The short answer is YES. This can be a hotly contested debate as there are both paid and volunteer departments that believe they are somehow exempt from basic safety programs. In the state of Ohio (OH) professional firefighters are NOT covered by OSHA since OH is a federal OSHA plan; and volunteers do not fall under OSHA. So in respect to complying with OSHA, both groups are correct. But in many states, including OH, there are worker compensation boards that regulate those workers who fall under the state worker compensation program. In the state of OH we have the Ohio Bureau of Workers’ Compensation; and I might add that EPA also enforces OSHA’s HAZWOPER standard for those responders that fall out of OSHA’s enforcement reach. But lets stay on the myth that OH firefighters are not required to comply with any specific respiratory protection standards…
As we will see below, professional and volunteer emergency responders who are not under OSHA’s jurisdiction MUST INDEED have the same program and meet the same requirements as if they were complying with OSHA’s 1910.134.
emphasis has been added by me
First, to establish the scope of the BWC standard…
4123:1-21-01 Scope and definitions.
(A) Scope.
The purpose of Chapter 4123:1-21 of the Administrative Code (hereinafter “this chapter”) is to provide reasonable safety for life, limb, and health of employees.
The requirements of this chapter are minimum requirements of an employer for the protection of such employer’s employees and no others, and constitute protective standards for all regular members of lawfully constituted fire departments of municipal corporations and townships, whether paid or volunteer, and employees employed in private or contractual-type fire departments that serve the public, who are engaged in the act of fire fighting. The requirements of this chapter do not apply to employees employed in industrial fire brigades, industrial fire departments, and private or contractual-type fire departments that do not serve the public. To the extent that any other codes of specific requirements adopted by the bureau of workers’ compensation may conflict with the requirements of this chapter, this chapter shall prevail.
Here is OH Code 4123:1-21-02 Personal protective clothing and equipment for structural fire fighting.
(P) Respiratory protection.
(1) ALL fire fighters exposed to hazardous atmospheres from fires and other emergencies, or where the potential for such exposure exists, shall be provided with self-contained breathing apparatus (“SCBA”) approved by the national institute for occupational safety and health (NIOSH) and the mine safety and health administration (MSHA).
(2) The fire department SHALL ADOPT and MAINTAIN a respiratory protection program that addresses the selection, inspection, safe use, and maintenance of respiratory protection equipment, training in its use, and the assurance of air quality testing.
(3) ALL members who might be required to use respiratory protection equipment SHALL be medically certified by a physician, or by a state of Ohio licensed health care professional who can perform medical evaluations under the supervision of a physician, on an ANNUAL basis. Medical certification can be obtained by a medical examination, or by using the medical questionnaire as referenced in CFR 1910.134 Appendix C.
(4) The facepiece seal capability of each member qualified to use “SCBA” SHALL be verified by qualitative fit testing on an ANNUAL basis and whenever new types of “SCBA” or facepieces are issued. Each new member shall be tested BEFORE being permitted to use SCBA in a hazardous atmosphere. Only members with a properly fitting facepiece shall be permitted by the fire department to function in a hazardous atmosphere with “SCBA.”
(5) Only “SCBA” with an approved service life of thirty minutes or more shall be considered acceptable.
(6) The following “SCBAs” shall be considered to meet the requirements of this rule:
(a) Open circuit “SCBA” of the positive-pressure type that operate only in the pressure demand mode.
(b) Open circuit “SCBA” of the positive-pressure type, equipped with an air flow control device for doffing and donning purposes only. Such air flow control device shall not permit the continued use of the “SCBA” in the demand mode after donning.
(c) Closed circuit “SCBA” with a rated service life of more than two hours and a minimum protection factor of five thousand, as determined by an acceptable quantitative fit test performed on each individual. Such “SCBA” are acceptable only when long-duration respiratory protection is deemed necessary by the employer. Closed circuit “SCBA” shall operate in the positive-pressure mode only.
(7) Open circuit “SCBA” approved by NIOSH/MSHA for use in the DEMAND MODE or for use in BOTH the DEMAND MODE and the PRESSURE DEMAND MODE are PROHIBITED.
(8) Breathing air supplied for a “SCBA” shall be of at least grade D quality as specified in “Compressed Gas Association Commodity Specification for Air, Pamphlet G-7.1” and shall have a dew point level of minus sixty-five degrees Fahrenheit (minus fifty-four degrees Celsius) or dryer (twenty-four v/v or less) and a maximum particulate level of five mg/m3 air.
(9) Breathing air quality shall be tested QUARTERLY and shall meet the requirements of paragraph (P)(8) of this rule. This shall also apply to vendor-supplied and other fire department-supplied compressed breathing air. The department receiving supplied air shall require the supplier to provide documentation that the air received has been tested quarterly and that it meets the requirements of paragraph (P)(8) of this rule. Written records shall be maintained.
(10) The employer SHALL NOT PERMIT ANY KNOWN INTERFERENCE with the facepiece-to face seal or with the operation of the exhalation valve on the full facepiece of an “SCBA” on employees who are exposed to hazardous atmospheres from fires and other emergencies or where the potential for such exposure exists. (This is where facial hair is NOT allowed!)
(11) Respiratory equipment shall be inspected, maintained, and repaired in accordance with the manufacturer’s recommendations. Maintenance shall include at least:
(a) A written record of such inspection and maintenance for each piece of equipment.
(b) Regulator calibration performed by a manufacturer-authorized person at no more than twelve-month intervals.
(12) Approved self-contained compressed air breathing apparatus may be used with approved cylinders from other approved self-contained compressed air breathing apparatus, provided that such cylinders are of the same capacity and pressure rating. All compressed air cylinders used with self-contained breathing apparatus shall meet department of transportation (DOT) and NIOSH criteria.
(13) SCBA cylinders shall be hydrostatically tested within the periods specified by the manufacturer and by DOT and NIOSH/MSHA.
(14) The practice of buddy breathing by any means is STRICTLY PROHIBITED. Buddy breathing is the practice of sharing a single SCBA breathing air source between two persons.
(15) The use of a universal air connection will be permitted to replenish the breathing air cylinder of an SCBA user from an independent rescue breathing air supply source. An independent rescue breathing air supply source does not include the breathing air from an SCBA being worn by another firefighter.
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