Several publications have raised concerns over the state of knowledge and competence in tunnel fire safety amongst fire and rescue personnel. Although fires in road tunnels are not common phenomena, the fire and rescue services still have to cope with such incidents. In order to perform an effective emergency response in the event of fires or other emergencies it is essential that the fire and rescue personnel possess necessary knowledge and skills. The responsibility to develop knowledge and competence amongst fire and rescue personnel is shared by a large number of actors at several hierarchical levels. The diversity of actors and organizations, as well as the interactions between them, makes the fire and rescue system a complex sociotechnical system. The Norwegian emergency response systems are partly designed on self-regulation principles, which encourage creative solutions. However, it seems that the frame conditions for developing optimal learning systems are not in place. So far, no agency seems to be able to establish recognized constraints that enables the involved actors to define their own competence levels. A set of safety constraints to learning processes is proposed to enable control and improvement of tunnel fire safety and rescue competencies.