OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 23, 1983

Mr. R. C. Freeman
Vice-President
Product Development & Technical Services
The Wool Bureau, Inc.
225 Crossways Park Drive
Woodbury, Long Island, N.Y. 11797

Dear Mr. Freeman:

Thank you for your correspondence concerning the Occupational Safety and Health Administration's (OSHA) protective clothing standards for fire fighters. Quite possibly, your dissatisfaction with the standard results from some error in your understanding of the standard.

Development of the OSHA fire brigade standard (1910.156) began in 1976. The rulemaking process was very comprehensive, and the fire brigade standard was promulgated in 1980 based on extensive public comment and hearings. We note your organization elected not to participate in our rulemaking.

The OSHA provisions for protective clothing (1910.156(e)) are not specific to one manmade fiber as you maintain. Protective clothing may be made of any material (manmade or natural fiber) as long as it meets the criteria specified in the OSHA standard. Cotton Incorporated was active in the OSHA rulemaking, and their input and other support in the public record caused OSHA to allow more flexibility in its standard than that permitted by the National Fire Protection Association's (NFPA) Standard.

OSHA is represented on the NFPA Committee, Protective Equipment for Fire Fighters. I believe that The Wool Bureau, Inc. is also represented on this committee. The NFPA Committee is actively working on new criteria and test methods for protective clothing for fire fighters. I am sure that the NFPA Committee would be interested in the information that you have submitted to OSHA. You may wish to submit it to them directly.

Your correspondence to OSHA also states that the trend appears to be an increase in injuries since the promulgation of the fire brigade standard. We would like copies of reports that indicate this trend as we do not have such information. We see training programs improving and better equipment being used. However, since the protective clothing provisions of the OSHA fire brigade standard are not even effective until July 1, 1985, it is unlikely that they have had any impact on recent injuries.

OSHA is continuously evaluating its standards to assure that employees are adequately protected. If revision of the fire brigade standard is necessary, all applicable information will be considered, including that which you have submitted to OSHA.

Again, thank you for your comments. We look forward to working with you on this important subject.

Sincerely,



Thorne G. Auchter
Assistant Secretary