“The cleverest of all, in my opinion, is the man who calls himself a fool at least once a month.” Fyodor Dostoevsky
OSHA does not require fire extinguishers. Not in most work places. The fire extinguishers that are in most work places are there because of insurance requirements. To use a fire extinguisher requires going toward danger and OSHA prefers that employees go away from danger.
However, if fire extinguishers are installed in the work place, OSHA has requirements. There are requirements about the kind of fire extinguishers to use and how they should be distributed. There are requirements about annual training for employees that will use fire extinguishers. There requirements about maintaining and inspecting fire extinguishers. It is this last requirement, about maintenance and inspections, that catches many work places off guard.
What Maintenance and Inspection?
There are four types of maintenance and inspection:
- Monthly visual inspection
- Annual maintenance
- Hydrostatic testing every 5 or 12 years, depending on the type of extinguisher
- Six-year maintenance, for rechargeable extinguishers subject to 12 year hydrostatic testing
The last three will all be performed by a licensed fire extinguisher maintenance contractor, or as OSHA puts it, “trained persons with suitable testing equipment and facilities”. Because the last three are done professionally by an outside contractor, there is not much point in going into detail about the required maintenance and testing. Generally, it is enough to know that it needs to be done.
The first requirement, however, the monthly visual inspection, can be done in-house by just about anyone. This is good thing since the visual inspection is supposed to be done monthly.
What to Inspect?
OSHA defines an inspection very simply as “a visual check of fire protection systems and equipment to ensure that they are in place, charged, and ready for use in the event of a fire.” That suggests a three-point checklist:
- Is the fire extinguisher in the correct location and accessible?
- Is the fire extinguisher full?
- Does the gauge or pressure indicator show the correct pressure?
Most safety professionals are uncomfortable with such a short list, however, so the internet has literally hundreds from which to choose if a more complicated checklist seems necessary. After all, anything worth doing is worth overdoing. Here is a compilation of a dozen different checklists:
- Is the fire extinguisher mounting hardware secure?
- Is the fire extinguisher is in its designated location?
- Is the fire extinguisher unobstructed, visible, and accessible?
- Is the fire extinguisher free from obvious physical damage or corrosion?
- Is the locking pin intact?
- Is the tamper seal unbroken?
- Is there no evidence of leakage from the fire extinguisher body, valve, hose, or nozzle?
- Do the nozzle and hose show no evidence being clogged or damaged?
- Does the gauge or pressure indicator show the pressure in the operable range or position?
- Does physically lifting the fire extinguisher confirm that it feels full?
- Are all labels, tags, and operating instructions on the nameplate legible and facing outward?
- Does the tag show that it has been no more than 12 months since the last professional servicing by a licensed fire maintenance contractor?
- Are there initials and dates on the back of the tag that show that fire extinguisher inspections are being conducted monthly?
These thirteen questions make a fine checklist, not only going into more detail on the basic three questions, but also including questions to assure and validate compliance with the standard.
What is “Monthly”?
Some OSHA regulations use a term like “annually” and OSHA means “no less often than once every 365 days (366 days during leap years)”. The design of the tag on fire extinguishers indicates that annual maintenance is to be done by the end of the anniversary month. That is, if the most recent annual maintenance was done on October 3, the next annual maintenance must be completed by October 31 of the following year.
So what does OSHA mean when it says that portable fire extinguishers “shall be visually inspected monthly”?
Does it mean every 30 days? Does it mean on same date of each month, e.g. January 15, February 15, March 15? Does it mean once during each calendar month? If the latter is true, then that would suggest that an inspection of July 1 followed by an inspection on August 31 (61 days apart) would be in compliance.
In a letter of interpretation dated 29-Nov-2006, OSHA refers to an older version of NFPA 10, Standard for Portable Fire Extinguishers, that states that monthly inspections means inspections “at approximately 30 day intervals.” That has been OSHA’s last word on the subject. That provides for some leeway, but it would be difficult to defend a 61 day interval as “approximately 30 days.”
In the most current version of NFPA 10, the 2013 Edition, the requirement is spelled out as “At least once per calendar month” [§184.108.40.206.1] and “not exceeding 31 days” [§220.127.116.11]. In the explanatory material in Appendix A, §A.18.104.22.168 indicates that inspection should be conducted 12 times per year, at least once per month. OSHA does not enforce NFPA 10, but NFPA codes are often cited as examples of good practice.
So, there is some flexibility, but not so much that a 61 day interval would be in compliance. There is some discussion in various internet forums of a 10-day grace period, but a “grace period” is never mentioned in any of the standards. If an inspection does slip, return to the originally scheduled date on the next inspection, e.g. April 19, May 23, June 19. Regardless, there should be at least one inspection in each calendar month.
Do the Inspections
If you have fire extinguishers, inspect them. Inspect them monthly, by whatever criteria for “monthly” you can offer without feeling foolish. The inspections do not have to be complicated and can be done by anyone. Keep a record of the inspections, just on the chance that you will need to prove that you have done them. But most importantly, do the inspections.