OSHA Region 10's
Role in Wildland Firefighting Safety
Carl Halgren Oregon Area Director, OSHA 
with Dick Terrill and Joy Flack

In 2002, there was confusion among some in the wildland firefighting community, especially Incident Management Teams (IMTs) from outside the Pacific Northwest, as to what role OSHA has. Hopefully, this document will provide a better understanding about what OSHA will and, equally important, will not do during inspections of wildland firefighting activity.

Key items to know are:

Purpose: OSHA will inspect federal agencies to ascertain how well safety and health 
is implemented on the fire line and in camps. OSHA will NOT direct how fire is to be fought. The inspections will identify hazards, determine if violations have occurred, and provide abatement assistance.

Jurisdiction: Federal OSHA has jurisdiction over federal employees. State OSHA 
programs (OR, WA, AK) have jurisdiction over private sector employers, i.e., contract crews. State OSHA programs also have jurisdiction over state, county, and city public employees.

Standards: OSHA has no standards for wildland firefighting. The National Interagency
Fire Center establishes policy for wildland firefighting in the Standards for Fire and Aviation Operations 2003, the "red book." OSHA has and will evaluate how these standards are followed. Specific OSHA requirements will be addressed in non-fire line operations, i.e., camps.

Responsibility: When Congress wrote the OSH Act, the responsibility to provide a
"safe and healthful workplace" was placed on the employer, not on employees. As representatives of the employer, all managers, supervisors, crew bosses, et cetera, have this responsibility, not only the Fire Safety Officer.

Relationship to Inspection Teams from Wildland Agencies: There is no direct relationship between OSHA and wildland agency inspection teams, e.g., the BLM Safety Accident Investigation Team (SAIT). The role of each is different, and may seem to be overlapping. When possible, OSHA will coordinate on-site activities in order to reduce duplication and disruption of the firefighting effort.

OSHA On-Site Activity: Per agreement with the agencies, OSHA will first contact the 
"person in charge" of where the fire is located and an authorized employee representative. The "person in charge" will be the Forest Supervisor, District Manager, Park Superintendent, et cetera. A copy(s) of the Delegation of Authority will be obtained. Based on that document, contact will be made with whomever is in charge of the fire operation and the camps. Normally, OSHA personnel will not go to the fire line. OSHA personnel will interview employer representatives and employees to establish compliance with OSHA standards and the "red book." The normal who, what, when, where, why and how questions will be raised, and hazards documented.

Close Out: At the completion of the on-site activity, a "closing conference" will be held
with the person in charge of the location and the person in charge of the fire, as well as employee representatives. Findings of the inspection, including apparent violations, will be discussed and hazard correction sought.

Citations: Citations will be issued if violations are determined to have occurred. The 
citations may be issued to the Regional Forester, State Director, Incident Commander, et cetera.