We’ve compiled a list of expert answers to our most commonly asked questions about fire protection and detection.

Fire detection

How often does OSHA say we must test or check our smoke detectors?

OSHA does not specify how often an employer must check or test smoke detectors. Use the manufacturer’s recommended maintenance and testing procedures. You may also want to consult your liability insurance carrier and local fire department for more information on fire safety.

Fire alarms

Is it required to have someone test outside fire alarms on any specific frequency?

It may depend upon what type of system. According to 29 CFR 1910.165(d)(2), a non-supervised alarm system must be tested every two months. Local fire and building codes may have other requirements, including different testing frequencies.

How can we have an effective fire alarm system in noisy work areas, or in areas where hearing impaired employees are working?

Alarm devices are commonly equipped with both visual and audible alarms. A strobe light can be activated in conjunction with the audible alarm. Contact your alarm service provider for more information on the type of alarms available, and for guidance on the optimal placement of alarms in your facility.

Does OSHA mandate placement of fire alarm pull boxes, such as every 200 feet or within 5 feet of an exit door?

OSHA makes reference to the location of alarm pull stations in Appendix A to 29 CFR 1910 Subpart L under employee alarm systems. There is no specific OSHA requirement to have pulls 200 feet apart. The agency indicates, “The alarm box stations should be available within a travel distance of 200 feet.” There is no mention of having one five feet from an exit door.

NFPA 101, Life Safety Code, somewhat mirrors OSHA in the 200-foot requirement. The consensus standard indicates that no one should have to travel more than 200 feet in horizontal distance on the same floor to reach an alarm box. They also indicate that alarm boxes need to be in the “exit access path near each required exit.”

Note that local fire codes are a good source for what applies in a given location, as they should reflect the requirements of OSHA and possibly NFPA.

Please keep in mind that OSHA did not incorporate NFPA’s Life Safety Code directly. If a company follows the 2009 edition, however, then per 29 CFR 1910.35, OSHA will consider that company to be in compliance with sections 1910.34, 1910.36, and 1910.37.

Fire extinguishers

What does OSHA mean by a monthly “visual” inspection of fire extinguishers?

While OSHA’s portable fire extinguisher regulation at 1910.157(e)(2) does not explain exactly what “visual inspection” should consist of, a June 27, 1997, Letter of Interpretation says that the intent of the monthly inspection is to provide assurance that the extinguisher will operate effectively and safely. In addition to being in its designated place (readily accessible and immediately available), and being pressurized, the extinguisher should be observed for other possible defects, such as corrosion, mechanical damage, the presence of welding, soldering, brazing, or possible tampering.

Must a log be kept of inspections?

OSHA requires at 1910.157(e)(1) that “The employer shall be responsible for the inspection, maintenance, and testing of all portable fire extinguishers in the workplace.” Employers must perform both a monthly visual inspection and annual maintenance check. OSHA only requires, however, that the annual maintenance check be documented.

Even if not required by OSHA, one way to demonstrate compliance with the required monthly inspection is to document it. The agency allows employers to use whatever type of recording system, either paper or electronic, which works for their facility. Typically, inspections are recorded via a tag attached to each fire extinguisher. Also, under NFPA 10, Standard for Portable Fire Extinguishers, monthly fire extinguisher inspections are required, and the consensus standard states, “This inspection shall be noted on a tag or label attached to the fire extinguisher and shall include the date of the inspection and the initials of the individual doing the inspection.”

Employers should also check with local fire authorities to determine if a tag is required under local or state fire code.

What criteria must be used to perform annual maintenance of a fire extinguisher?

OSHA requires in 1910.157(e) that portable fire extinguishers be subjected to an annual maintenance check. OSHA says at 1910.144(c)(31) that maintenance means “the performance of services on fire protection equipment and systems to assure that they will perform as expected in the event of a fire. Maintenance differs from inspection in that maintenance requires the checking of internal fittings, devices and agent supplies.” However, 1910.157(e)(3) says that, “Stored pressure extinguishers do not require an internal examination.”

OSHA further says in non-mandatory Appendix A to 29 CFR 1910 Subpart L that the ultimate responsibility for the inspection, maintenance, and testing of portable fire extinguishers lies with the employer and suggests that they also check with the manufacturer of the unit that has been purchased and obtain guidelines on inspection, maintenance, and testing.

Can annual fire extinguisher inspections be done in-house?

