Part 4 Of The Guide To Understanding The OSHA Requirements For Portable Fire Extinguishers

Travis Jolliff

This is the final Part 4 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 focused on the General Requirements and Exemptions to Requirements while Part 2 in the series focused on the Selection and Distribution Requirements. Part 3 in the series focused on the Inspection, Maintenance and Testing Requirements. This final Part 4 in the series will focus on Hydrostatic Testing Requirements

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)]

Hydrostatic testing requirements

An employer must:

  • Assure that hydrostatic testing is performed by trained persons with suitable testing equipment and facilities. [29 CFR 1910.157(f)(1)]
  • Assure that portable extinguishers are hydrostatically tested at the intervals listed in Table L-1, except under any of the following conditions [29 CFR 1910.157(f)(2)]:
    • When the unit has been repaired by soldering, welding, brazing, or use of patching compounds. [29 CFR 1910.157(f)(2)(i)]
    • When the cylinder or shell threads are damaged. [29 CFR 1910.157(f)(2)(ii)]
    • When there is corrosion that has caused pitting, including corrosion under removable name plate assemblies. [29 CFR 1910.157(f)(2)(iii)]
    • When the extinguisher has been burned in a fire. [29 CFR 1910.157(f)(2)(iv)]
    • When a calcium chloride extinguishing agent has been used in a stainless steel shell. [29 CFR 1910.157(f)(2)(v)]
  • Assure that an internal examination of cylinders and shells to be tested is made before the hydrostatic tests in addition to an external visual examination. [29 CFR 1910.157(f)(3)]
  • Assure that portable fire extinguishers are hydrostatically tested whenever they show new evidence of corrosion or mechanical injury, except under the conditions listed in paragraphs (f)(2)(i)-(v). [29 CFR 1910.157(f)(4)]
  • Assure that hydrostatic tests are performed on extinguisher hose assemblies that are equipped with a shut-off nozzle at the discharge end of the hose. The test interval must be the same as specified for the extinguisher. [29 CFR 1910.157(f)(5)]
  • Hydrostatically test carbon dioxide hose assemblies with a shut-off nozzle at 1,250 psi (8,620 kPa). [29 CFR 1910.157(f)(6)]
  • Hydrostatically test dry chemical and dry powder hose assemblies with a shut-off nozzle at 300 psi (2,070 kPa). [29 CFR 1910.157(f)(7)] Hose assemblies passing a hydrostatic test do not require any type of recording or stamping. [29 CFR 1910.157(f)(8)]
  • Test hose assemblies for carbon dioxide extinguishers within a protective cage device. [29 CFR 1910.157(f)(9)]
  • Test carbon dioxide extinguishers and nitrogen or carbon dioxide cylinders used with wheeled extinguishers every five years at 5/3 of the service pressure as stamped into the cylinder. Nitrogen cylinders that comply with 49 CFR 173.34(e)(15) may be hydrostatically tested every 10 years. [29 CFR 1910.157(f)(10)]
  • Hydrostatically test stored pressure and Halon 1211 types of extinguishers at the factory test pressure, not to exceed two times the service pressure. [29 CFR 1910.157(f)(11)]
  • Test self-generating type soda acid and foam extinguishers at 350 psi (2,410 kPa). [29 CFR 1910.157(f)(12)]
  • Do not use air or gas pressure for hydrostatic testing. [29 CFR 1910.157(f)(13)]
  • Remove from service extinguisher shells, cylinders, or cartridges that fail a hydrostatic pressure test, or that are not fit for testing. [29 CFR 1910.157(f)(14)]
  • Ensure that the equipment for testing compressed gas type cylinders be of the water jacket type. The equipment must have an expansion indicator that operates with an accuracy within 1 percent of the total expansion or .1cc (.1mL) of liquid. [29 CFR 1910.157(f)(15)(i)]
  • Ensure that the equipment for testing non-compressed gas type cylinders includes the following [29 CFR 1910.157(f)(15)(ii)]:
    • A hydrostatic test pump, hand or power operated, capable of producing at least 150 percent of the test pressure, which must include appropriate check valves and fittings. [29 CFR 1910.157(f)(15)(ii)(A)]
    • A flexible connection for attachment to fittings to test through the extinguisher nozzle, test bonnet, or hose outlet, as is applicable. [29 CFR 1910.157(f)(15)(ii)(B)]
    • A protective cage or barrier for personal protection of the tester, designed to provide visual observation of the extinguisher under test. [29 CFR 1910.157(f)(15)(ii)(C)]
  • Maintain and provide upon request to the Assistant Secretary evidence that the required hydrostatic testing of fire extinguishers has been performed at the time intervals shown in Table L-1. Such evidence must be in the form of a certification record that includes:
    • The date of the test.
    • The signature of the person who performed the test.
    • The serial number, or other identifier, of the fire extinguisher that was tested.

Such records must be kept until the extinguisher is hydrostatically re-tested at the time interval specified in Table L-1 or until the extinguisher is taken out of service, whichever comes first. [29 CFR 1910.157(f)(16)]

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