Fire prevention housekeeping

OSHA 1910.39 calls for the control of accumulations of flammable and combustible waste materials. It is the intent of this standard to assure that hazardous accumulations of combustible waste materials are controlled so that a fast developing fire, rapid spread of toxic smoke, or an explosion will not occur.

This does not necessarily mean that each room or area has to be swept each day. Employers and employees should be aware of the hazardous properties of materials in their workplaces, and the degree of hazard each poses. Certainly oil soaked rags in a maintenance area have to be treated differently than general paper trash in office areas, for example. However, large accumulations of waste paper or corrugated boxes, etc., can pose a significant fire hazard.

Accumulations of materials which can cause large fires or generate dense smoke that are easily ignited or may start from spontaneous combustion, are the types of materials with which this standard is concerned. Such combustible materials may be easily ignited by matches, welder’s sparks, cigarettes, and similar low level energy ignition sources.

Maintenance of equipment under the FPP

Certain equipment is often installed in workplaces to control heat sources or to detect fuel leaks. An example is a temperature limit switch on high temperature dip tanks, or flame failure and flashback arrester devices on furnaces, and similar heat producing equipment. If these devices are not properly maintained or if they become inoperative, a definite fire hazard exists.

Again, employees and supervisors should be aware of the specific type of control devices on equipment involved with combustible materials in the workplace and should make sure, through periodic inspection or testing, that these controls are operable. Manufacturers’ recommendations should be followed to assure proper maintenance procedures.

Fire fighting options

Employers are generally required to provide portable fire extinguishing equipment for use in fighting incipient stage fires in the workplace. Section 1910.157, however, provides alternatives for employers who do not want their employees to fight incipient stage fires in the workplace. Employers that 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.

Evacuate all employees

The employer chooses to evacuate all employees to safety when a fire occurs. Employers that select this option do not have to comply with 1910.157 unless a specific standard in part 1910 requires that portable fire extinguishers be provided. If this option is selected, compliance with 1910.38 and 1910.39 is required through 1910.157(b)(1).

Evacuate some employees

The employer chooses to evacuate all employees except those designated to use portable fire extinguishers. Employers that select this option need not comply with the distribution requirements of 1910.157(d). This option allows the employer to distribute extinguishers so that they are available to the employees who have been designated to fight incipient stage fires. If this option is selected, compliance with 1910.38 is required through 1910.157(b)(2).

Have fire extinguishers but evacuate all employees

Some employers keep portable fire extinguishers in the workplace, even though they do not want employees fighting fires and have a policy for total evacuation. Portable fire extinguishers may be required in the workplace by other organizations such as insurance companies or local fire departments. Portable fire extinguishers that are not intended for employee use may still pose a hazard if they are not properly maintained. Employers who select this option must comply only with the maintenance, inspection, and testing requirements in paragraphs (e) and (f) of 1910.157.

All employees fight fires

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. Employers that provide portable fire extinguishers for employee use must provide an educational program to familiarize then with the general principles of fire extinguisher use. Those employees expected to use portable fire extinguishers must receive “hands on” training in the use of the fire extinguishing equipment. If the employer chooses to comply with all of 1910.157, there is no requirement to comply with 1910.38 or 1910.39.

Fire extinguisher basics

Fire extinguishers may be mounted in any location that is easily accessible to employees. They should never have to use a ladder to reach an extinguisher. OSHA allows this flexibility to ensure that employees can obtain extinguishers as fast as possible.

If your company decides to use fire extinguishers, it is responsible for the proper selection and distribution of those extinguishers. You must also ensure that the extinguishers provide the necessary degree of protection for the hazards present in your workplace.

Who can inspect fire extinguishers?

Ultimate responsibility for the inspection, maintenance, and testing of all fire extinguishing systems lies with the employer. Your company may choose to use outside contractors to perform the actual inspection, maintenance, and testing of your extinguishing systems, either portable or standpipe.

When contracting for such work, you must ensure that the contractor is capable of performing the work. If the company decides to perform the inspection, maintenance, and testing requirements in-house, you must ensure that those persons doing the work have been appropriately trained and will recognize problem areas that could cause an extinguisher or system to be inoperable.

It is advisable to check with state/local fire codes for any specific qualification requirements.

Selection and distribution of fire extinguishers

The selection and distribution of fire extinguishers must reflect the type and class of fire hazards associated with a particular workplace.

• Class A. Extinguishers for protecting Class A hazards may be selected from the following types: water, foam, loaded stream, or multipurpose dry chemical.
• Class B. Extinguishers for protecting Class B hazards may be selected from the following types: Halon 1301, Halon 1211, carbon dioxide, dry chemicals, foam, or loaded stream.
• Class C. Extinguishers for protecting Class C hazards may be selected from the following types: Halon 1301, Halon 1211, carbon dioxide, or dry chemical.
• Class D. Combustible metal fires are considered Class D hazards. These fires pose a different type of problem in the workplace. Extinguishers using water, gas, or certain dry chemicals cannot extinguish or control this type of fire.
• Class K. Combustible cooking media (vegetable or animal oils and fats) and cooking appliances are considered Class K hazards. Extinguishers for protecting Class K hazards include wet chemical extinguishers.

Fire detection systems

Fire detection systems do just that — detect fires. They also trigger fire suppression systems and employee alarm systems. It is important that fire detection systems work properly and effectively. Early detection of a fire means faster reaction to the fire, timely notification of employees, and less property damage.

The regulations for fire detection systems at 1910.164 apply to companies that must have fire suppression systems because they are regulated by a specific OSHA standard or paragraphs therein. These include:

• 1910.36 — General requirements — Means of egress
• 1910.106 — Flammable liquids
• 1910.107 — Spray finishing using flammable and combustible materials
• 1910.125 — Additional requirements for dipping and coating operations that use flammable liquids or liquids with flashpoints greater than 199.4 °F (93 °C)
• 1910.109 — Explosives and blasting agents
• 1910.265 — Sawmills

Fire alarm systems

If your facility is faced with a fire emergency, it’s important to protect the safety of employees. You must notify employees of the emergency situation for their safe evacuation from the affected area. The employee alarm system regulations pertain to the maintenance, testing, and inspection of the local fire alarm signaling systems used to alert employees, regardless of the other functions of the system.

Discharge or supervisory alarms required on various fixed extinguishing systems or to supervisory alarms on fire suppression, alarm, or detection systems are not covered under 1910.165 unless they are intended to be employee alarm systems.

Employee alarm systems are designed to provide a warning for necessary emergency action as called for in the emergency action plan, or for reaction time for safe escape of employees from the workplace or the immediate work area, or both if necessary.

Portable fire suppression

Portable fire suppression systems include portable fire extinguishers and standpipe and hose systems.

Fixed fire suppression

In addition to well-maintained exit routes and fire exits, a properly designed and installed fixed fire suppression system enhances fire protection in the workplace. In some cases, fixed fire suppression equipment is required. Fixed fire suppression systems include automatic sprinkler systems and fixed extinguishing systems.

Fire brigades

If a fire occurs at your facility, will your facility’s fire protection equipment, along with the services of the local fire department, be enough to protect your facility and employees? Will the local fire department respond in a timely fashion? If you determine that your facility needs more protection and/or a faster response time than the local fire department can provide, you may decide to organize an in-house fire brigade.

