means that there is no administrative, planning, or analytical staff available at the town level to support any new fire department planning or compliance requirements. (And Iowa has no significant county government functions that can fill this gap.) If OSHA requires a community risk analysis be created, reviewed, and annually updated, there is nobody to do this. There is nobody to administer a health and wellness program. Additionally, the fire chiefs themselves don’t generally have the skill sets needed to fill these administrative and strategic roles. Most of them don’t have management or financial backgrounds, they come from a lot of technical trades. They were chosen because they were good at managing emergency incidents, not budgets, strategic plans, or data analysis. It’s unlikely they have significant formal education in public administration. This places the small-town chief at a major disadvantage over his/her suburban and urban counterpart when it comes to implementing a new set of rules as lengthy and comprehensive as what is being proposed. Urban and large suburban department chiefs have better access to staff with the skill sets needed to read, analyze, and develop a strategic compliance plan, and they have the more staff to monitor and update the plan.
Macro Difficulties
There are handful of large, macro, requirements in the proposed rule that would have a substantially detrimental effect on small town fire departments in Iowa. They are:
Apparatus Inspections:
The proposed OSHA rule would incorporate by reference NFPA 1910, Standard for the Inspection, Maintenance, Refurbishment, Testing and Retirement of In-Service Emergency Vehicles. This rule would require that all fire apparatus is inspected weekly or within 24-hours of responding to an emergency. Inspections would have to be conducted by staff who are trained in DOT and chassis inspection. The rule will require periodic comprehensive, diagnostic inspections of up to 70 components (not all trucks have all 70 components). To the best of the IFA’s knowledge, no fire department in Iowa is currently doing truck inspections to the extent called for by NFPA 1910. And there is no significant risk of injury or death that requires OSHA to mandate how departments conduct truck inspections and maintenance. The most current firefighter fatality data from the US Fire Administration for the year 2021 indicates that twelve (12) firefighters were killed in motor vehicle accidents in 2021. In ten of the twelve crash fatalities there is no possibility that the crash and death was the result of a mechanical failure of the fire apparatus (due to failure to inspect or maintain it properly). In these cases, the deaths were in a result of failing to wear seat belts, collisions with tractor trailer trucks, going through stop signs, and other driver errors. In one case, two deaths were in a roll-over of a tanker and there is no determination of the cause. Data from other years shows the same pattern. From 2013 to 2022, ninety-seven firefighters died in crashes, but only four of those deaths can be attributed to any kind of vehicle mechanical failure. Here’s what the factual data tells us about firefighter deaths in vehicle crashes from 2013 to 2022:
6 deaths with an unknown cause of the crash.
35 deaths in crashes involving a collision without any mechanical problem.
Intersection collisions, struck by drunk drivers, driver error, etc.
28 deaths in private vehicles (Not subject to NFPA 1910).
4 deaths because of a mechanical failure to a fire truck.
21 deaths in aircraft, ATVs, and being struck by a fire truck.
Half of these deaths were not even in fire trucks,
If NFPA 1910 is adopted, at best, it might have prevented four deaths over ten years. The four deaths occurred as follows:
In 2016, three firefighter deaths resulted from two separate crashes. Both crashes were the result of tire failures.
One firefighter died in a crash that was a result of a transmission transfer case failure while the truck was returning from a repair facility. The crash resulted in a recall by Navistar Inc. for International 4800 trucks built between June 1999 and May 2002 equipped with Fabco TC-200 transfer cases.
A Summary of Hazards identified by OSHA During Fatality Investigations, it is stated that 29 firefighter deaths or 10.6% of firefighter deaths are attributable to “Vehicle Preparedness and Operation”. Combining vehicle preparedness deaths and vehicle operation deaths is inappropriate and results in an inaccurate view of the situation. If the data was separated into two categories, vehicle preparedness and vehicle operations, then the data clearly indicates that the overwhelming number of deaths in this area result from vehicle operations and have no nexus to vehicle preparedness (such as weekly inspections). Therefore, it is not necessary for the federal government to require strict compliance with NFPA 1910 (FKA NFPA 1911) to prevent firefighter deaths and injuries. There is no national fire apparatus mechanical inspection or maintenance safety problem. The data does not support the need for federal OSHA action. And even if it did warrant OSHA action, the proposed solution fails to pass any cost-benefit analysis in terms of time and money to implement. Employee safety will not be improved by any measurable standard if this rule is approved.
