Wednesday, February 14, 2024

Review - OSHA Emergency Response Standard NPRM – Part 3 – Risk Management Plan

Earlier this month, the DOL’s Occupational Health and Safety Administration (OSHA) published a notice of proposed rulemaking in the Federal Register (89 FR 7774-8023) on “Emergency Response Standard”. This is the third part of a series of articles looking at that complex rule making. Here, I will look at the requirements for WERE’s and ESO’s to establish a risk management plan in the proposed 29 USC 1910.156. Specifically, this looks at the proposed §1910.156(f).

Earlier articles in the series included:

Overview, and



The following terms defined in the proposed rule that are pertinent to this discussion include:



Risk Management Plan

The new paragraph (f)(1) proposed by this NPRM would require “WEREs and ESOs to develop and implement a written comprehensive risk management plan [RMP] based on the type and level of service(s) that would be established in proposed paragraphs (c) [WERE] and (d) [ESO] [links added] of the proposed rule.” Based upon NFPA 1500, Standard on Fire Department Occupational Safety, Health, and Wellness Program, the RMP would be designed to “ensure that risks to the team members' and responders' health and safety have been identified and evaluated, and a control plan has been developed and implemented by the WERE and ESO in a manner that mitigates or reduces the risk to a level that is as low as reasonably practicable”.


For more details about the risk management plan requirements, see my article at CFSN Detailed Analysis - - subscription required.

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