It should be noted that the Fire Brigades Standard at 1910.156 does not require an employer to organize a fire brigade. However, if you do decide to organize a fire brigade, the requirements of the regulation apply.

Respiratory protective devices

Respiratory protection is required to be worn by fire brigade members while working inside buildings or confined spaces where toxic products of combustion or an oxygen deficiency is likely to be present; respirators are also to be worn during emergency situations involving toxic substances. When fire brigade members respond to emergency situations, they may be exposed to unknown contaminants in unknown concentrations. Therefore, it is imperative that fire brigade members wear proper respiratory protective devices during these situations. Additionally, there are many instances where toxic products of combustion are still present during mop-up and overhaul operations. Therefore, fire brigade members should continue to wear respirators during these types of operations.

Self-contained breathing apparatus are not required to be equipped with either a buddy-breathing device or a quick-disconnect valve. However, these accessories may be very useful and are acceptable as long as such accessories do not cause damage to the apparatus, restrict the air flow of the apparatus, or obstruct the normal operation of the apparatus.

Buddy-breathing devices are useful for emergency situations where a victim or another fire brigade member can share the same air supply with the wearer of the apparatus for emergency escape purposes.

The employer is encouraged to provide fire brigade members with an alternative means of respiratory protection to be used only for emergency escape purposes if the self-contained breathing apparatus becomes inoperative. Such alternative means of respiratory protection may be either a buddy-breathing device or an escape self-contained breathing apparatus (ESCBA). The ESCBA is a short-duration respiratory protective device which is approved for only emergency escape purposes. It is suggested that if ESCBA units are used, that they be of at least five minutes’ service life.

Quick-disconnect valves are devices which start the flow of air by insertion of the hose (which leads to the facepiece) into the regulator of self-contained breathing apparatus, and stop the flow of air by disconnecting the hose from the regulator. These devices are particularly useful for those positive-pressure self-contained breathing apparatus which do not have the capability of being switched from the demand to the positive-pressure mode.

The use of a self-contained breathing apparatus where the apparatus can be switched from a demand to a positive-pressure mode is acceptable as long as the apparatus is in the positive-pressure mode when performing interior structural fire fighting operations. Also acceptable are approved respiratory protective devices which have been converted to the positive-pressure type when such modification is accomplished by trained and experienced persons using kits or parts approved by NIOSH and provided by the manufacturer and by following the manufacturer’s instructions.

There are situations which require the use of respirators which have a duration of two hours or more. Long duration apparatus may be needed in such instances as working in tunnels, subway systems, etc.

Protection factor (sometimes called fit factor) is defined as the ratio of the contaminant concentrations outside of the respirator to the contaminant concentrations inside the facepiece of the respirator.

Protection factors are determined by quantitative fit tests. An acceptable quantitative fit test should include the following elements:

1. A fire brigade member who is physically and medically capable of wearing respirators, and who is trained in the use of respirators, dons a self-contained breathing apparatus equipped with a device that will monitor the concentration of a contaminant inside the facepiece.
2. The fire brigade member then performs a qualitative fit test to assure the best face to facepiece seal as possible. A qualitative fit test can consist of a negative-pressure test, positive-pressure test, isoamyl acetate vapor (banana oil) test, or an irritant smoke test. For more details on respirator fitting see the NIOSH booklet entitled “A Guide to Industrial Respiratory Protection” June, 1976, and HEW publication No. (NIOSH) 76-189.
3. The wearer should then perform physical activity which reflects the level of work activity which would be expected during fire fighting activities. The physical activity should include simulated fire-ground work activity or physical exercise such as running-in-place, a step test, etc.
4. Without readjusting the apparatus, the wearer is placed in a test atmosphere containing a non-toxic contaminant with a known, constant, concentration. The protection factor is then determined by dividing the known concentration of the contaminant in the test atmosphere by the concentration of the contaminant inside the facepiece when the following exercises are performed:
   1. Normal breathing with head motionless for one minute;
   2. Deep breathing with head motionless for 30 seconds;
   3. Turning head slowly from side to side while breathing normally, pausing for at least two breaths before changing direction. Continue for at least one minute;
   4. Moving head slowly up and down while breathing normally, pausing for at least two breaths before changing direction. Continue for at least two minutes;
   5. Reading from a prepared text, slowly and clearly, and loudly enough to be heard and understood. Continue for one minute; and
   6. Normal breathing with head motionless for at least one minute.

The protection factor which is determined must be at least 5,000. The quantitative fit test should be conducted at least three times. It is acceptable to conduct all three tests on the same day. However, there should be at least one hour between tests to reflect the protection afforded by the apparatus during different times of the day.

The above elements are not meant to be a comprehensive, technical description of a quantitative fit test protocol. However, quantitative fit test procedures which include these elements are acceptable for determining protection factors. Procedures for a quantitative fit test are required to be available for inspection by the Assistant Secretary or authorized representative.

Organizations such as Los Alamos Scientific Laboratory, Lawrence Livermore Laboratory, NIOSH, and American National Standards Institute (ANSI) are excellent sources for additional information concerning qualitative and quantitative fit testing.

Installation and restoration

Fire detection systems must be designed by engineers or other professionals who are familiar with and have expertise in the design of fire protective systems. All devices or equipment used in the fire detection system’s design and installation must be approved for that purpose.

Perform acceptance tests on the detection system after installation and before placing it into service. These tests determine if the detection system is operable and functioning as intended. Correct any problems uncovered during the acceptance tests before placing the system into service.

After any test or alarm, restore the system to its operating condition as soon as possible. You must have a readily available supply of all detection devices or components that are normally destroyed in the process of detecting fires. The replacements must be on the premises or at a local supplier in sufficient quantities and locations for prompt restoration of the system.

Response time

Make sure the fire detection systems:

• Operate in time to control or extinguish a fire, and
• Provide a warning for emergency action and safe escape of employees, if designed to be an employee alarm and evacuation signal.

Do not delay alarms or devices initiated by fire detector actuation for more than 30 seconds unless it is necessary for the immediate safety of employees. When this delay is necessary, address it in an emergency action plan.

Maintenance and testing

Maintain fire detection systems at all times except during maintenance and repairs. Test and adjust the systems as often as needed to maintain proper reliability and operating condition; except, factory calibrated detectors need not be adjusted after installation. Use only trained personnel, knowledgeable of the system, to perform the servicing, maintenance, and testing of the detection system.

Clean the fire detectors at regular, periodic intervals. They must be cleaned of dirt, dust, or other particulates.

Supervisory systems

All hydraulic and pneumatic operated detection systems must be equipped with supervisory systems if they were installed after January 1, 1981. To provide optimum fire protection, monitor all fire detectors for equipment failures.

Electrically operated sensors can be used for effective monitoring and typical types of supervision for:

• Air pressure
• Fluid pressure
• Electrical circuits

Protection of fire detectors

Locate or protect all detection equipment so that it is protected from any mechanical or physical impact that might make it inoperable. Fire detectors can be protected as follows:

• Use protective coatings or noncorrosive materials for corrosive atmospheres.
• Use canopies, hoods, or other suitable protection for weather protection.
• Use suitable cages or metal guards for protection from physical damage, or locate detectors where their contact with materials or equipment is not possible.
• Make sure detectors are supported independently of their attachment to wires or tubing.

Placement and spacing of detecting devices

OSHA requires that the number, spacing, and location of detectors be based on the following design data:

• Field experience,
• Field tests,
• Manufacturer’s recommendations, or
• Recognized testing laboratory listings.