Administrative Burden:
An unpaid, volunteer fire chief would be expected to spend the equivalent of a month’s work to initially implement these proposed rules. Given everything else this chief is doing without pay in his/her spare time, this is an undue burden given the expected outcomes, and lack of data supporting the need for much of this regulation in small and very small towns. For a part-time chief, who is paid stipend or annual salary, this moves his/her pay for the job to pennies on the hour. The one-time implementation of these rules would require a full month’s full-time work to understand and implement. And this assumes the chief doesn’t have do anything else that month such as his/her full-time job, respond to emergency calls, or otherwise administer the department in all other areas. Worse is the annual time needed for compliance. Volunteer and part-time chiefs would be expected to put in 376 hours or 9.4 weeks of full-time work each year to comply with the rules. This would be in addition to what they currently do to administer their departments and respond to emergency calls.
Then OSHA has estimated this task will take fire chief two hours to familiarize themselves with the new rules. The proposal document is 250 pages long. The chief will have read through a dozen or more NFPA standards. It seems unrealistic that anyone is going to be able to familiarize themselves, in any meaningful way, with how this document changes the organization and operations of their fire department in two hours. The proposed rules are too much, too fast. The chief getting a $542 per month stipend is woefully underpaid to do this work, and the unpaid volunteer is simply being abused. Nobody will do the job of volunteer or part-time fire chief under these conditions. If all of these proposed rules are enacted, how many firefighter deaths and injuries are going to be prevented in towns smaller than 1000 people, and what is the cost-benefit analysis to support the rules?
Overreach:
Some of the NFPA standards being incorporated into these rules have elements that lack a nexus to employee/firefighter injuries and deaths. While not a complete list, here are some examples:
NFPA 1021 – Officer Training:
The proposed rule will require that all fire department officers must have training that meets the NFPA 1021 Standard. Some of the topics required by this standard have no bearing on or only a remote bearing on firefighter deaths and injury. Some of these topics are:
Preparing budgets
Developing a financial management system
Answering Public Inquires
Purchasing and Finance (Public Bidding)
Writing Media Releases & Administering Public Relations Programs
What is the significant risk of death or injury that OSHA hopes to mitigate by requiring every fire officer in the United States to have training to write media releases, manage budgets, or provide for ADA accommodations, especially if these areas are not within the normal scope of their job?
It is not within OSHA’s authority to require training that is not related to workplace deaths and injuries. It would be better if OSHA were to limit the requirement for officer training to those topics more aligned or related to preventing deaths and injuries. Additionally, officers in small, typically volunteer, fire departments do not have responsibility for these, and other topics contained within the NFPA 1021 standard. It will be inappropriate to require training for employees on topics that are beyond the scope of their jobs. (NOTE: It is important to understand that when NFPA standards are used as “best practices” the fire chief (AHJ) has the ability to modify the standard as it pertains to their fire department’s resources and needs. For instance, fire officers would receive training that is equivalent to the NFPA 1021 standard, to the extent it is part of their job. A volunteer fire department officer does not need training regarding collective bargaining agreements, because there are no collective bargaining agreements at volunteer organizations. Making the NFPA 1021 standard (and other standards) legally required, as written, is not appropriate because they were not designed to implemented exactly the same way by each department. One size does not fit all. The standards themselves contain language that allows for modification, by the AHJ, based upon local needs and resources.)
