**Occupational Safety and Health Administration (OSHA), Department of
Labor.**

**RIN 1218-AC17**

**Comment in response to request for information.**

To whom it may concern,

I am writing to comment on OSHA's request for information regarding
elements of emergency responder health and safety. I write as a
concerned citizen and former lifeguard trained in aquatic emergency
response. One does not typically think of lifeguards as being trained to
handle any situations outside of the pool deck. I, however, was required
by my employer to achieve extensive certifications, which covered
incident scene safety, electricity and fire hazards, and all sorts of
emergency response first aid.

To begin, I applaud the Occupational Safety and Health Administration
for seeking to further address response and preparedness. In general, I
do agree that the standards mentioned in the request for information are
outdated and in need of being revisited. Additionally, I feel that all
types of emergencies and areas of interests mentioned in the request for
information need to be considered by OSHA when deciding what actions to
take to address emergency response and preparedness.

The request for information asks forty-one (41) specific questions. This
comment will answer only those questions to which I can form an adequate
and relevant response. This comment will not answer those questions
which I am not qualified to answer. My specific comments follow and are
arranged by question number.

1.  I believe that all types of emergency incidents should be included
    if the agency takes action on emergency response and preparedness.
    If the agency is going to take action, why not act on all of the
    events that could pose a threat to human lives. To purposely exclude
    certain events is to only do half the job. In this vein, addressing
    all types of incidents would allow OSHA to form a large scale,
    comprehensive response system.

2.  Yes, OSHA should consider the full continuum of activities to be
    considered "emergency response and preparedness." Changes in the
    security climate of the United States, namely terrorism, have
    redefined the way in which we prepare for, deal with, and recover
    from events. Therefore, each of those stages must be considered by
    the agency.

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4.  While I am unable to offer an answer on what type of work tasks
    should be considered emergency response or skilled support work, I
    am able to say that those tasks performed exclusively and
    exhaustively by law enforcement should not be labeled as such. While
    these law enforcement duties do include responding to emergencies,
    they are of a different sort not being considered in this effort by
    OSHA.

> 6\. While I cannot comment on a specific state's standards, I will
> assert my opinion
>
> that OSHA should hold all states to the same standards for emergency
> response and preparedness. This also would contribute to a national,
> comprehensive response plan.

9\. Since firefighters often encounter situations where their
surroundings rapidly

> deteriorate, changing the landscape they are in, they should always be
> required to use a personal alert safety system (PASS) device in order
> to locate missing, trapped, or incapacitated firefighters.

11\. Based on common sense, the National Institute for Occupational
Safety and

> Health's (NIOSH) certification for self contained breathing apparatus
> is not sufficient if it does not subject the breathing apparatus to
> heat and flame. How can firefighters and other personnel go on the job
> with breathing devices that have not been tested under heat and flame?

18\. I feel that incident scene safety should be added to the list of
initial training

> requirements. Emergency responders may quickly find themselves in need
> of other emergency responders if they are not taught to be aware of
> the safety risks posed by the scene. Since these are basic safety
> precautions, they should be refreshed every three years as a brief
> part of some other, pre-existing refresher course. Also, adding this
> requirement would not be costly as this material can be quickly and
> easily learned.

24\. Based on common sense, in the situations described, I think it is
plain to see that

there is no distinction between a "safety official" and a "safety
officer".

26\. Based on my years of lifeguard training experience, I feel that the
agency should

> consider a credentialing system. This system should be made up of a
> combination of the mentioned methods, with an emphasis on the trainee
> adequately demonstrating the specified competencies. Consult the Red
> Cross credentialing systems for a model.

28. OSHA should implement the following procedure regarding vaccines
    because it

> seems to make the most logical sense. The Centers for Disease Control
> will determine that a vaccine is necessary. Then, employers should
> provide this vaccine to employees at no additional cost. The vaccine
> should be available to the employee at a reasonable time and place,
> and the employee should be subject to appropriate medical screening.
> This seems to be the fair and just thing to do. If our emergency
> responders are required to enter fields in which diseases are present,
> then they should be given the proper vaccinations. Vaccinations can be
> every bit as important as protective equipment.

30\. Even the most basic lifeguard training includes certification for
Automated

> External Defibrillators (AEDs). AEDs have proven to be an invaluable
> tool across the nation from emergency rooms to high school sporting
> events. Any statute that does not provide for an AED is painfully
> outdated. This becomes even clearer when the emergency responder
> suffers a cardiac event and needs the assistance of his own life
> saving device.

36\. Yes, communications hardware is needed by all responders. Imagine a
terrorist

> attack where second and third explosions detonate at a later time
> during the rescue effort. Without communications hardware, whatever
> specific type that may be, responders would have no way of organizing
> subsequent efforts to deal with the new risks and hazards.

In conclusion, OSHA should focus primarily on keeping our emergency
responders well equipped, well trained, and safe. I would like to
reiterate that OSHA should organize a comprehensive, nation wide
approach of the best practices for dealing with emergency response
situations.

Sincerely,

Jason A. Antin