This information can be obtained from the approved listings for detectors, NFPA standards, fire protection engineers or consultants, and detector manufacturers.

System design

The employee alarm system must be loud enough to be heard, or seen, above all noise and light level throughout your facility. The alarm must be distinctive and recognizable as a signal to evacuate the area or to perform actions specified in the emergency action plan.

Notifying employees

Educate employees so they know how to notify others if they discover an emergency is present:

• Explain to employees the preferred ways of reporting emergencies, such as manual pull box alarms, public address systems, radio, or telephones.
• Post the emergency telephone number(s) near telephones, or employee notice boards, and other conspicuous locations when telephones serve as a means of reporting emergencies.
• When a communication system also serves as the alarm system, all emergency messages must have priority over all non-emergency messages.

Educate employees as to the procedures for sounding alarms in the facility. If your establishment has 10 or fewer employees, direct voice communication is acceptable for sounding the alarm, provided that all employees can hear the alarm. A back-up system is not needed in these facilities.

Maintenance and testing

Test a non-supervised alarm system every two months. Use a different actuation device in each test of a multi-actuation device system so that no individual device is used for two consecutive tests. After each test, quickly restore the system to its normal operating condition.

Maintain or replace power supplies as often as necessary to assure a fully operational condition. Back-up means of alarm, such as employee runners or telephones, must be provided when systems are out of service.

If the alarm circuitry is installed after January 1, 1981, and is capable of being supervised, supervise it and provide positive notification to assigned personnel whenever a deficiency exists in the system. Make sure that all supervised alarm systems are tested at least annually for reliability and adequacy.

Confirm that the person servicing, maintaining, and testing the system is trained in the designed operation and functions necessary for reliable and safe operation of the system.

Portable fire extinguishers

Portable fire extinguishers are designed to be used by employees during the beginning stages of a fire. They contain an extinguishing agent which eliminates one of the vital elements of fire (heat, fuel, or oxygen). If used properly, fire extinguishers can save both lives and property.

Section 1910.157 covers the placement, use, maintenance, and testing of portable fire extinguishers that are provided for employee use. However, the regulation does not apply if you, as an employer:

• Have an established and implemented written fire safety policy. This policy requires the immediate and total evacuation of employees from the facility when the fire alarm signal is sounded; AND
• Have an emergency action plan (EAP) and a fire prevention plan (FPP) that meet the requirements of 29 CFR 1910.38 and 1910.39, respectively; AND
• Do not have fire extinguishers available in the facility.

If 1910.157 applies, your facility’s fire extinguishers must be accepted, certified, listed, or labeled by a nationally recognized testing laboratory. The types of extinguishers in your facility should be determined by the classes of anticipated workplace fires and the size and degree of hazard which would affect their use. Here are some rules of thumb:

Multi-purpose extinguishers (ABC) will handle all A, B, and C fires.

Storage and location

Mount, locate, and identify your fire extinguishers so that they are readily accessible to employees without subjecting themselves to possible injury. Do not put an extinguisher where employees cannot reach it or wherever other equipment is in the way. Make sure the storage location is not in an area where the extinguisher could be damaged. For example, placing an extinguisher in a heavily-traveled forklift aisle might need to be reconsidered.

Keep extinguishers in their designated places at all times, except during use. They should be fully charged and in operable condition.

The location of portable fire extinguishers depends on the fire hazards present:

• Storage location for class A fires: If a class A fire can occur, locate extinguishers so that employees travel no more than 75 feet or less to reach it. You can use standpipe systems or hose stations connected to a sprinkler system instead of class A portable fire extinguishers, if they:
  • Meet the respective requirements of 29 CFR 1910.158 or 1910.159,
  • Provide total coverage of the area to be protected, and
  • Receive annual employee training on their use.

• Storage location for class B fires: Locate fire extinguishers so that the level distance is 50 feet or less from the hazard area.
• Storage location for class C fires: Locate extinguishers for class C fires close to class A or B extinguishers for the same area.
• Storage location for class D fires: Locate extinguishers or other extinguishing agents for class D fires so the travel distance from the combustible metal working area to any extinguishing agent is 75 feet or less.
• Storage location for class K fires: Locate extinguishers near the cooking area. (OSHA does not have a specific location provision for these types of fires.)

Reading fire extinguisher labels

All fire extinguishers should be marked with a symbol indicating the type of fire class on which it should be used. Review Appendix B to NFPA 10, Standard for Portable Fire Extinguishers, to see the types of labels that are on portable fire extinguishers. NFPA offers free access to NFPA 10 at www.nfpa.org/freeaccess.

Employee training

If you provide portable fire extinguishers for employees to use, you must also provide them an educational program to teach them the general principles of fire extinguisher use and the hazards involved with the incipient stage of fire fighting. Provide this training when employees are first hired and then at least once a year thereafter.

Training can include information on:

• How to distinguish between different fires and different fire extinguishers,
• How to operate portable fire extinguishers,
• The capabilities of portable fire extinguishers,
• When to use and when not to use portable fires extinguishers, and
• General fire safety and prevention.

Employees who have been designated to use fire fighting equipment as part of the EAP must be trained in the use of the appropriate equipment. This training must be provided upon initial assignment to the designated group and then at least once a year.

How to use fire extinguishers

Allow only a properly trained employee to use an extinguisher if a fire occurs. When using a typical extinguisher, follow the “PASS” method. This method includes holding the extinguisher upright, and:

• Pulling the pin, standing back eight or ten feet,
• Aiming at the base of the fire,
• Squeezing the handle to release the extinguishing agent, and
• Sweeping at the base of the fire with the extinguishing agent.

Do not aim high at the flames — the fire won’t be put out. Act fast and spray quickly at the base of the fire, not at the smoke or flames because most extinguishers have a very limited operation time (only 8-10 seconds).

When to use a portable fire extinguisher

Because fires are dangerous, it’s critical to know when it’s “safe” to attempt to fight a fire with a portable fire extinguisher. Meet all of the following before attempting to fight a fire:

• The building is completely evacuated.
• Someone is calling the Fire Department.
• The fire is small and confined (a wastebasket fire is considered small and confined).
• You can fight the fire with your back towards a non-threatened escape.
• The extinguisher’s class (A, B, C, D, or K) matches the type of fire involved.
• The extinguisher works effectively.
• You’re trained and confident in extinguisher use.

When NOT to use a portable fire extinguisher

It’s just as important to know when you should evacuate. Don’t attempt to fight a fire if any of these conditions exist:

• The fire is already large or has grown beyond its original confined space.
• The path of escape is threatened.
• You aren’t sure how to use the extinguisher.
• You aren’t sure if the extinguisher is the right type for the fire.

Inspection, maintenance, and testing

As an employer, you are responsible for inspecting, maintaining, and testing the fire extinguishers at your facility. The person within the company responsible for these processes must be trained to do the work and to recognize problem areas that could cause an extinguisher to be inoperable.

Testing of fire extinguishers is done in intervals:

• Once a month: Visually inspect extinguishers.
• Every 12 months: Perform a maintenance check:
  • Record the date of this inspection and retain this record for one year after the last entry or the life of the shell, whichever is less.
  • A stored pressure extinguisher does not require internal examination.