The Appendix to 29 CFR 1910 Subpart L indicates that if an employer chooses to perform the inspection, then the employer must make sure that those who perform the inspection have been trained to do so and to recognize problem areas. NFPA 10, Standard for Portable Fire Extinguishers, provides guidelines as may the extinguisher manufacturer.

Who can perform the portable fire extinguisher “annual maintenance check” required under 1910.157(e)(3)?

The OSHA regulation does not specify who is to conduct the check. It would be advisable to contact the OSHA local area office for guidance on the qualifications needed. Also, the manufacturer’s instructions should be followed.

In addition, NFPA 10, Standard for Portable Fire Extinguishers, (which OSHA references in 29 CFR 1910 Subpart L, Appendix B) may provide useful information. This standard provides detail about who can inspect and service equipment. It requires, among other things, that “maintenance, servicing, and recharging shall be performed by trained and certified persons having available the appropriate servicing manual(s). . . .”

In addition, it is always a good idea to check with the local government fire authority for any additional requirements.

Where should fire extinguishers be placed within a warehouse or storage facility?

OSHA says in 1910.157(d):

1. "Portable fire extinguishers shall be provided for employee use and selected and distributed based on the classes of anticipated workplace fires and on the size and degree of hazard which would affect their use.
2. The employer shall distribute portable fire extinguishers for use by employees on Class A fires so that the travel distance for employees to any extinguisher is 75 feet (22.9 m) or less.
3. The employer may use uniformly spaced standpipe systems or hose stations connected to a sprinkler system installed for emergency use by employees instead of Class A portable fire extinguishers, provided that such systems meet the respective requirements of 1910.158 or 1910.159, that they provide total coverage of the area to be protected, and that employees are trained at least annually in their use.
4. The employer shall distribute portable fire extinguishers for use by employees on Class B fires so that the travel distance from the Class B hazard area to any extinguisher is 50 feet (15.2 m) or less.
5. The employer shall distribute portable fire extinguishers used for Class C hazards on the basis of the appropriate pattern for the existing Class A or Class B hazards.
6. The employer shall distribute portable fire extinguishers or other containers of Class D extinguishing agent for use by employees so that the travel distance from the combustible metal working area to any extinguishing agent is 75 feet (22.9 m) or less. Portable fire extinguishers for Class D hazards are required in those combustible metal working areas where combustible metal powders, flakes, shavings, or similarly sized products are generated at least once every two weeks."

Depending upon the classes of anticipated workplace fires, employers must provide and distribute fire extinguishers according to the requirements outlined above. If on the other hand, extinguishers are provided but are not intended for employee use and the employer has an emergency action plan and a fire prevention plan that meet the requirements of 1910.38 and 1910.39, respectively, then only the requirements of paragraphs (e) and (f) of 1910.157 apply, and fire extinguishers do not need to be made available.

However, fire extinguishers may be required by a local or state building or fire code. As such, employers need to contact their Fire Marshall or fire inspector for details regarding any applicable requirements. An employer’s liability insurance carrier may also require that fire extinguishers be available throughout their facility.

How much distance must be maintained around a fire extinguisher?

Neither OSHA nor the NFPA provide a specific distance that must be left clear around a fire extinguisher. At 1910.157(c)(1), OSHA states only that employers shall “mount, locate and identify (fire extinguishers) so that they are readily accessible to employees without subjecting the employees to possible injury.” NFPA 10, Standard for Portable Fire Extinguishers, states, “Fire extinguishers shall be conspicuously located where they will be readily accessible and immediately available. . .” and “Fire extinguishers shall not be obstructed. . . .” Also, be aware that state or local requirements may apply.

If you can quickly go to and easily retrieve an extinguisher, OSHA should be satisfied. However, whether or not there is a “blockage” or “accessibility” issue would be carefully scrutinized by an OSHA inspector. Most employers keep the floor beneath the fire extinguisher clear, and will mark that area with tape or floor markings so that nothing is inadvertently placed there.

At what height must extinguishers be mounted?

OSHA only requires that extinguishers be mounted, located, and identified so that they are readily accessible. However, NFPA 10, Standard for Portable Fire Extinguishers, states that units weighing 40 pounds or less be installed such that the top of the unit is not more than five feet above the floor. For units weighing more than 40 pounds, the top of the unit should be no more than 3.5 feet above the floor. There should always be at least four inches between the bottom of the unit and the floor.

