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Training requirements for fire-brigade instructors

Summary A union representative asked what qualifications fire-brigade instructors needed under 29 CFR 1910.156. OSHA said its requirements were performance-oriented and did not use the NFPA’s four instructor levels, while identifying Instructor I as the minimum equivalent and recommending fire-service experience. It also addressed testing, candidate evaluations and supervisory roles.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1985-01-07
Date issued
January 7, 1985
Status
Active
Status last verified October 10, 2026

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January 7, 1985

Mr. Ronald G. Mowery
Business Representative
Local No. 1455; IBEW
[Recipient address omitted]
Dear Mr. Mowery:

This is in response to your correspondence of December 12 concerning requirements of the Occupational Safety and Health Administration (OSHA) for fire brigade instructors.

The many fire brigades covered by the OSHA fire brigade standard (1910.156) vary widely in type, function, and size. The OSHA requirements for fire brigades, therefore, are performance-oriented to provide enough flexibility for the employer to organize a fire brigade which best reflects the needs of the workplace. Consequently, OSHA's training requirements for instructors are minimum, general type requirements. They are not divided into different levels of competence such as Instructor I, II, III, and IV as defined by the National Fire Protection Association standard (NFPA-1041).

The appendix to the fire brigade standard contains guidelines which should help you better understand the intent of OSHA's fire brigade training requirements. A copy of the OSHA standards are enclosed, and I have marked the appropriate pages for your information.

The following information is in response to your specific questions.

  1. The minimum acceptable standards for instructors should be at least equivalent to Instructor I (NFPA-1041).

  2. The instructor candidate need not be, or have been, a full time member of a fire department for five years. However, fire department experience (either volunteer or paid) would be helpful, and is certainly recommended.

  3. Although OSHA's requirements are not specific with respect to teaching methods, we would recommend that tests be routinized.

  4. While we do not see any advantage for a pass/fail determination being made at an administrative level, there are no OSHA requirements against it.

  5. It is acceptable to OSHA to have fire brigade candidates pass a standardized set of physical, emotional and mental evaluations.

  6. It is acceptable to OSHA to have these evaluations performed at an administrative level.

  7. It is acceptable to OSHA to have an Instructor III act in an administrative or supervisory capacity and have the actual skill instruction performed by Instructors I and II.

I hope this information will be helpful to you. Please contact Mr. Glen Gardner of my staff (202-523-7225) if you need further information.

Sincerely,
Barry J. White
Director, Directorate of Safety
Standards Programs

Enclosure

[Requester letter reproduced on OSHA page; omitted here.]

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