• Every six months: Empty and perform applicable maintenance on stored pressure dry chemical extinguishers that require a 12-year hydrostatic test:
  • Dry chemical extinguishers having non-refillable disposable containers are exempt from this requirement.
  • When recharging or hydrostatic testing is performed, the six-year requirement begins from that date.

Alternate equivalent protection must be provided when extinguishers are removed from service for testing. Options for this protection include:

• Replacing the extinguisher,
• Restricting the unprotected area from employee exposure,
• Providing a hose system that’s ready to operate, or
• Posting a fire watch.

What to look for during a visual inspection

During the monthly visual inspection, make sure the extinguishers are:

• Mounted properly in their designated location;
• Fully charged and ready for use;
• Sealed;
• Free from defects like rust, scratches, dents, missing pins, cracked hoses, broken nozzles, and gauges that don’t measure pressure;
• Appropriately initialed and dated on an inspection tag attached to the extinguisher;
• Labeled with the proper six-year or hydrotest label; and
• Labeled with the original manufacturer’s label or band.

Hydrostatic testing of extinguishers

Hydrostatic testing uses special equipment and precise water pressure to test portable extinguishers. Use only trained workers with suitable testing equipment and facilities to perform this test. This testing must be performed in intervals according to the type of extinguisher.

Exceptions to this requirement are when:

• The extinguisher has been repaired by soldering, welding, brazing, or use of patching compound;
• The cylinder or shell threads are damaged;
• There is corrosion that has caused pitting, including corrosion under removable name plate assemblies;
• The extinguisher has been burned in a fire; or
• A calcium chloride extinguishing agent has been used in a stainless steel shell.

Review the table below from 29 CFR 1910.157(f) to determine when extinguishers in your facility must be hydrostatically tested:

See 1910.157 for more detailed information on the requirements for hydrostatic testing of fire extinguishers.

Standpipe and hose systems

Section 1910.158 was written to provide adequate coverage of those standpipe and hose systems that an employer may install in the workplace to meet the requirements of a particular OSHA standard. For example, OSHA permits the substitution of hose systems for portable fire extinguishers in 1910.157. If you choose to provide hose systems instead of portable Class A fire extinguishers, then those hose systems used for substitution would have to meet the applicable requirements of 1910.157. All other standpipe and hose systems not used as a substitute would be exempt from these requirements.

The section specifically exempts Class I large hose systems. By large hose systems, OSHA means those 21⁄2” (6.3 cm) hose lines that are usually associated with fire departments of the size that provide their own water supply through fire apparatus. When the fire gets to the size that outside protection of that degree is necessary, OSHA believes that in most industries employees will have been evacuated from the fire area and the “professional” fire fighters will take control.

Protection of standpipes

You must make sure that standpipes are protected so that they can be relied upon during a fire emergency. This means protecting the pipes from mechanical and physical damage.

There are various means for protecting the equipment such as, but not limited to, enclosing the supply piping in the construction of the building, locating the standpipe in an area which is inaccessible to vehicles, or locating the standpipe in a stairwell.

Hose covers and cabinets

You should keep fire protection hose equipment in cabinets or inside protective covers which will protect it from the weather elements, dirt, or other damaging sources. The use of protective covers must be easily removed or opened to assure that the hose and nozzle are accessible.

When the employer places hose in a cabinet, the employer must make sure that the hose and nozzle are accessible to employees without subjecting them to injury. In order to make sure that the equipment is readily accessible, you must also make sure that the cabinets used to store equipment are kept free of obstructions and other equipment which may interfere with the fast distribution of the fire hose stored in the cabinet.

Hose outlets and connections

Assure that employees who use standpipe and hose systems can reach the hose rack and hose valve without the use of portable equipment such as ladders. Hose reels are encouraged for use because one employee can retrieve the hose, charge it, and place it into service without much difficulty.

Hose

When you elect to provide small hose in lieu of portable fire extinguishers, those hose stations being used for the substitution must have hose attached and ready for service.

However, if more than the necessary amount of small hose outlets is provided, hose does not have to be attached to those outlets that would provide redundant coverage. Further, where the installation of hose on outlets may expose the hose to extremely cold climates, you may store the hose in houses or similar protective areas and connect it to the outlet when needed.

There is approved lined hose available that can be used to replace unlined hose which is stored on racks in cabinets. The lined hose is constructed so that it can be folded and placed in cabinets in the same manner as unlined hose.

Hose is considered to be unserviceable when it deteriorates to the extent that it can no longer carry water at the required pressure and flow rates. Dry rotted linen or hemp hose, cross threaded couplings, and punctured hose are examples of unserviceable hose.

Nozzles

Variable stream nozzles can provide useful variations in water flow and spray patterns during fire fighting operations and they are recommended for employee use. It is recommended that 100 psi (700kPa) nozzle pressure be used to provide good flow patterns for variable stream nozzles.

The most desirable attribute for nozzles is the ability of the nozzle person to shut off the water flow at the nozzle when it is necessary. This can be accomplished in many ways. For example, a shut-off nozzle with a lever or rotation of the nozzle to stop flow would be effective, but in other cases a simple globe valve placed between a straight stream nozzle and the hose could serve the same purpose. For straight stream nozzles 50 psi nozzle pressure is recommended.

The intent of this standard is to protect the employee from ‘‘run-away’’ hoses if it becomes necessary to drop a pressurized hose line and retreat from the fire front and other related hazards.

Design and installation

OSHA says that standpipe and hose systems designed and installed in accordance with NFPA Standard No. 14, Standpipe and Hose Systems, are considered to be in compliance with this standard.

Automatic sprinkler systems

The most reliable fire fighting device for the workplace, and a key fixed fire suppression system, is the automatic sprinkler system. Through the use of properly spaced sprinkler heads and discharge water flow patterns, the system provides complete coverage for a particular workplace.

OSHA regulates the design, maintenance, and testing of automatic sprinkler systems at 1910.159 when they are required by a specific OSHA standard. These include:

• 1910.36 — General requirements — Means of egress
• 1910.106 — Flammable liquids
• 1910.107 — Spray finishing using flammable and combustible materials
• 1910.125 — Additional requirements for dipping and coating operations that use flammable liquids or liquids with flashpoints greater than 199.4 °F (93 °C)
• 1910.109 — Explosives and blasting agents
• 1910.265 — Sawmills

Design requirements

Your automatic sprinkler system must provide complete coverage for the zone it protects.

The acceptable designs include:

• Pipe schedule designed systems, which depend on standard-sized pipe, the number of sprinklers, and pipe length to give the proper coverage.
• Hydraulic designed systems, which are based on the engineered design of a pipe size to produce a given water density or flow rate at any particular point in the system.

Design and install your automatic sprinkler system with approved materials. The materials used in your system must meet applicable local fire and building codes.

Water supply

Water supply is an important factor in evaluating the protection of an automatic sprinkler system. No water supply or inadequate water supply means no or an inadequate fire protection. An inadequate water supply can be caused by:

• Improperly closed valves,
• Excessive demand,
• Broken water mains, or
• Broken fire pumps.

The water supply for the automatic sprinkler system must be automatic and must provide the designed water flow for at least 30 minutes. In addition, make an auxiliary supply available in the event that the original water supply is not in service. However, if your automatic sprinkler system consists of 20 or fewer sprinklers, then an auxiliary water supply is not necessary.

