I addressed the Albany County Legislature.

Standing up for our Volunteer Fire Departments and volunteer fire fighters.

—COPY OF LETTER SENT—

 David R. DeCancio, Bethlehem Town Board Member

Ddecancio@townofbethlehem.org

May 2, 2024

Occupational Safety and Health Administration                                                                         

 Via electronic submission only www.regulations.gov

 RE: Agency: Occupational Health and Safety Administration

 Docket No. OSHA-2007-0073 Notice of Proposed Rulemaking  

Docket ID OSHA-2007-0073

Dear Occupational Safety and Health Administration,

My name is David DeCancio and I am a Bethlehem Town Board Member representing approximately 36,000 residents served by Volunteer Fire Departments. On behalf of our brave and selfless volunteer firefighters and our community I would like to express my concerns regarding the implementation of the proposed Emergency Response Standard (“ERS”) cited above, and will highlight the significant impact they would have on our already struggling volunteer fire departments and their members.  

Talk to any volunteer fire department and you will hear the same thing  “We are struggling to recruit new volunteer firefighters and our numbers are dwindling” In fact, The Firefighters Association of the State of New York (FASNY) says it’s getting to be a crisis.

We all agree that the intent to modernize fire safety and emergency response standards is commendable but, it must also consider the practical implications these new standards will have on our volunteer-based fire departments, like the ones here in the Town of Bethlehem.   

The proposed updated standard would issue several new requirements that would be very burdensome, and in many cases nearly impossible for volunteer fire departments to comply with. Specifically, there would be prohibitively restrictive standards on physical exams, the purchase of new equipment, and the formation of emergency plans that exceed the staffing capabilities of many volunteer departments. 

I would like to highlight some of the concerns raised by our local Fire Officials in a 4/24/24 Spotlight Newspaper article, “Fire chiefs object to new OSHA training requirements”https://spotlightnews.com/news/2024/04/24/fire-chiefs-object-to-new-osha-training-requirements/

• Albany County Fire Coordinator Gerald Paris, Jr stated …that although the changes may be 40 years overdue, the problem is OSHA “is trying to make 40 years of change in just two years.  The changes are not achievable for volunteer firefighters within the timeline.”

   

• Selkirk Fire Department Chief Thomas Neri said all 12 Selkirk command staff officers would be disqualified to serve. and … Impact on experienced non-command staff firefighters also runs high because some pre-2002 training will not qualify.  “More senior firefighters will have to start training all over again.”  Neri said. “Firefighters with years of experience will be sidelined.”

   

• Slingerlands Fire Department Chief Craig Sleurs “A lot of the changes are good changes, so I’m not saying they’re bad, but to put them all on at one time and make us do that [is a problem].”  Sleurs also said that the regulations fail to take into account that many departments are already handling these safety issues in their own way or issues, like fatalities, have not occurred.  “I think they’re trying to wear us out,” 

The challenge lies in balancing the need for updated safety standards with the operational realities and limitations of our volunteer fire departments. And based on the concerns raised by our local volunteer fire fighters the complexities of some of the proposed OSHA revisions as written, will place even further strains on their struggling volunteer fire departments and their ability to retain and recruit new volunteer fire fighters.

The real-life impact of these OHSA revisions could very well be: fewer volunteer fire fighters available to respond to emergency calls and/or the forcing communities like ours to consolidate volunteer fire departments which would result in longer response times or worse yet, force us to shift to paid fire operations and further burden local property taxpayers.

I hope that you take into consideration the concerns being raised by volunteer fire departments and fire officials and work with them to ensure we modernize fire safety and emergency response standards in a way that ensures the viability of volunteer fire departments and keeps our first responders safe.  

With kind regards, I am,

Sincerely,

David R DeCancio                                                                           

Bethlehem Town Board Member