NFPA 1140 – Wildland Fire Training:
OSHA’s proposal calls for training all wildland firefighters to NPPA 1140, Standard for Wildland Fire Protection. This will require a great deal of unneeded training for primarily structural firefighters. NFPA 1140 defines “wildland’ and “wildland fire” as follows:
Wildland: Land in an uncultivated, more or less natural state and covered by timber, woodland, brush, and/or grass.
Wildland Fire: A fire that originates in or extends to vegetative fields and that can involve structures or other combustible materials.
It then goes on to essentially say that the standard applies to firefighters who respond to wildland fires (among other things). By these definitions almost all firefighters are wildland firefighters and must meet the standards of Wildland FF I, Wildland Fire Officer I, Wildland FF II, and Wildland Fire Officer II. The standard makes no distinctions for the size and frequency of wildland fires handled by the fire department, nor their risk to the community. A 10’ x 10’ roadside fire that a structural engine company would easily extinguish with no specialized equipment, specialty PPE or wildland specific training is treated the same as the 829,900-acre Lime Complex Fire in Alaska in 2022. In practice, there is clearly a difference between structural firefighters who extinguish frequent small brush fires or the occasional larger fire, and true wildland firefighters. The OSHA rules need to distinguish between the two groups so that structural firefighters aren’t required to meet NFPA 1140, as is beyond their normal scope of operations, and there is no data showing that this additional training is necessary for their safety.
It should be noted that Firefighter 1 training (NFPA 1010) includes basic wildland firefighter that is appropriate and sufficient for most structural firefighter extinguishing small or infrequent wildland fires. And among those departments that may handle some larger wildland fires or respond to them more frequently, but are still primarily structural fire departments, there should be some tiered level of training based upon the nature of their jurisdiction’s wildland fire frequency, size, and risk.
FF I has enough training for a structure fire department in Iowa to handle a wildland fire with this training it does not warrant the full scope of training required by NFPA 1140, as would be required under the proposed rule. Additionally, the data suggests there is no significant risk of death and injury to firefighters requiring OSHA intervention. In 2023, there were thirteen firefighters killed in the line-of-duty related to wildland firefighting. The ten-year average for wildland related line-of-duty deaths is ten (10) firefighters. A look at the causes of the deaths clearly shows no nexus to wildland fire training. The deaths were as follows:
4 Medical Deaths o All apparent heart attacks
4 Vehicle Crashes
One crash in a private vehicle
Two ATV/UTV crashes
Single Vehicle Crash
3 Aircraft Crashes
1 Firefighter Struck by a Falling Tree
1 Firefighter Killed by Contact with an Electrical Powerline
OSHA proposed solution to firefighter deaths is requiring training that would not have prevented any of these deaths. With an average of ten deaths per year, most of which have no nexus to insufficient training, does not seem to represent a significant risk requiring OSHA intervention, and even if it does, the solution, requiring extensive additional wildland firefighter training to a wider range of departments, will not address the reasons that most wildland firefighters die.
This requirement also touches on an important point – one size does not fit all. In this case, wildland fire training in one part of the country is not the same as other parts because from one part of the country to another the topography is different, the size of the fires is different, the type of fuel is different, the speed and ease of access to fight the fire is different, the community risk is different, and frequency of significant fires is different. Local jurisdictions need to be able to modify NFPA 1140 to match the situation in their area. For instance, fire shelter training will be required for all firefighters who respond to wildland fires (defined as a fire in forests, woodlands and not in buildings). Almost every fire department responds to some wildland fires that meet this rather broad definition. Most of these are small fires – mulch, roadside, and less than an acre in size. There is no need for wildland fire shelters at these fires. This is a waste of training time and will not improve worker safety. Additionally, the nature of wildland fires in the northeast is very different from the west. Fire shelters are not typically used for the small brush fires that most fire departments deal with in the northeast. Has there been a fire shelter deployment or the need for a fire shelter deployment in the northeast in the twenty years? One size does not fit all.
And OSHA provides no cost analysis for providing this training to small volunteer fire departments that routinely respond to a small number of wildlands fires each year. There is no cost-benefit for this proposal.
