OSHA’s proposed “Medical and Physical Requirements” requirements in it’s new Emergency Response Standard

Emergency response is a physically demanding occupation; approximately half of all firefighter on-duty and line-of-duty deaths are due to cardiovascular events. Emergency response activities can place a tremendous strain on the cardiovascular system, which can trigger a catastrophic cardiovascular event. This is especially true for team members and responders with pre-existing heart conditions, which they may or may not be aware of. Emergency response activities often involve activities that increase the risk of team member and responder musculoskeletal injuries, e.g., lifting and carrying heavy loads (equipment, PPE, victims, etc) in awkward positions, sustained use of equipment that may result in injuries related to repetitive motion, ergonomically unsafe cutting angles when safer approaches are unavailable, or vibration.

Emergency response activities often occur in extreme environmental conditions that increase risks for heat or cold injury. Noise from sirens, alarms, and equipment motors can induce hearing loss, especially if the noise exposure is occurring in situations where it may be concurrent with exposure to carbon monoxide or other substances known to have synergistic effects with noise on hearing loss, especially as many responders may not use hearing protection devices out of concern for effective communication with others on the scene.

Emergency response activities may also involve exposure to numerous toxic substances. Team members and responders may be exposed to combustion products produced by the fire they are responding to as well as from the operation of their equipment/apparatus, hazardous materials when material releases occur, and infectious diseases during emergency medical responses that may result in adverse health effects to team members and responders. Additionally, exposure to combustion products increases team members’ and responders’ risk of developing several different kinds of cancer.

Finally, emergency response activities expose team members and responders to traumatic, emotionally charged events, and the impact of these events on responders’ mental health is compounded by inadequate duration and quality of sleep due to the unpredictable nature of calls, which is exacerbated by frequently working back-to-back long shifts and excessive overtime, especially in understaffed fire departments. Mental health issues may be worsened by perceived stigma regarding use of mental health services.

Proposed paragraph (g) includes medical and physical requirements to address these hazards. The physical fitness and physical and mental medical requirements in paragraph (g) serve two purposes:

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