OSHA Emergency Response Standard
Worker Health & Safety

Issue Summary:

OSHA is preparing to initiate rulemaking for an Emergency Response standard, which would replace in the existing Fire Brigades standard (29 CFR 1910.156) and expand roles covered beyond industrial fire brigades to include workplace emergency response teams, plant emergency organizations and others.

Some of the potential concerns with the new standard include:

  • Extensive medical testing and fitness requirements
  • Behavioral and mental health screening mandates
  • Equipment requirements

Additionally, there is potential for duplicative or conflicting requirements with other standards like Process Safety Management of highly hazardous chemicals (PSM), and Hazardous Waste Operations and Emergency Response (HAZWOPR), which specialty chemical manufacturers already adhere to.

Business Impact on the Specialty Chemical Industry:

A more rigorous and onerous standard would add complexity and costs for facilities that have industrial fire brigades and plant emergency response teams. Additionally, requirements put in place by the new standard could conflict with existing OSHA and EPA accident prevention requirements.


SOCMA supports an Emergency Response Standard that protects the health and safety of employees who participate in emergency response activities while ensuring that standard does not cause new regulatory burdens or operational uncertainty.

  • While SOCMA strongly supports worker health and safety, regulations should appropriately protect workers without being burdensome or overly prescriptive. Holding volunteer industrial fire brigades to the same standards as professional firefighters’ risks being overly protective given that the level of risks is not equivalent.

Current Status of Standard:

In late 2022, OSHA moved the proposed Emergency Response standard to its short-term regulatory agenda, indicating that the final rule will likely be published before the end of 2023. OSHA may continue to hold informal listening sessions or conduct other stakeholder outreach, so SOCMA will monitor and engage as the rulemaking progresses.

SOCMA Advocacy Activity:

  • March 2019: SOCMA participates in OSHA briefing on Fire Brigade Standard, the precursor to Emergency Response Standard
  • September 2021: SOCMA member companies participate in SBREFA small business advocacy panel, sharing concerns and potential impacts to specialty chemical manufacturers the standard will have
  • October 2021: SOCMA member companies provide comments emphasizing potential impacts following small business advocacy panel
  • July 2022: SOCMA educates and informs OSHA on unique impacts and needs of specialty chemical sector on emergency response
  • March 2023: SOCMA continues advocacy efforts to educate OSHA on emergency response standards
  • April 2023: OSHA participates in SOCMA Town Hall Series to discuss emergency response standards with member companies.

Contact SOCMA’s Government Relations team for more information and assistance on how the Emergency Response standard impacts your chemical manufacturing facility: government.relations@socma.org.

DISCLAIMER: This document was prepared by the Society of Chemical Manufacturers and Affiliates (SOCMA) and is disseminated for informational and educational purposes only and is not intended as legal advice and does not create any legal relationship or responsibility between SOCMA and user.

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