OSHA is looking for Small Entity Representatives from the following areas:

  • County/city/municipal government executives who are involved with budgeting for government expenditures including emergency response services
  • Skilled Support Employers – non-emergency response organizations who assist at emergency scenes including heavy equipment operators, construction companies that help with demolition, etc.
  • Industrial fire brigades or emergency response teams
  • Private Emergency Medical Response operations

Public entities must be in OSHA state plan states and serve populations of fewer than 50,000 to participate. Private entities must meet the SBA definition of a small entity.

Please contact OSHA or the Office of Advocacy at SBA if you are interested in participating.

About the Emergency Response Standard

The primary focus of the Emergency Response standard would be to protect workers who respond to emergencies as part of their regularly assigned duties. Examples include: fire brigades/workplace emergency response teams, industrial and municipal fire fighters, technical rescuers, emergency medical service providers, etc. A secondary focus of the rule would be to protect those workers who may be called upon, from time to time, to respond to emergencies. Examples include: skilled support workers such as heavy equipment and crane operators, heavy wrecker/rotator operators, etc. This new standard would replace in its entirety existing 29 CFR 1910.156, Fire Brigades.

Topics in the potential draft standard to be considered by the SBAR panel include:

  • Organization Risk Management
  • Medical/Fitness Requirements
  • Training and Qualifications
  • Facility and Equipment Preparedness
  • Vehicle Preparedness and Operation
  • Pre-Incident Planning and Post-Incident Analysis
  • Standard Operating Procedures and Incident Management
  • Emergency Incident Operations
  • Skilled Support Employer Requirements


In accordance with the requirements of the Small Business Regulatory Enforcement Fairness Act (SBREFA), OSHA will be convening a Small Business Advocacy Review (SBAR) panel in Spring 2019. The panel, comprising members from Advocacy, OSHA and OMB's Office of Information and Regulatory Affairs, will listen to and report on what Small Entity Representatives (SERs) from entities that would potentially be affected by the draft rule have to say. Each SER will be sent a packet of documents to review, then asked to participate in a small-group teleconference to discuss concerns related to the information provided and how the draft regulation might potentially affect their entity.

The definition of a "small entity" varies widely across the broad range of industries potentially covered by the standard. Please see the SBA Table of Size Standards for the exact definition of a small entity for your industry or contact OSHA or SBA for assistance. Examples of small entities include:

  • Career fire, rescue, EMS, etc., organizations that are controlled by "governments of cities, counties, towns, [or] townships, … with a population of less than fifty thousand." These organizations must be in an OSHA State Plan state to participate in SBREFA
  • Volunteer, paid-per-call, and combination paid/volunteer fire, rescue, EMS, etc., organizations in OSHA state plan states where volunteers are considered employees.
  • Forest fire suppression/support (NAICS 115310) entities with annual revenue less than $19 million.
  • Firefighting as a commercial activity (NAICS 561990) entities with annual revenue less than $11 million.
  • Ambulance service (NAICS 621910) entities with annual revenue less than $15 million.
  • For most industries with fire brigades/workplace emergency response teams, employers with fewer than 1,000 or 1,250 employees depending on the NAICS industry that employer falls under.
  • Chemical manufacturing industry employers with fewer than 500 to fewer than 1,250 employees depending on the NAICS industry that employer falls under.
  • Oil and gas industry employers with fewer than 1,000 employees; entities in support activities for oil and gas less than $38.5 million in revenue.

OSHA will host several SBAR Panel teleconferences that the public will be able to listen to. Each Small Entity Representative will be asked to participate in one of the teleconferences. Entities that would like to participate in the SBAR Panel as SERs should contact Bruce Lundegren at the Small Business Administration, Bruce.Lundegren@SBA.gov, (202) 205-6144; or Robert Burt at OSHA, Burt.Robert@dol.gov, (202) 693-1952.

For additional information about the rulemaking, please see: Emergency Response Rulemaking.

What is a Small Business Advocacy Review (SBAR) Panel


When: OSHA anticipates formally convening the SBAR Panel in Spring 2019


What is the Emergency Response standard?

This rulemaking effort is separate from OSHA's technical assistance resources for emergency response and recovery workers. For those resources, visit OSHA's Emergency Preparedness and Response page.

  • April 26, 2019 – Convene SBREFA Panel
  • Teleconferences with SERs:
    • May 7
    • May 8
    • May 9
  • June 26, 2019 - Complete Panel Report

SBAR Panel Small Entity Representatives (SERs), as of 02/27/19:

  • TBD
  • TBD
  • TBD

Contact OSHA for questions:

Contact SBA's Office of Advocacy for questions:

  • Bruce Lundegren (office represents the views of small entities in the SBREFA process), Bruce.Lundegren@sba.gov or (202) 205-6144.
  • Teleconference Public Access Information: Phone # TBD Passcode # TBD
  • All teleconferences will be open to the public via telephone, but only SERs and SBAR Panel members can participate in the discussions. The public is also invited to attend in person (capacity may be limited). The teleconferences will be held in the Department of Labor Building at 200 Constitution Ave NW in Washington DC.
  • Any interested party may submit comments, even those who are not participating as SERs, and OSHA will include those comments in the public docket. While OSHA has no legal obligation to consider or to respond to non-SER comments, the Agency will consider them in its discretion as resources allow. All such comments can be submitted to OSHA docket OSHA-2007-0073 via the government's e-regulatory portal, Regulations.gov. The comment period will last until two weeks after the SBAR Panel report is completed.