OSHA Fire Extinguisher Requirements May Surprise You

The Occupational Safety and Health Administration (OSHA) prohibits employees from using a portable fire extinguisher unless they’ve been trained to recognize when and how to use it. Organizations are required to provide this training when employees are first hired and annually thereafter. Employers are also advised to establish a policy clarifying who is qualified to use fire extinguishers, the situations in which they can and should be used, and the proper procedures for use.

This is not the only requirement for fire extinguisher use that may be surprising.

Curtis Chambers, CSP, president of OSHA Training Services, provided the following commonly asked questions (and answers) about portable fire extinguishers he’s encountered while conducting mock OSHA inspections. Chambers made clear that employers operating in states with approved state-OSHA programs should check their state-OSHA requirements, which could vary from those of federal OSHA.

Does OSHA require employers to document monthly equipment inspections?

Chambers: OSHA requires a visual inspection of all portable extinguishers be performed at least monthly, but does not have a requirement for documentation of monthly inspections, whereas the mandatory annual inspections and periodic maintenance inspections do have to be documented. Many employers choose to document their monthly inspections anyway. In fact, most inspection tags that are attached to portable extinguishers after their annual inspections have a 12-month grid on the back where an inspector can enter the date and initials when the monthly inspections are performed.

Be warned, however, OSHA has cited employers using these tags as evidence that monthly inspections were not performed because, even though the back of the tag 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. In other words, if you want to go above and beyond, be religious about it or else your lackluster recordkeeping can come back to bite you.

Does OSHA require documentation of the training sessions?

Chambers: There is no requirement to document the initial or annual refresher training and education sessions. Again, though, many employers find it easier to manage this aspect of their health and safety programs by using a system to document these sessions. Make sure that you capture the names of all trained employees attending the sessions. And more importantly, go back and identify all those workers who were absent due to sickness, vacation or other reasons on training day and get them into a make-up session so you can document their attendance.

How high above the floor does OSHA require extinguishers to be mounted?

Chambers: OSHA requires that the employer shall mount portable fire extinguishers so they are accessible to employees. There is no height requirement listed. However, in OSHA’s e-Tool for Evacuation Plans and Procedures, the agency states the following: “To prevent fire extinguishers from being moved or damaged, they should be mounted on brackets or in wall cabinets with the carrying handle placed 3-1/2 to 5 feet above the floor. Larger fire extinguishers need to be mounted at lower heights with the carrying handle about 3 feet from the floor.”

Two other considerations for mounting height are your local fire code (which may specify a tighter range) and local building codes, which often incorporate guidelines from the Americans with Disabilities Act or newer versions of the National Fire Protection Association standard for portable extinguishers.

How high do the ‘Fire Extinguisher’ signs need to be installed above the extinguishers?

Chambers: OSHA only requires extinguishers be “identified.” While an extinguisher mounted to a wall may be clearly visible from up close, they may be blocked from view if a person is standing a distance away. Materials stacked on pallets or shelving could prevent the extinguisher from being seen, as could open doorways or parked equipment like forklifts. Therefore, it is usually best to install a sign (or other means of identification) above a portable fire extinguisher so its location can be identified from a distance in case it is obstructed from view. How high? Depending on jobsite conditions, there are many cases where the fire extinguisher sign (or other means of identification) needs to be placed very high (near the ceiling) above fire extinguishers (as opposed to right on top of it) to enable them to be located when the previously mentioned obstacles are present.

Roy Maurer is an online editor/manager for SHRM.

Follow him at @SHRMRoy

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