Provide equivalent protection when you shut down the primary water supply for the sprinkler system. Equivalent protection could include:

• A fire watch with extinguishers in place and hoses manned.
• A secondary water supply, such as a tank truck and pump.
• A tank or fire pond with fire pumps.

In addition, you may want to evacuate the workplace or have an emergency plan that requires evacuation in the event that the primary water supply is shut down.

OSHA does permit the use of hose connections with the sprinkler system for wet pipe systems when the water supply satisfies combined standpipe and sprinkler demands.

Sprinklers

Use only approved sprinklers in your sprinkler system. If a non-standard sprinkler or part must be used as the replacement part, conduct an engineering review of the altered part of the system. The review must show that the changes to the system will not alter the effectiveness of the system as it is presently designed. Water supplies, water densities, and water flow characteristics should remain the same.

Protect all components, pipes, and sprinklers of the automatic sprinkler system against mechanical impact damage. This protection may include:

• Mechanical guards,
• Mechanical screens, or
• Location of system components in areas where physical contact is not possible.

Spacing, as well as the location of the sprinklers, is important to the protection that the system provides. Space the sprinklers to provide the maximum amount of area protection coverage per sprinkler. The placement of sprinklers should minimize the discharge spray interference by the following:

• Building and structural members, and
• Building contents.

Discharge spray interference can result in damage to unprotected areas because the spray pattern is diverted; therefore, any building or structural obstructions must be considered in the design of the automatic sprinkler system.

Sprinkler alarms

When a system has more than 20 sprinklers, an audible local waterflow alarm is required.

The alarm must sound when the waterflow through the system equals the flow from one sprinkler. Use a siren, whistle, flashing light, or similar alerting device as an alarm. The objective is to transmit a recognizable signal to the necessary people. The most popular alarm is the motor gong or bell that sounds when water begins to flow through the system.

Hydraulically designed systems

Make sure the hydraulically designed automatic sprinkler systems, or portions thereof, are identified as such. In addition, indicate the location, number of sprinklers in the hydraulically designed section, and the basis of the design.

Inspection, testing, and maintenance

Ensure the automatic sprinkler system will function in the event of a fire through routine inspections, regular testing, and proper maintenance.

Review the following concerns when inspecting your automatic sprinkler system:

• Are there areas not covered by the system?
• Can the sprinklers distribute their flow properly? Are there any obstructions in the way?
• Have additions been made and do they affect the flow of water or water densities?
• Are materials stored so the clearance distance between sprinklers and the materials below them is more than 18 inches?
• Are the pipes properly secured?
• Are sprinklers properly installed?
• Are the proper sprinklers being used?
• Are the sprinklers coated with deposits?
• Are the sprinklers and pipes corroded?
• Are there any leaks?
• Are the valves for the system opened?

Routine inspections are usually performed by the building owner, but inspections can also be performed by your insurance carrier, the local fire department, or sprinkler contractors.

Another aspect to maintaining an effective automatic sprinkler system is the testing of the system. There are three types of tests:

• Acceptance tests — These tests must be performed before the system is put into service. Invite the installer, designer, your insurance representative, and the local fire department to witness the tests. Include the following as part of the acceptance tests:
  • Flushing of the underground connections,
  • Hydrostatic tests of piping in the system,
  • Air tests in dry-pipe systems,
  • Dry-pipe valve operation, and
  • A test of drainage facilities.

• If any problems are found during the tests, they must be corrected before the system can be placed into service.

• Main drain flow test — Annually perform the main drain flow test on each system after the system is in service.
• Opening of inspector’s test valve — Open the inspector’s valve every two years. This step will assure that the sprinkler system is operating properly.

A system loses effectiveness when it has inoperable sprinklers, leaks, or clogged pipes. Proper maintenance procedures are required to keep the automatic sprinkler system at its optimum. The procedures might include the following:

• Procedures for shutting down the sprinkler system;
• Alternate methods of fire protection:
  • A fire watch with extinguisher in place and hoses manned,
  • A secondary water supply, such as a tank truck and pump, or
  • A tank or fire pond with fire pumps;

• Procedures for replacing sprinklers, including information on:
  • Emergency stocks of sprinklers,
  • Types of sprinklers, and
  • Tools used in the replacement of sprinklers;

• Procedures for pipe repairs; and
• Procedures for recording repairs.

Whenever maintenance on the sprinkler system requires the system to be shut off, the safety of the employees must be the main concern. The maintenance work can only be done when the fire hazard exposure to employees is at a minimum. Perform repairs and changes to the system when employees are not working or are not occupying the area protected by the shutdown system.

If this fire prevention technique is not possible, then alternate methods of fire protection are necessary.

Fixed extinguishing systems

As with the automatic sprinkler systems, OSHA only regulates fixed extinguishing systems when you must comply with a standard that requires an extinguishing system. Additionally, OSHA regulates systems that are total flooding, which causes high concentrations of the extinguishing agent to be released. Some of the effects of high concentrations of extinguishing agents include:

• Visual disorientation if a cloud of a dry chemical agent is released.
• Exposure of employees to hazardous combustion byproducts when agents come in contact with hot metals or surfaces.
• Exposure to hazardous concentrations of the agent.

Fixed extinguishing systems include dry chemical, gaseous agents, water spray, and foam.

Design requirements

The design of a fixed extinguishing system must be based on the type of fire that the system will control or extinguish. The components of the system must be suitable and approved for use with the specific fire hazard. The suppression agent must also be approved for use with the specific fire hazard. Using improper components or unapproved agents would prevent your fixed extinguishing system from controlling or extinguishing the fire.

The design must consider and/or include, depending on your system, the following elements:

• The climate in which the system must operate — The system must be operable in ambient temperature extremes;
• A corrosive atmosphere — The system must be made of noncorrosive materials or protected against corrosion;
• An automatic detection system that complies with 1910.164;
• At least one manual operating station; and
• A distinctive alarm or warning device that complies with 1910.165.

Automatic detection systems

Fixed extinguishing systems require automatic detection equipment. The purpose of the equipment is to:

• Detect fire,
• Activate the suppression system, and
• Possibly activate an employee alarm system.

This equipment must be approved for the application in which it is used. Like the extinguishing system, the effectiveness of the automatic detection system depends on proper installation and maintenance. A poorly installed or maintained detection system could mean an uncontrolled fire with major damage losses.

Alarm system

Use an alarm or signaling system with your extinguishing system to alert employees that the extinguishing system is discharging. The alarm or signaling system must be a distinctive signal that can be perceived above the ambient noise or light levels in the area. The exception is the system for which the discharge is immediately recognizable.

An acceptable alarm can be any of the following, as long as it is identifiable by employees: bell, gong, whistle, horn, flashing light, or combinations of signals.

Signs and warnings

Post signs or warnings to notify employees of areas protected by fixed extinguishing systems. These signs are required when the concentration of the agent is hazardous to the employees. Post the hazard warning or caution signs at the entrance of the inside of these protected areas.

Use safeguards and warnings to prevent employees from entering discharge areas in which the atmosphere remains hazardous to employee safety and health after discharge.

Mark the manual operating devices to identify the hazard they are protecting against.

Inspections and maintenance

Perform an acceptance test on a new detection system to ensure it is operating properly. The acceptance tests must be performed before the system can be put into service. Invite the installer, designer, your insurance representative, and the local fire department to witness the tests. Any problems found during the acceptance test should be corrected before the system is put into service.

