Hazard Pay for Prescribed Burns: OPM's Final Rule, the Fireline Test and Who Is Left Out

Bottom line

A crew member holding a fireline on a wildfire has drawn a 25 percent hazard differential since 1969 ^[1]. The same crew member doing the same work on a planned burn has drawn nothing extra. On August 14, OPM published a final rule that closes that gap for General Schedule and Federal Wage System employees, starting with the first pay period that begins on or after September 14 ^[1]. The test is duty-based and narrow: you must be on a crew, on the fireline, after the fire is lit ^[1].

What happened

OPM proposed the change on April 14 and took comments through June 15 ^{[1, 2]}. It received 92 comments, nearly all supportive, and adopted the proposed text and the 25 percent rate without change ^[1]. The Forest Service and Interior’s wildland fire office had asked for it, on the argument that prescribed fire crews face many of the hazards found on wildfire lines ^{[1, 2]}.

Two schedules, one rate. Hazardous duty pay for GS employees rests on 5 U.S.C. 5545(d) and 5 CFR part 550, subpart I ^[1]. Environmental differential pay for wage-grade employees rests on 5 U.S.C. 5343(c)(4) and 5 CFR 532.511 ^[1]. Both schedules already listed forest and range fires at 25 percent, and neither mentioned prescribed fire ^{[1, 2]}. The rule adds the same entry to each: “Participating as a member of a firefighting crew engaged in activities on the fireline directly involving the implementation and control of a prescribed wildland fire” ^[1].

The word that was removed. The version OPM showed the Federal Prevailing Rate Advisory Committee in July 2024 covered fireline activities “related to the preparation, implementation, and control” of a prescribed fire ^[2]. The committee recommended it by consensus ^{[1, 2]}. OPM then changed “related to” to “directly involves” and dropped “preparation” entirely ^[2]. Its reasoning, repeated in the final rule, is that the hazard comes from the active fire and its aftermath, not from work done before ignition ^[1]. One commenter argued that much prescribed fire time is spent staging and waiting for good conditions. OPM agreed that time does not count: “moving personnel and equipment into place and waiting for the burn window will not be the trigger for payment” ^[1].

What does count, per OPM: ignition, holding, patrol, mop-up, fireline construction and snag felling ^[1]. The proposal noted that patrol and mop-up “can continue for days” after ignition ^[2].

The classification bar, written down. Ordinarily, hazard pay is not payable when the hazard was already considered in classifying the position ^[1]. The 2021 infrastructure law, Public Law 117-58, created an exception for occupational series whose primary duties are preventing, controlling, suppressing or managing wildland fire ^{[1, 2]}. OPM’s regulation had never reflected that. The rule adds 5 CFR 550.904(f) to say so ^[1]. Several commenters argued that GW-0456 firefighters, whose base pay already reflects fire hazards, should be excluded. OPM disagreed, citing the statute ^[1]. It also noted that Congress set a special base rate for firefighters in section 1807 of Public Law 119-4, the 2025 full-year funding law, and said fairness concerns about collateral-duty staff should be fixed by paying them properly, not by withholding pay from GW firefighters ^[1].

The numbers. OPM estimates about 10,000 GS employees and 2,500 FWS employees at USDA and Interior could be affected ^[1]. USDA puts its cost at about $20 million a year, based on roughly 250 hours of prescribed fire work per employee ^[1]. Interior’s figure is given as about $12.5 million a year in one paragraph and $9.0 million for fiscal 2026, rising to $9.5 million in fiscal 2027, in the next ^[1]. The rule does not explain the difference.

The National Federation of Federal Employees, which says it first raised the issue with OPM in 2022, called the result “a monumental victory” ^{[3, 4]}.

What it means for you

GW-0456 wildland firefighters. You are covered when you meet the duty test ^[1]. OPM was explicit: “Eligibility is determined by whether the employee performs covered duties under the regulatory standard, not by the pay plan code alone” ^[1]. The new differential sits alongside the special base rate, not in place of it ^[1].

GS employees in other series who work burns on a collateral basis. Timber, recreation and other staff who serve on a prescribed fire crew qualify on the same terms ^[1]. Answering commenters who said such staff are underpaid for fireline work, OPM wrote that the point “supports including those employees” ^[1]. Hours spent on a burn outside the fireline, or before ignition, do not qualify ^[1].

Federal Wage System employees. The environmental differential is paid on the basis of hours in pay status, consistent with the structure of Part II of the EDP schedule ^[1]. The wage-grade entry sits under category 10, Firefighting, at the “high degree” level, next to the forest and range fire line that dates to July 1, 1972 ^[1].

Employees at agencies other than USDA and Interior. The rule says other agencies may occasionally have employees temporarily assigned to prescribed burns who meet the criteria ^[1]. The proposal said the employing agency decides whether an employee qualifies ^[2]. Readers should note that this places the fireline judgment with local timekeepers and supervisors, and the rule offers no definition of “fireline” beyond the duty list.

Smokejumpers, aviation and air tanker base staff. Not covered. OPM declined to expand the rule to training jumps, ramp operations or air tanker bases because those questions were outside the rulemaking record ^[1]. It said they “may be considered separately” in future rulemaking, with no timetable ^[1]. NFFE says it is working with Rep. Celeste Maloy on H.R. 5091, the Wildland Firefighter Hazard Pay Correction Act, which would put the change in statute ^[4]. Government Executive’s report does not mention that bill ^[3].

Payroll offices. The proposal anticipated that payroll providers would need to set up time and attendance codes for the new differential, and said they may create their own codes so long as they report the required Enterprise Human Resources Integration data ^[2].

Contractors and retirees. The rule amends title 5 pay schedules for GS and FWS employees ^[1]. It does not address contract crews, and it says nothing about retirement or annuities.

Escaped burns. One commenter noted that an escaped prescribed fire can be reclassified as a wildfire, at which point the existing category applies ^[1]. OPM’s answer was that the hazards exist during a successful burn too, and that waiting for an escape “would compensate the escape event, but not the hazardous fireline work” ^[1].

Questions you’re probably asking

When does hazard pay for prescribed burns start?

With the first pay period beginning on or after September 14, 2026 ^[1]. Prescribed burn work before that pay period does not qualify under the new category ^[1].

How much is hazard pay for prescribed fire work?

25 percent, the same rate already paid for fireline work on wildfires ^[1]. GS employees receive it as hazardous duty pay and Federal Wage System employees as environmental differential pay ^[1].

Are GW-0456 wildland firefighters eligible for prescribed fire hazard pay?

Yes. OPM says employees under the GW pay plan code are included and are not barred because fire duties are part of their position classification ^[1]. They must meet the same fireline duty test as everyone else ^[1].

Does prep work before ignition count toward hazard pay on a prescribed burn?

No. The rule excludes pre-ignition preparation, and OPM says moving people and equipment into place or waiting for the burn window will not trigger payment ^[1].

Are smokejumper training jumps or air tanker base crews covered?

Not by this rule. OPM declined to add smokejumper proficiency jumps, aviation and air tanker base work, saying those could be considered in separate future rulemaking ^[1].

What I’m watching

• September 14, 2026: the rule takes effect; the differential applies from the first pay period beginning on or after that date ^[1]. Watch for agency payroll and timekeeping instructions before then.
• No date set: any OPM rulemaking on smokejumper training jumps, aviation or air tanker base work ^[1], and any movement on H.R. 5091 ^[4].