THE COHEN GROUP
  Environmental Health & Safety Consulting Services

The Cohen Group Newsletter - Volume 7  Issue 2, Article 3.  April, 2005

  Fire Extinguishers
Are You Required to Have Them?
By Tim Bormann, CIH

Among the most common questions we are asked by employers are those relating to requirements for portable fire extinguishers. Cal/OSHA has many regulations on portable fire extinguishers, but the most extensive requirement can be found in Title 8 California Code of Regulations, Section 6151 of the General Industry Safety Orders. This article will address the most common questions we receive.

First, employers are exempt from this regulation under the following conditions (unless fire extinguishers are required by another Cal/OSHA requirement):

" The employer has established and implemented a written safety policy which requires the immediate and total evacuation of employees from the workplace upon sounding the fire alarm and includes an emergency action plan and a fire prevention plan which meets the requirements of Sections 3220 (emergency action plan) and 3221 (fire prevention plan) and when fire extinguishers are not available in the work place"

However, although not always required by Cal/OSHA, most buildings are required to have fire extinguishers by the local fire department through the Uniform Fire Code.

When fire extinguishers are present, Section 6151 requires the employer to ensure that the fire extinguishers are regularly inspected, maintained and tested. The extinguishers must receive a monthly "quick check" that the fire extinguisher is available and will operate. This is done by verifying that the fire extinguisher is in its designated place; that it has not been actuated or tampered with and that there is no obvious physical damage or condition to prevent its operation. Fire extinguishers must also receive an annual maintenance check. This includes a thorough examination and any necessary repair or replacement. Monthly inspections and annual maintenance checks must be documented. Each fire extinguisher commonly has a tag where the monthly inspection can be documented. In addition, the tag must also indicate the last time the extinguisher received the annual maintenance check. Inspections and maintenance can also be recorded electronically, but records must be available for review by the fire department or Cal/OSHA.

Cal/OSHA requires that fire extinguishers be mounted, located and identified so that they are readily accessible to employees. The fire extinguishers must be maintained in a fully charged and operable condition and kept in their designated places, except during use. Of course selecting the right fire extinguisher is crucial. There are 4 primary classes of fires and fire extinguishers:

· Class A – Ordinary Combustibles
· Class B – Flammable Liquids
· Class C – Electrical Equipment
· Class D – Combustible Metals

Many extinguishers are rated for 2 or more classes. Combination (e.g., Class A/B/C) extinguishers have numerical ratings which indicate their relative extinguishing effectiveness. A typical marking on a multi-purpose extinguisher might read 2-A: 20-B: C. The higher the number, the greater the extinguishing potential for that class of fire.

Cal/OSHA also designates maximum travel distances to fire extinguishers depending on the class of the fire. Class A and Class D fires extinguishers must be located so that the travel distance for employees is 75 feet or less. For Class B extinguishers the travel distance is 50 feet or less. Fire extinguishers used for Class C fires must be distributed on the basis of the appropriate patterning for Class A or Class B fires.

Even though your building may be required to have fire extinguishers, there is no requirement to use them. Use (or policy against use) of fire extinguishers should be clearly spelled out in your emergency action plan and fire prevention plan as well as during your employee safety training.

Employees can only use fire extinguishers if they have been specifically trained. Where the employer provides fire extinguishers for employee use, the employees must receive annual training. The time of the fire is not the time to learn how to use a fire extinguisher. While there is no requirement for "hands-on" use of the fire extinguisher during training, some fire departments may provide this service.

The Cohen Group can assist you in preparing an emergency action plan (8 CCR §3220) or a fire prevention plan (8 CCR §3221). We can also assist you in your training needs.