Have a person knowledgeable in the design and function of the system inspect the detection system annually to assure the system is in good operating condition.

If a fixed extinguishing system becomes inoperable, inform your employees of the situation and take temporary precautions to ensure their safety until the system is operable again. Any defects or impairments of the system must be corrected by trained personnel.

Besides the system inspection and maintenance, inspect the suppression agent containers for weight and pressure losses, depending on the type of container. The following table shows the time table for this inspection.

Keep a record of the inspection and maintenance on the container, on a tag attached to the container, or in a central location. Maintain this record until the next semi-annual check or for the life of the container, whichever is less.

Personal protective equipment (PPE)

If employees rescue a trapped coworker from an area in which a hazardous agent discharge has occurred, PPE is required. The employer must provide, at a minimum, a positive-pressure self-contained breathing apparatus. First aid equipment should also be provided.

Total flooding systems with potential hazards

If you have total flooding systems that provide agent concentrations exceeding the maximum safe levels, then you must have an emergency action plan in accordance with 1910.38. The following are the maximum safe levels:

• Halon 1211 and carbon dioxide systems — less than 4 percent;
• Halon 1301 systems — less than 10 percent;
• Halon 1301 concentrations are not 7 percent or greater, and egress time is not greater than one minute;
• Halon 1301 concentrations are not 10 percent or greater, and egress time is greater than 30 seconds but less than one minute; and
• Halon 1301 concentrations are not 10 percent or greater, and egress time is not greater than 30 seconds.

If the total flooding systems are installed in an area that employees cannot enter during or after system discharge, the system is exempted from these requirements.

A pre-discharge alarm, which can be perceived above the area noise and light levels, is required. It must be actuated before system discharges, but must allow for safe egress of employees before the system discharges.

This system must have an automatic actuation device by the means of a fire detection device. The pre-discharge alarm and the fire detection device must be interconnected, so employees can safely exit the discharge area before the system discharges.

Dry chemical fixed extinguishing systems

Dry chemical extinguishing systems use a very small particle chemical with expellant to extinguish a fire. The systems consist of the small particle chemical agent, the expellant, and the actuating devices. The system’s discharging method can be either:

• Total flooding — This system is used when the area being protected is totally enclosed. It discharges a prescribed amount of the suppression agent into the contained area.
• Local application — This system discharges directly into the fire. It is used for situations where the hazard can be isolated, such as an open tank of flammable material.

Dry chemical systems must meet the general requirements for fixed extinguishing systems, as well as specific requirements for dry chemical systems. Comply with the following specific requirements for dry chemical agents:

• Make sure the dry chemical is compatible with any foams or wetting agents with which they are used.
• Do not mix together the dry chemical agents of different compositions.
• Refill the system with the dry chemical agent stated on the name plate or an equivalent compatible material.
• Provide an alarm system if the dry chemical discharge can obscure the vision of employees. This alarm must comply with 1910.165 and must provide employees enough time to exit the area before agent discharge.
• Sample the dry chemical supplies at least annually to determine if the supply is free of moisture. Stored pressure systems are exempt from this sampling.
• Reach the designed concentration of the dry chemical agent within 30 seconds of initial discharge.
• Regularly inspect and maintain the system.

Gaseous agent fixed extinguishing systems

Gaseous agents can be used with fixed extinguishing systems to extinguish fires. The agent is usually in the gaseous state in storage, but there are some in the liquid state during storage. Some of the gaseous agents that are used in this type of system are halons, which are being phased out, and carbon dioxide.

Carbon dioxide is an effective extinguishing agent because it dilutes the oxygen content to the point where the atmosphere no longer supports combustion.

As with the dry chemical extinguishing system, a gaseous agent system must comply with the general requirements for fixed extinguishing systems and the specific requirements for gaseous agents. Comply with the following specific requirements for gaseous agent systems:

• Confirm that the agent’s initial supply and its replenishment supply is an approved type for the system’s application.
• Do not expose employees to toxic concentrations of the agent or its decomposition products.
• Use a pre-discharge alarm that can be perceived above the area noise and light levels. The alarm must be actuated before the system discharges, allowing employees to safely evacuate the discharge area. This requirement is for systems with the following designed discharge concentrations:
  • Halon 1211 and carbon dioxide at a concentration of four percent or greater.
  • Halon 1301 at a concentration of 10 percent or greater.

The following requirements are only for total flooding systems:

• Maintain the designed concentration of the gaseous agent at all times, especially until a fire has been extinguished or is under control. When a system is being overhauled, it is exempt from this requirement.
• Attain the designed extinguishing concentration within 30 seconds of initial discharge. Halon systems must reach designed concentration within 10 seconds of initial discharge.
• Use Halon 1301 only under the following conditions:
  • Halon 1301 concentrations are seven percent or less, and egress times are one minute or less.
  • Halon 1301 concentrations are 10 percent or less, and egress times are greater than 30 seconds but less than one minute.
  • Halon 1301 concentrations are greater than 10 percent in an area not normally occupied by employees, and egress times are less than 30 seconds. No unprotected employees can enter the area during discharge.

• Regularly inspect and properly maintain the gaseous agent so it is effective.

Water spray and foam fixed extinguishing systems

The last type of fixed extinguishing system includes the:

• Water spray system — The water spray system extinguishes the fire by dilution, cooling, and smothering. It consists of the following elements:
  • A reliable water source,
  • Nozzles or similar devices,
  • Piping, and
  • A drainage system.

• Foam system — The foam system prevents or stops combustion by forming a blanket between the horizontal surface of the fire. This blanket acts as a coolant, vapor sealant, and barrier between the air and the burning surface. Foam systems consist of the following:
  • A reliable water source,
  • An air supply,
  • A foam generation device,
  • Foam distribution devices, and
  • A drainage system.

Foam systems have definite limitations. Consider the following limitations when selecting the type of foam for the specific hazard:

• Some foams are not acceptable for use on fires involving flammable gases or liquefied gases with boiling points below ambient workplace temperatures.
• Some foams are not effective on polar solvents.
• Foams using water as part of the mixture should not be used on combustible metals. If the temperature of the burning metal is reduced below its ignition temperature, then only authorized foams can be used.
• Certain foams may be incompatible and break down when they are mixed.
• Foams used for water soluble solvents must be tested and approved for such use.

OSHA requires that water spray and foam systems meet the general requirements for fixed extinguishing systems and the specific ones for water spray and foam systems.

If you have a water spray or foam system, comply with the following requirements:

• The design of the system must effectively control the fire in the protected areas or equipment.
• The system must provide for proper drainage facilities for the water or foam. The drainage system must direct the flow of the water or foam:
  • Away from work areas,
  • Away from emergency egress routes, and
  • Toward a central collection area.

Pre-fire planning

It is suggested that pre-fire planning be conducted by the local fire department and/or the workplace fire brigade in order for them to be familiar with the workplace and process hazards. Involvement with the local fire department or fire prevention bureau is encouraged to facilitate coordination and cooperation between members of the fire brigade and those who might be called upon for assistance during a fire emergency.

Organizational statement

In addition to the information required in the organizational statement, required under 1910.156(b)(1), it is suggested that the organizational statement also contain the following information: a description of the duties that the fire brigade members are expected to perform; the line authority of each fire brigade officer; the number of the fire brigade officers and number of training instructors; and a list and description of the types of awards or recognition that brigade members may be eligible to receive.

