CFA staff and volunteers gained an exemption under the new laws, allowing unvaccinated workers to attend emergency scenes in "exceptional circumstances", however they will not be allowed at brigades for training or functions.

The COVID-19 Mandatory Vaccination (Workers) Directions, which came into effect on October 7, list four exceptional circumstances, two of which potentially apply to CFA workers:

If "a worker is required to respond to an emergency," or "a worker is required to perform urgent and essential work to protect the health and safety of workers or members of the public, or to protect assets and infrastructure," they can attend a scene regardless of their vaccination status.

A spokesperson for the CFA said the organisation had confirmed the exemption would allow unvaccinated staff and volunteers to respond to emergencies if required.

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The mandatory vaccination directions did not specify who was empowered to decide whether exceptional circumstances apply in a particular situation, nor if or how such decisions would be checked to ensure proper compliance.

The spokesperson emphasised the CFA was not treating the exemption as a loophole for members.

"CFA's understanding is that this is a provisional arrangement to allow emergency services to continue to be able to respond to emergencies while its workers get vaccinated," the spokesperson said.

"It is not an exemption CFA will be using in the long term to avoid members having to get vaccinated."

The mandate still poses problems for CFA workers unwilling to get vaccinated, because they will be unable to attend CFA stations unless there is an emergency and will not be able to participate in training exercises.

Competency training usually occurs in October and November each year in the lead up to the fire season, so almost no CFA members have done their update for this year. Members cannot attend emergencies if their training isn't up to date, so any unvaccinated members will soon be unqualified to attend emergencies.

Bookar CFA member Andrew Duynhoven said he knew of a number of brigades with key members who were not going to get vaccinated.

"It will have a devastating effect," he said of the mandate.

"I know one brigade where the captain is not going to get vaccinated, so that's not viable."

The Bookar brigade is well vaccinated and will not be affected by the mandate, but Mr Duynhoven said the viability of some smaller brigades often hinged on the availability of one or two key members, either because of their availability or skills.

"Most volunteers aren't available until they knock off work at 5 o'clock, so you need one or two who are always available," he said.

"Then we can't turn out if at least one person isn't a truck driver."

The Standard spoke to the captains of two south-west brigades who said they would step down if the mandate was enforced, leaving those brigades unviable, and said they knew of dozens of other members who had no plans to get vaccinated.

One local brigade captain from District 6, which covers the Otway and Corangamite regions, said he wasn't an anti-vaxxer, but rejected the element of coercion in the mandate.

"I've informed the CFA I'm not vaccinated and I'm not going to get vaccinated because the CFA tell me to," he said.

He said if the mandate is enforced his small brigade would "be without a captain", which would make it unviable.

Owen O'Keefe, a CFA veteran of more than 40 years and fully vaccinated, said he could see the mandate leading to tension within brigades, but he thought most members would get vaccinated.

"I would imagine the bulk of the CFA members because of their motivation to be a volunteer would make them want to get vaccinated," he said.

The CFA spokesperson said the organisation had been encouraging members to get vaccinated since they became eligible in April.

"CFA volunteers dedicate themselves to protecting their communities; we are confident they will continue to roll up their sleeves like they do every summer to keep Victorians safe," they said.

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