Inspection & Maintenance:
Almost the entire standard is an over-reach. There is no data that the inspection and maintenance of fire trucks are resulting in FF deaths and injuries. Much of this has been discussed above, however, we would like to comment on three specific areas within NFPA 1910 as follows:
All fire apparatus will be required to have an annual axle weight test. (NFPA 1910) This not simply weight the truck but weighing each individual axle. Almost no fire departments in Iowa, particularly those in small towns or more isolated rural communities have access to the required certified scales that can weigh individual axles. For many of the small and very small departments in Iowa, having volunteers available to do this is difficult.
Overweight trucks should not be allowed. But, annual weighing of fire trucks is not the solution, especially since there is no data indicating how many trucks are overweight. There is no data indicating a significant risk based upon overweight fire trucks. And, if there is, weighing trucks annually is the most administratively burdensome and most expensive solution available. OSHA could be asking us to weight thousands of trucks to identify a handful of overweight vehicles. Rules requiring that fire apparatus meet the manufacturer’s weight requirements with a requirement that they be weighed when put in service and then again whenever they are altered or substantial equipment is added, would address the issue. If a truck is weighed and then no changes are made over the course of the year, the weight won’t change.
The proposed rules will require the annual testing of fire apparatus brakes (NFPA 1910). Each department will be required to layout a test course with a start and stop line (40’ away for most trucks), drive each truck at 20 mph at the start line, and hit the brakes when the front bumper crosses the line, and then measure the stopping distance to see if it conforms to the chart in the standards. To the best of our knowledge, not a single fire department in Iowa is currently doing this. This is not a normal or accepted practice.
Where is the data indicating fire truck accidents and injuries to firefighters because of poor brakes? Truck dealers/maintenance facilities don’t offer this testing as a service. For a small department with a handful of volunteers to set this up and run it is asking for a lot of effort for no defined gain.
IFA believes that there no significant risk of death or injury to firefighters because departments are not annually testing the brakes for their trucks in the is manner.
Truck tires will have to be replaced every seven (7) years (or sooner if the tread is worn out). This is good practice, but it is unclear where the seven (7) year time limit comes from. Even assuming there is science or data to support the seven-year time limit.
Is there a significant risk of firefighter death and injury due to old tires on fire trucks? Firefighter line-of-duty death data from the past decade shows four (4) deaths resulting from three fire truck crashes where the truck’s tires were identified as the cause of the crash. This doesn’t seem to rise to the level of risk that requires Federal OSHA intervention.
Does OSHA Have a Case Requiring New or Additional Federal Regulation? Generally, No. In its proposal for these new regulations, OSHA seems to say that the fire service has failed to address firefighter injuries and deaths on its own, and therefore, OSHA must step in with regulations. And in a few narrow areas that may be true, but data suggests that in the broader context this statement of need by OSHA is not accurate. Firefighter injuries are declining without OSHA’s involvement. From 1981 to 2022, overall firefighter injuries have declined from 103,340 injuries (1981) to 65,650 injuries (2022). This is decrease of about 36%. Fireground injuries (a subset of the above data) has dropped from 67,500 injuries in 1981 to 21,325 injuries in 2022. This is about a 68% decrease.
Firefighter line-of-duty deaths are also declining without OSHA regulation. There were 136 firefighter line-of-duty deaths in 1981 and 96 deaths in 2022. It is also important to note that the methodology for counting firefighter line-of-duty deaths has substantially changed since 1981 to include more deaths. In 2003, we started to include certain heart attacks and strokes that occurred off-duty. These are known as “hometown hero’s” deaths with the data sets starting then. And more recently, COVID-19 deaths were added to the line-of-duty death roles.
Without these two new categories being added to the line-of-duty death definitions, the number of firefighter line-of-duty fatalities would have dropped from 136 deaths in 1981 to 73 deaths in 2022. This represents a 46% decrease.