Physical capability

The physical capability requirement applies only to those fire brigade members who perform interior structural fire fighting. Employees who cannot meet the physical capability requirement may still be members of the fire brigade as long as such employees do not perform interior structural fire fighting. It is suggested that fire brigade members who are unable to perform interior structural fire fighting be assigned less stressful and less physically demanding fire brigade duties, e.g., certain types of training, recordkeeping, fire prevention inspection and maintenance, and fire pump operations.

Physically capable can be defined as being able to perform those duties specified in the training requirements of 1910.156(c). Physically capable can also be determined by physical performance tests or by a physical examination when the examining physician is aware of the duties that the fire brigade member is expected to perform.

It is also recommended that fire brigade members participate in a physical fitness program. There are many benefits which can be attributed to being physically fit. It is believed that physical fitness may help to reduce the number of sprain and strain injuries as well as contributing to the improvement of the cardiovascular system.

Fire brigade training and education

The regulatory paragraph on training and education does not contain specific training and education requirements because the type, amount, and frequency of training and education will be as varied as are the purposes for which fire brigades are organized. However, the paragraph does require that training and education be commensurate with those functions that the fire brigade is expected to perform; i.e., those functions specified in the organizational statement. Such a performance requirement provides the necessary flexibility to design a training program which meets the needs of individual fire brigades.

At a minimum, hands-on training is required to be conducted annually for all fire brigade members. However, for those fire brigade members who are expected to perform interior structural fire fighting, some type of training or education session must be provided at least quarterly.

In addition to the required hands-on training, it is strongly recommended that fire brigade members receive other types of training and education such as: classroom instruction, review of emergency action procedures, pre-fire planning, review of special hazards in the workplace, and practice in the use of self-contained breathing apparatus.

It is not necessary for the employer to duplicate the same training or education that a fire brigade member receives as a member of a community volunteer fire department, rescue squad, or similar organization. However, such training or education must have been provided to the fire brigade member within the past year and it must be documented that the fire brigade member has received the training or education. For example: there is no need for a fire brigade member to receive another training class in the use of positive-pressure self-contained breathing apparatus if the fire brigade member has recently completed such training as a member of a community fire department. Instead, the fire brigade member should receive training or education covering other important equipment or duties of the fire brigade as they relate to the workplace hazards, facilities and processes.

It is generally recognized that the effectiveness of fire brigade training and education depends upon the expertise of those providing the training and education as well as the motivation of the fire brigade members. Fire brigade training instructors must receive a higher level of training and education than the fire brigade members they will be teaching.

This includes being more knowledgeable about the functions to be performed by the fire brigade and the hazards involved. The instructors should be qualified to train fire brigade members and demonstrate skills in communication, methods of teaching, and motivation. It is important for instructors and fire brigade members alike to be motivated toward the goals of the fire brigade and be aware of the importance of the service that they are providing for the protection of other employees and the workplace.

It is suggested that publications from the International Fire Service Training Association, the National Fire Protection Association (NFPA-1041), the International Society of Fire Service Instructors and other fire training sources be consulted for recommended qualifications of fire brigade training instructors.

In order to be effective, fire brigades must have competent leadership and supervision. It is important for those who supervise the fire brigade during emergency situations, e.g., fire brigade chiefs, leaders, etc., to receive the necessary training and education for supervising fire brigade activities during these hazardous and stressful situations. These fire brigade members with leadership responsibilities should demonstrate skills in strategy and tactics, fire suppression and prevention techniques, leadership principles, pre-fire planning, and safety practices. It is again suggested that fire service training sources be consulted for determining the kinds of training and education which are necessary for those with fire brigade leadership responsibilities.

It is further suggested that fire brigade leaders and fire brigade instructors receive more formalized training and education on a continuing basis by attending classes provided by such training sources as universities and university fire extension services.

The following recommendations should not be considered to be all of the necessary elements of a complete comprehensive training program, but the information may be helpful as a guide in developing a fire brigade training program.

All fire brigade members should be familiar with exit facilities and their location, emergency escape routes for handicapped workers, and the workplace “emergency action plan.”

In addition, fire brigade members who are expected to control and extinguish fires in the incipient stage should, at a minimum, be trained in the use of fire extinguishers, standpipes, and other fire equipment they are assigned to use. They should also be aware of first aid medical procedures and procedures for dealing with special hazards to which they may be exposed. Training and education should include both classroom instruction and actual operation of the equipment under simulated emergency conditions. Hands-on type training must be conducted at least annually but some functions should be reviewed more often.

In addition to the above training, fire brigade members who are expected to perform emergency rescue and interior structural fire fighting should, at a minimum, be familiar with the proper techniques in rescue and fire suppression procedures. Training and education should include fire protection courses, classroom training, simulated fire situations including “wet drills” and, when feasible, extinguishment of actual mock fires. Frequency of training or education must be at least quarterly, but some drills or classroom training should be conducted as often as monthly or even weekly to maintain the proficiency of fire brigade members.

There are many excellent sources of training and education that the employer may want to use in developing a training program for the workplace fire brigade. These sources include publications, seminars, and courses offered by universities.

There are also excellent fire school courses by such facilities as Texas A and M University, Delaware State Fire School, Lamar University, and Reno Fire School, that deal with those unique hazards which may be encountered by fire brigades in the oil and chemical industry.

These schools, and others, also offer excellent training courses which would be beneficial to fire brigades in other types of industries. These courses should be a continuing part of the training program, and employers are strongly encouraged to take advantage of these excellent resources.

It is also important that fire brigade members be informed about special hazards to which they may be exposed during fire and other emergencies. Such hazards as storage and use areas of flammable liquids and gases, toxic chemicals, water-reactive substances, etc., can pose difficult problems. There must be written procedures developed that describe the actions to be taken in situations involving special hazards. Fire brigade members must be trained in handling these special hazards as well as keeping abreast of any changes that occur in relation to these special hazards.

Fire fighting equipment

It is important that fire fighting equipment that is in damaged or unserviceable condition be removed from service and replaced. This will prevent fire brigade members from using unsafe equipment by mistake. Fire fighting equipment, except portable fire extinguishers and respirators, must be inspected at least annually. Portable fire extinguishers and respirators are required to be inspected at least monthly.

Protective clothing

Paragraph (e) of 1910.156 does not require all fire brigade members to wear protective clothing. It is not the intention of these standards to require employers to provide a full ensemble of protective clothing for every fire brigade member without consideration given to the types of hazardous environments to which the fire brigade member might be exposed.

It is the intention of these standards to require adequate protection for those fire brigade members who might be exposed to fires in an advanced stage, smoke, toxic gases, and high temperatures. Therefore, the protective clothing requirements only apply to those fire brigade members who perform interior structural fire fighting operations.

Additionally, the protective clothing requirements do not apply to the protective clothing worn during outside fire fighting operations (brush and forest fires, crash crew operations) or other special fire fighting activities. It is important that the protective clothing to be worn during these types of fire fighting operations reflect the hazards which are expected to be encountered by fire brigade members.

Foot and leg protection

Section 1910.156 permits an option to achieve foot and leg protection. The section recognizes the interdependence of protective clothing to cover one or more parts of the body. Therefore, an option is given so that fire brigade members may meet the foot and leg requirements by either wearing long fire-resistive coats in combination with fully extended boots, or by wearing shorter fire-resistive costs in combination with protective trousers and protective shoes or shorter boots.