Must fire extinguishers be mounted and maintained on forklifts?

OSHA does not require employers to equip forklifts with portable fire extinguishers. However, depending on the hazards present in an area where forklifts travel, OSHA may have requirements for fire protection in that specific hazardous location which would include mounting extinguishers on forklifts. Again, it depends upon the area where the forklift operates.

Also, if the truck manufacturer equips the forklifts with fire extinguishers, the employer must maintain the extinguishers according to the requirements of 1910.157. If the truck comes so equipped, the extinguisher cannot be removed permanently from the forklift without written permission from the manufacturer.

Local or state fire codes may also apply, so employers must check with local authorities or the Fire Marshal.

Must each fire extinguisher have a sign?

OSHA requires at 1910.157(c)(1) that employers “mount, locate and identify (fire extinguishers) so that they are readily accessible to employees. . . .” While some method of identification is required, OSHA does not specifically require a sign. However, according to 1910.144, red is the basic color for identification of fire protection equipment and apparatus. As such, fire extinguisher signage or other identifiers should be red. It should be noted that ANSI Z535.2 recommends specifications for sign format and colors for fire extinguisher location signs. Also, employers must comply with state and local fire codes which may dictate more specific requirements regarding signs, markings, and labels.

How must we “identify” a fire extinguisher, e.g., signs, markings, color, etc.?

According to 1910.157(c)(1), employers must provide portable fire extinguishers and mount, locate, and identify them so that they are readily accessible to employees without subjecting the employees to possible injury. OSHA does not state how employers must identify fire extinguishers. Whatever method is used, employees who are expected to use the fire extinguisher must understand how the fire extinguishers are identified. Signs or wall, post, or floor paint or tape are popular methods. While any color identifier is acceptable, red is the basic color for identification of fire protection equipment and apparatus, according to 1910.144. It should be noted that ANSI Z535.2 recommends specifications for sign format and colors for fire extinguisher location signs.

Is there a required format for documenting monthly fire extinguisher inspections?

OSHA has no recordkeeping requirements for monthly inspections, as they do for the annual maintenance checks. However, maintaining records of the inspections would be considered a good business practice. The following are considerations for inspection:

• Location in a designated place;
• The appropriate type of extinguisher(s) is present;
• No obstruction to access or visibility;
• Operating instructions on the nameplate are legible and facing outward;
• Safety seals and tamper indicators are not broken or missing;
• Fullness determined by weighing or “hefting”;
• Examination for obvious physical damage, corrosion, leakage, or clogged nozzle;
• Pressure gauge reading or indicator is in the operable range or position;
• For wheeled units, the condition of tires, wheels, carriage, hose, and nozzle;
• Comprehensive maintenance has been performed in the last six years (check the date of the last hydro/comprehensive maintenance or the date the unit was placed in service; the date is usually found on a label on the case);
• Hydrotest has been performed in the last 12 years (check the date of the last hydro or the date unit was place in service; the date is usually found stamped into the case or on a label on the case); and
• Hazard communication label in place if the extinguisher contains a hazardous chemical.

Also, extinguishers commonly have a tag attached to them indicating the routine inspection history. These should be checked to verify that inspections are being done.

How long must fire extinguisher inspection records be kept?

OSHA says in 1910.157(e)(3) that, “The employer shall record the annual maintenance date and retain this record for one year after the last entry or the life of the shell, whichever is less.” OSHA does not require that records of monthly fire extinguisher inspections be retained. However, as a best practice, employers should establish an associated recordkeeping system to demonstrate compliance with the monthly inspection requirement.

What training must our employees receive to operate a fire extinguisher?

If you do not expect any employees to use a fire extinguisher, then no training is required. However, for any employees who are expected to use them, OSHA covers training in 1910.157(g).

Where the employer has provided portable fire extinguishers for employee use, the employer must provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage firefighting. This training must be provided upon initial employment and at least annually thereafter.

The employer shall provide employees who have been designated to use firefighting equipment as part of an emergency action plan with training in the use of the appropriate equipment. This training must be provided upon initial assignment to the designated group of employees and at least annually thereafter.

Employers must also satisfy local/state building and fire codes in regard to fire extinguishers.

What qualifications must an individual have to conduct fire extinguisher training?

