Part 1 Of The Guide To Understanding The OSHA Requirements For Portable Fire Extinguishers

Travis Jolliff

This is Part 1 of a 4 part series of articles intended to provide a better understanding and detailing of the OSHA requirements for portable fire extinguishers since a thorough understanding of requirements and expectations is the first step in becoming compliant. The applicable governing regulations and sections are identified where appropriate to allow the reader a ready reference for additional research. While this article does not provide every detail of the applicable requirements it should provide enough information to give the reader a good grasp of the scope and nature of the OSHA requirements for portable fire extinguishers in the workplace.  Collectively, the 4 part series of articles will cover:

  • General Requirements;
  • Exemptions from requirements;
  • Selection and distribution requirements;
  • Inspection, maintenance and testing requirements; and
  • Hydrostatic testing requirements

Part 1 in the series will focus on the OSHA General Requirements and Exemptions to OSHA Requirements for portable fire extinguishers

In all cases, the requirements detailed in each part of the series of articles will only apply to the placement, use, maintenance, and testing of portable fire extinguishers provided in a workplace intended for the use of employees.

The requirements detailed in the articles do not apply to fire extinguishers provided for employee use on the outside of workplace buildings or structures.

In those cases where fire 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 [29 CFR 1910.38], then only the requirements detailed in the articles that address the inspection, maintenance and testing and hydrostatic testing requirements will  apply. [29 CFR 1910.157(a)]

General OSHA requirements for portable fire extinguishers

An employer 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. [29 CFR 1910.157(c)(1)]
  • Use only approved portable fire extinguishers. [29 CFR 1910.157(c)(2)]
  • Do not use portable fire extinguishers that use carbon tetrachloride or chlorobromomethane extinguishing agents. [29 CFR 1910.157(c)(3)]
  • Assure that portable fire extinguishers are maintained, fully charged, operating properly, and kept in designated places at all times except during use. [29 CFR 1910.157(c)(4)]
  • Remove from service all soldered or riveted shell self-generating soda acid or self-generating foam or gas cartridge water type portable fire extinguishers that are operated by inverting the extinguisher to rupture the cartridge or to initiate an uncontrollable pressure generating chemical reaction to expel the agent. [29 CFR 1910.157(c)(5)]

Exemptions from OSHA requirements for portable fire extinguishers

The following exemptions apply:

  • Where the employer has established and implemented a written fire safety policy which requires the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal and which includes an emergency action plan and a fire prevention plan that meet the requirements of 29 CFR 1910.38 and 29 CFR 1910.39 respectively, and when extinguishers are not available in the workplace, the employer is exempt from all requirements of this section unless a specific standard in Part 1910 requires that a portable fire extinguisher be provided. [29 CFR 1910.157(b)(1)]
  • Where the employer has an emergency action plan meeting the requirements of 29 CFR 1910.38, which designates certain employees to be the only employees authorized to use the available portable fire extinguishers, and which requires all other employees in the fire area to immediately evacuate the affected work area upon the sounding of the fire alarm, the employer is exempt from the distribution requirements in the selection and distribution section. [29 CFR 1910.157(b)(2)]

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