In some narrow areas, such as cardiac deaths and deaths from not wearing seat belts, there is case that can be made for some new regulation. For instance, requiring seat belts when responding to and returning from incidents, could save five or six lives per year, without spending money or creating new administrative burdens. A cost-benefit analysis works for this, even if it is a small number of fatalities. (Does it reach OSHA mandate regarding “significant risk”?) More importantly, cardiac screening, could result in up to 40 fewer deaths per year. This is almost half of all firefighter deaths in a typical year. OSHA should seek a financially less expensive cardiac screening method and less administratively difficult to deliver method than requiring NFPA 1582 medical exams.
Additionally, the data says that small communities have fewer injuries than larger communities. This means that small and very small towns should not have to meet the same health and safety rules as large urban communities. One regulation cannot cover all there has to be a way to adjust to the need in the situation.
Behavioral Health & Wellness Programs
A substantial part of the OSHA proposal would require all fire departments to provide a behavioral health and wellness program to all firefighters. It is unclear what is OSHA’s goal or need for mandating behavioral health and wellness programs, particularly in the half of the fire service in very small towns. There is a great deal of discussion in the fire service about firefighter suicide, PTSD, stress, and other behavioral/emotional health. However, there has been very few studies and there is almost no data telling us the nature and scope of these problems in small town, primarily volunteer, fire departments.
There is no objective studies or science to help guide them in choosing a vendor and a program that works for them. Small departments with no administrative staff, they have to rely on outside sources to provide these kinds of services. Requiring a wellness program for these small departments is likely to end up with towns finding the least expensive way to “check the box” and meet the regulation, regardless how well the program works. The IFA fears departments spending money on wellness apps, that nobody uses and provide nominal service, simply to comply with the rule. We need know what the problem is before we start mandating the solutions.
Incorporating NFPA Standards
OSHA is incorporating by reference at least twenty-one (21) NFPA Standards into their regulations. This changes the standards from industry best practices into legally mandated practices, but most of these standards are not designed to be absolute as a law. All NFPA standards contain language that allows the Authority Having Jurisdiction (AHJ), typically the fire chief, to adopt the standard in whole or in part, and to modify the standard to fit local needs and resources. If these become OSHA regulations, the fire chief can no longer modify the standard. OSHA seems to assume that incorporating the NFPA standards by reference does not create a burden on fire departments because departments are already using them. This is not the case. Very few departments use NFPA standards in whole, or literally. They almost all modify the standards to fit local resources and needs. The standards are created knowing that chiefs can and do modify them.
While the NFPA standards process is public, transparent, and well run, much of what makes it into standards lacks scientific validity or solid data to support its inclusion. There is a great deal of opinion in these standards. It has been very beneficial to an organization as it has given them a guide to operation that they are able to organize to work for their situation. Placing it into OSHA regulations burdens them in meeting it to the letter forcing a burden of finance and administration on a volunteer department.
Conclusion
I would like to finish with that the IFA is the Voice of the Iowa Firefighters and want to represents and advocates for the improvement of the Iowa Fire Service. This includes firefighter safety so they may improve emergency protection in our communities.
The new OSHA Regulations will be detrimental to our volunteer departments that make up 93% of Iowa’s Fire services. The cost and time needed to implement these regulations would increase budgets by up to $14,000 and 198 hours of extra administrative time that these departments do not have. Many departments are already struggling with budget short falls and low memberships and we feel the new OSHA regulations will only make it worse causing many small Iowa Departments to close. This will increase response times and workloads for other volunteer departments and leave the public with the danger of slower protection. This runs the risk of lowering ISO ratings and increasing insurance rates for home owners in rural areas.
Sincerely, IFA Board
President
Roger Carr
1st Vice-Present
Aaron Clemons
2nd Vice-President
Kent Brix
3rd Vice-President
Mike Kime
4th Vice-President
Rick Schmidt
5th Vice-President
Lonnie Newhall
Past President
Chuck Raska