Body protection

Paragraph (e)(3) of 1910.156 provides an option for fire brigade members to achieve body protection. Fire brigade members may wear a fire-resistive coat in combination with fully extended boots, or they may wear a fire-resistive coat in combination with protective trousers.

Fire-resistive coats and protective trousers meeting all of the requirements contained in NFPA 1971-1975, Protective Clothing for Structural Fire Fighting, are acceptable as meeting the requirements of this standard.

The lining is required to be permanently attached to the outer shell. However, it is permissible to attach the lining to the outer shell material by stitching in one area such as at the neck. Fastener tape or snap fasteners may be used to secure the rest of the lining to the outer shell to facilitate cleaning. Reference to permanent lining does not refer to a winter liner which is a detachable extra lining used to give added protection to the wearer against the effects of cold weather and wind.

Hand protection

The requirements of the paragraph on hand protection may be met by protective gloves or a glove system. A glove system consists of a combination of different gloves. The usual components of a glove system consist of a pair of gloves, which provide thermal insulation to the hands, worn in combination with a second pair of gloves which provide protection against flame, cut, and puncture.

It is suggested that protective gloves provide dexterity and a sense of feel for objects. Criteria and test methods for dexterity are contained in the NIOSH publications, The Development of Criteria for Firefighters’ Gloves: Vol. I: Glove Requirements and Vol. II: Glove Criteria and Test Methods. These NIOSH publications also contain a permissible modified version of Federal Test Method 191, Method 5903, (paragraph (3) of appendix E) for flame resistance when gloves, rather than glove material, are tested for flame resistance.

Head, eye, and face protection

Head protective devices which meet the requirements contained in NFPA No. 1972 are acceptable as meeting the requirements of this standard for head protection.

Head protective devices are required to be provided with ear flaps so that the ear flaps will be available if needed. It is recommended that ear protection always be used while fighting interior structural fires.

Many head protective devices are equipped with face shields to protect the eyes and face. These face shields are permissible as meeting the eye and face protection requirements of this paragraph as long as such face shields meet the requirements of 1910.133 of the General Industry Standards.

Additionally, full facepieces, helmets or hoods of approved breathing apparatus which meet the requirements of 1910.134 and paragraph (f) of 1910.156 are also acceptable as meeting the eye and face protection requirements. It is recommended that a flame resistant protective head covering such as a hood or snood, which will not adversely affect the seal of a respirator facepiece, be worn during interior structural fire fighting operations to protect the sides of the face and hair.

Respiratory protective devices

Respiratory protection is required to be worn by fire brigade members while working inside buildings or confined spaces where toxic products of combustion or an oxygen deficiency is likely to be present; respirators are also to be worn during emergency situations involving toxic substances. When fire brigade members respond to emergency situations, they may be exposed to unknown contaminants in unknown concentrations. Therefore, it is imperative that fire brigade members wear proper respiratory protective devices during these situations. Additionally, there are many instances where toxic products of combustion are still present during mop-up and overhaul operations. Therefore, fire brigade members should continue to wear respirators during these types of operations.

Self-contained breathing apparatus are not required to be equipped with either a buddy-breathing device or a quick-disconnect valve. However, these accessories may be very useful and are acceptable as long as such accessories do not cause damage to the apparatus, restrict the air flow of the apparatus, or obstruct the normal operation of the apparatus.

Buddy-breathing devices are useful for emergency situations where a victim or another fire brigade member can share the same air supply with the wearer of the apparatus for emergency escape purposes.

The employer is encouraged to provide fire brigade members with an alternative means of respiratory protection to be used only for emergency escape purposes if the self-contained breathing apparatus becomes inoperative. Such alternative means of respiratory protection may be either a buddy-breathing device or an escape self-contained breathing apparatus (ESCBA). The ESCBA is a short-duration respiratory protective device which is approved for only emergency escape purposes. It is suggested that if ESCBA units are used, that they be of at least five minutes’ service life.

Quick-disconnect valves are devices which start the flow of air by insertion of the hose (which leads to the facepiece) into the regulator of self-contained breathing apparatus, and stop the flow of air by disconnecting the hose from the regulator. These devices are particularly useful for those positive-pressure self-contained breathing apparatus which do not have the capability of being switched from the demand to the positive-pressure mode.

The use of a self-contained breathing apparatus where the apparatus can be switched from a demand to a positive-pressure mode is acceptable as long as the apparatus is in the positive-pressure mode when performing interior structural fire fighting operations. Also acceptable are approved respiratory protective devices which have been converted to the positive-pressure type when such modification is accomplished by trained and experienced persons using kits or parts approved by NIOSH and provided by the manufacturer and by following the manufacturer’s instructions.

There are situations which require the use of respirators which have a duration of two hours or more. Long duration apparatus may be needed in such instances as working in tunnels, subway systems, etc.

Protection factor (sometimes called fit factor) is defined as the ratio of the contaminant concentrations outside of the respirator to the contaminant concentrations inside the facepiece of the respirator.

Protection factors are determined by quantitative fit tests. An acceptable quantitative fit test should include the following elements:

1. A fire brigade member who is physically and medically capable of wearing respirators, and who is trained in the use of respirators, dons a self-contained breathing apparatus equipped with a device that will monitor the concentration of a contaminant inside the facepiece.
2. The fire brigade member then performs a qualitative fit test to assure the best face to facepiece seal as possible. A qualitative fit test can consist of a negative-pressure test, positive-pressure test, isoamyl acetate vapor (banana oil) test, or an irritant smoke test. For more details on respirator fitting see the NIOSH booklet entitled “A Guide to Industrial Respiratory Protection” June, 1976, and HEW publication No. (NIOSH) 76-189.
3. The wearer should then perform physical activity which reflects the level of work activity which would be expected during fire fighting activities. The physical activity should include simulated fire-ground work activity or physical exercise such as running-in-place, a step test, etc.
4. Without readjusting the apparatus, the wearer is placed in a test atmosphere containing a non-toxic contaminant with a known, constant, concentration. The protection factor is then determined by dividing the known concentration of the contaminant in the test atmosphere by the concentration of the contaminant inside the facepiece when the following exercises are performed:
   1. Normal breathing with head motionless for one minute;
   2. Deep breathing with head motionless for 30 seconds;
   3. Turning head slowly from side to side while breathing normally, pausing for at least two breaths before changing direction. Continue for at least one minute;
   4. Moving head slowly up and down while breathing normally, pausing for at least two breaths before changing direction. Continue for at least two minutes;
   5. Reading from a prepared text, slowly and clearly, and loudly enough to be heard and understood. Continue for one minute; and
   6. Normal breathing with head motionless for at least one minute.

The protection factor which is determined must be at least 5,000. The quantitative fit test should be conducted at least three times. It is acceptable to conduct all three tests on the same day. However, there should be at least one hour between tests to reflect the protection afforded by the apparatus during different times of the day.

The above elements are not meant to be a comprehensive, technical description of a quantitative fit test protocol. However, quantitative fit test procedures which include these elements are acceptable for determining protection factors. Procedures for a quantitative fit test are required to be available for inspection by the Assistant Secretary or authorized representative.

Organizations such as Los Alamos Scientific Laboratory, Lawrence Livermore Laboratory, NIOSH, and American National Standards Institute (ANSI) are excellent sources for additional information concerning qualitative and quantitative fit testing.