Most comments regarding the OSHA Emergency Response Standard have focused on several key issues, including:
Clarity and Scope of the Standard: Many commenters have expressed concerns about the clarity of certain provisions, particularly regarding the scope of the standard. There has been confusion over how the regulations will apply to different industries and whether they will be appropriate for both large and small employers, as well as varying workplace environments.
Training and Certification Requirements: A significant number of comments have addressed the proposed training and certification requirements for emergency responders. Employers have raised concerns about the feasibility of implementing comprehensive training programs, particularly in industries with a high turnover rate or limited resources. There is also discussion about whether the standard’s training requirements are too stringent or would impose unnecessary costs on businesses.
Cost Implications and Economic Impact: Some commenters, particularly from business and industry groups, have expressed concerns about the economic impact of the proposed standard. These comments often focus on the costs associated with compliance, including investments in new equipment, employee training, and ongoing record-keeping requirements. They argue that these costs may disproportionately affect smaller employers and may be difficult to absorb without compromising business operations.
Feasibility of Emergency Response Plans: Employers have raised concerns about the practicality of developing and implementing detailed emergency response plans as required by the proposed standard. Many have questioned whether the level of detail required for plans is achievable for all types of workplaces, especially those with dynamic or hazardous work environments.
Personal Protective Equipment (PPE) and Resources: Several comments have addressed the proposed requirements for emergency responders to have specific personal protective equipment (PPE) and other resources on hand during emergencies. Comments have varied between concerns over the cost and availability of suitable PPE, and the need for flexibility in selecting the most appropriate resources depending on the specific type of emergency response required.
Workforce Size and Emergency Response Capacity: Many comments have pointed out that the requirements may not take into account the diversity of workplace sizes. Smaller companies, in particular, have raised concerns about the practical challenges of ensuring adequate emergency response capacity without the same resources as larger organizations.
These comments reflect a range of perspectives, with many advocating for revisions to make the standard more adaptable, clear, and economically feasible while still maintaining a strong focus on worker safety during emergencies. OSHA will consider this feedback as it works toward finalizing the rule.