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Commonly Asked Questions About Portable Fire Extinguishers
Answers to Five Commonly Asked Questions About Portable Fire Extinguishers
November 1, 2014 - It’s been a little over a year since I posted a blog explaining Federal OSHA’s requirements to provide education and training on portable fire extinguishers to workers when there are extinguishers available for their use. Since that time, some readers have emailed me with other questions about extinguishers; the same questions that come up quite often when I conduct mock-OSHA inspections. While I could probably ramble on answering fifteen or twenty of these recurring questions today, I decided to post answers to five commonly-asked questions about portable fire extinguishers in my blog.
Federal OSHA standard 1910.157(c)(1) simply states 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, they state 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 (they may specify a tighter range) and local building code, which often incorporate guidelines from the Americans with Disabilities Act (ADA) or newer versions of the NFPA standard for portable extinguishers.
According to the previously-mentioned ADA guidelines, objects mounted to the wall with their leading edges located between 27" and 80" above the finished floor must not protrude more than four inches into walkways, corridors, passageways, or aisles. Recessed cabinets help employers meet this guideline when mounting portable extinguishers in these areas of a building. So while this is not a Federal OSHA requirement, the ADA guidelines may be incorporated into your local fire code and/or building code.
Federal OSHA regulation 1910.157(c(1) only require 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 from the extinguisher. 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 job site conditions, there are many cases where the fire extinguisher sign (or other means of identification) needs to be place very high (up near the ceiling) above fire extinguishers (as opposed to right on top of it, like I see so often) to enable them to be located when the previously-mentioned obstacles are present.
Federal OSHA standard 1910.157(e)(2), which requires a visual inspection of all portable extinguishers be performed at least monthly, 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 chose 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 back of them where an inspector can enter the date and their initials whenever they perform the monthly inspections.
However, be warned; 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 lack-luster record-keeping can come back to bite you in the butt!
Paragraph (g) of the Federal OSHA standards for portable fire extinguishers covers training and education requirements. 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 portable fire extinguisher training and education sessions. But the same principle that applies to the missed monthly inspection records can also get you here. Make sure that you capture the names of ALL trained employees attending these training sessions. And more importantly, go back and identify all those workers who were off work due to sickness, vacation, or other reasons on training day and get them into a make-up session so you can document their attendance.
Please remember that employers operating in states having their own approved State-OSHA programs should check their State-OSHA requirements, which could vary from those of Federal OSHA that I have outlined above.
Have you been asked these questions about portable fire extinguishers before? Perhaps you have some additional information about these issues that you’d like to share? If you do have further information pertinent to this topic, please click here and entering your comment in the “Comments” box. And last but not least, I would like to encourage you to Share this Blog post with others in your Network who might benefit from reading this information.
ABOUT THE AUTHOR:
Curtis Chambers is a Certified Safety Professional (CSP) and holds a Master of Science degree in Occupational Safety and Health. He has held numerous leadership positions managing and evaluating health and safety programs and providing training on workplace safety and health topics at various public organizations and private corporations. Mr. Chambers is currently the President of OSHA Training Services Inc. Visit their website at www.oshatraining.com.
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