The fire extinguisher standard states only that an employer provide “the education required. . .” without further explaining how that should be done. In a January 28, 1982, letter of interpretation, OSHA says that “where the employer has provided portable fire extinguishers for employee use in the workplace, the employer shall also provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage firefighting. Hands on experience using actual fires in a controlled environment is not required in your particular case.” In other words, it is the employer’s responsibility to ensure that employees are properly trained for their assigned duties. As a good practice, the person who provides the training should have sufficient knowledge and experience to teach the trainees to properly use the necessary equipment and efficiently perform the anticipated firefighting procedures.

How is 1910.157, Portable Fire Extinguishers, applied with respect to 1910.38, Emergency Action Plans, and 1910.39, Fire Prevention Plans?

Employers are generally required by 29 CFR 1910 to provide portable fire extinguishing equipment for use in fighting incipient stage fires in the workplace. 29 CFR 1910.157, however, provides alternatives for employers who do not want some or all of their employees to fight incipient stage fires in the workplace. Employers who opt for the evacuation of all or most employees to a safe area do not have to comply with certain requirements of 1910.157, depending on the option chosen. These options are:

1. The employer evacuates all employees to safety when a fire occurs [1910.157(b)(1)]: Employers who select this option are relieved from compliance with 1910.157 unless a specific standard in part 1910 requires that portable fire extinguishers be provided. If the employer selects this option, compliance with 1910.38 and 1910.39 is required through 1910.157(b)(1).
2. The employer evacuates all employees except those designated to use portable fire extinguishers [1910.157(b)(2)]: Employers who select this option need not comply with the distribution requirements of 1910.157(d). This option allows for the employer to distribute extinguishers in a manner such that they are available to the employees designated to fight incipient stage fires. If the employer selects this option, compliance with 1910.38 is required through 1910.157(b)(2).
3. The employer keeps portable fire extinguishers in the workplace but does not want employees fighting fires and therefore evacuates the employees to safety [1910.157(a)]: OSHA recognizes that portable fire extinguishers may be required in the workplace by other organizations (e.g., insurance companies, local fire departments, etc.). Portable fire extinguishers that are not intended for employee use may still pose a hazard if they are not properly maintained. Where this option is selected and the employer meets 1910.38 and 1910.39, then only the maintenance, inspection, and testing requirements in paragraphs (e) and (f) of 1910.157 apply.

Employers who do not select any of these options but instead provide portable fire extinguishers for use by any employee to use in fighting incipient stage fires must comply with 1910.157 in its entirety. Employees who provide portable fire extinguishers for employee use must provide an educational program to familiarize all employees with the general principles of fire extinguisher use [1910.157(g)(1) and (g)(2)]. Employees who are expected to use portable fire extinguishers must be provided with “hands on” training in the use of the fire extinguishing equipment [1910.157(g)(3)]. If the employer chooses to comply with all of 1910.157, there is no requirement under 1910.157 to comply with 1910.38 or 1910.39.

Other

Does OSHA require fire drills?

OSHA does not require fire drills under 29 CFR 1910.38. However:

If an employer’s emergency action plan (EAP) and/or emergency response plan (ERP), under 1910.38 or 1910.120, respectively, contain provisions for conducting any type of drills, OSHA would require the employer to implement and conduct those drills.

If an employer requires its employees, under 1910.119, to take action in response to a chemical release of a highly hazardous chemical, these actions must be addressed in the employer’s process safety management “procedures or plans” (i.e., under 1910.119(f) and 1910.119(n)). If the employer then determines that drills are needed to assure that employees are adequately trained in those procedures, OSHA requires the employer to include those drills in its procedures and plans, and the employer must also ensure that employees are trained in those procedures.

Regardless if fire drills are required by OSHA, the agency says it is a good idea for employers to hold practice evacuation and shelter-in-place drills “as often as necessary” to keep employees prepared. This may be more a matter of policy than of regulation, but OSHA may turn to the General Duty Clause of the OSH Act if an incident were to occur and fire drills would have prevented it.

Note that local fire codes may require fire drills, even when OSHA does not. Check your fire codes to be sure. NFPA 101, the Life Safety Code, states that where a fire drill is required by a jurisdictional authority, then fire drills must be conducted at a frequency that is sufficient to keep building occupants familiar with the procedure. You may wish to coordinate your fire drills with your local fire department.

How can I find out if our warehouse or storage facility needs to have fire lanes?

You can check your local municipal building codes and/or fire codes for fire lane requirements. Your local police are regulated by the “Uniform Traffic Code,” and they may have information for you.