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 what ever 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, monthly fire extinguisher inspections are required and states at 6.2.1 that “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.”

OSHA has cited employers using these tags as evidence that monthly inspections were not performed. Even though the tag’s back had several months with the initials in place to document the inspections were conducted, there was one (or more) month where the initials were not entered. If you decide to follow the best practice, not required by OSHA, ensure that every month is documented. The extinguishers should be tagged so monthly inspections can be recorded and when each unit is placed in service. Then within one year, each fire extinguisher will require an annual inspection. Per NFPA 10, 4-3.1 Frequency, fire extinguishers shall be inspected when initially placed in service and after that at 30-day intervals. Fire extinguishers shall be inspected at more frequent intervals when circumstances require. This initial check is like the monthly check and isn’t an annual check inspection.

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