Local Government Center 60 Community Drive Augusta, Maine 04330-9486

Officers
President
Chief Thomas Higgins
Bangor Fire Department

1st Vice President

Chief William Gillespie Date: April 30, 2024
Liberty Fire Department

2nd Vice President

Chief Matthew Bartlett Ref: Comments on OSHA proposed update 1910.156, The Fire Brigade
Bar Harbor Fire Department Standard
Sgt. at Arms
Chief Michael Robitaille
Yarmouth Fire Department

Correspondence Secretary
Chief Brent Libby
Windham Fire Department
Maine Fire Chiefs’ Association represents the leadership of the Fire Service in the
State of Maine. There are approximately 482 communities in the State served by
Treasurer
Chief Kenneth Brillant 338 Fire Departments. Of those 338 Fire Departments over 85% are completely
Brunswick Fire Department
or primarily volunteer. Maine has a population of 1,385,000 spread over 31,000
Board of Directors (1-yr.)
Chief Bob Chase
square miles of land mass. The bulk of the population is in the southern half of
Androscoggin County the state, yet there is only one community exceeding 50,000 in population in the
Chief Dan Small State.
Cumberland County

Asst Chief Julia Gray We have reviewed the proposed change of the Fire Brigade Standard to The
Hancock County
Emergency Response Standard 1910.156. We found it to be overwhelming and
Chief Chris Farley
Knox County difficult to breakdown into precise expectations. To aid in that process we feel
Chief Dan Brooks
that a checklist of expectations as a stand-alone document developed by OSHA
At-Large, Piscataquis County would be extremely beneficial in determining agency impacts.
Chief Matt Duross
York County
Departments in Maine are already struggling with staffing issues compounded by
Board of Directors (2-yrs.) the time needed to prepare and equip staff for emergency response. Both
Chief Paul Smeltzer
Lincoln County volunteer and career departments are in a constant hiring mode. Only to
Chief Peter Metcalf exasperate the situation even more are the costs currently associated with
Penobscot County preparing and equipping emergency response staff. Taxpayers across the State are
Chief Bernard Williams already overburdened with double digit inflation. Many of our departments and
Somerset County
communities are constantly struggling just to keep the doors open under the
Chief Patrick Richards
Waldo County
current standard. The staffing, training, financial and service delivery impacts of
this proposed standard could be overwhelming for many departments and
Chief Timothy Hernandez
Washington County communities, forcing them to make drastic decisions, perhaps closing doors.
Board of Directors (3-yrs.)
Those impacts could have a domino effect on neighboring response areas who are
Chief Nathan Allen able to address impacts for their current service area.
Aroostook County

Chief Tim Hardy

Franklin County Maine Fire Chiefs’ Association strongly supports anything that will make our
Chief Andrew Clark
members safer and have fought to do that over the years. Conversely though we
Kennebec County feel that if this proposal becomes a standard the service impacts could severely
Chief Scott Dennett jeopardize the safety of everyone at the very least on the receiving end of service
Oxford County
delivery.
Deputy Chief Chris Cummings
Sagadahoc County
We would like to request that OSHA develops a checklist of precise expectations
Past President and share that information along with this or an updated version of the proposal.
Chief Darrell White
Presque Isle Fire Department

Executive Director
Chief William St. Michel (ret)
Established 1912
 Local Government Center 60 Community Drive Augusta, Maine 04330-9486

We would also like to see an extended review or comment period, with or without an accompanying
checklist.

We feel that one size fits all areas and services is not the answer as demonstrated when NFPA 1710 &
NFPA 1720 were developed. Therefore, we would recommend a tiered approach based on types of
service and staffing models as well as geographical area served.

We also feel that a rapid compliance timeframe coupled with strict and severe penalties is not the
answer. The only way everyone will be able to make even a portion of the proposed expectations is
with a phased in implementation period extending over 10 – 20 years coupled with education first.

We appreciate the opportunity to comment on the proposed changes to the Fire Brigade Standard and
would be happy to assist or respond with additional information.

Respectfully,
William St. Michel

Executive Director

Established 1912