5.4 Extinguishers: fight it or leave

1 Three policies, three sets of duties

There is also a fourth case in (a): where extinguishers are provided but not intended for employee use and the employer has an EAP and a fire prevention plan meeting 1910.38 and 1910.39, only paragraphs (e) and (f) — inspection, maintenance, testing and hydrostatic testing — apply.

2 The general and distribution rules

(c)(1): extinguishers must be mounted, located and identified so that they are readily accessible to employees without subjecting them to possible injury. (c)(2): only approved extinguishers. (c)(4): maintained in a fully charged and operable condition and kept in their designated places at all times except during use.

Travel distance is where paragraph (d) gets specific, and the numbers are worth knowing:

• (d)(2) — for Class A fires, the travel distance for employees to any extinguisher must be 75 feet or less.
• (d)(4) — for Class B fires, the travel distance from the Class B hazard area to any extinguisher must be 50 feet or less.
• (d)(5) — Class C extinguishers are distributed on the pattern appropriate to the existing Class A or Class B hazards.
• (d)(6) — for Class D, the travel distance from the combustible metal working area to any extinguishing agent must be 75 feet or less; extinguishers are required where combustible metal powders, flakes or shavings are generated at least once every two weeks.

"Readily accessible" in (c)(1) and 1910.178(m)(14) — fire aisles, access to stairways and fire equipment kept clear — are the two paragraphs a stack of pallets in front of an extinguisher violates simultaneously.

3 Inspection, maintenance and testing

Paragraph (e) sets a rhythm that is easy to run and easy to forget.

1. 1
   (e)(2) — extinguishers must be visually inspected monthly. In place, unobstructed, seal intact, gauge in the green, no obvious damage, instructions facing out.
2. 2
   (e)(3) — an annual maintenance check. Stored-pressure extinguishers do not require internal examination. The employer records the annual maintenance date and retains the record for one year after the last entry or the life of the shell, whichever is less.
3. 3
   (e)(4) — stored-pressure dry chemical extinguishers that require a 12-year hydrostatic test must be emptied and subjected to applicable maintenance procedures every 6 years. Non-refillable disposable containers are exempt.
4. 4
   (e)(5) — when an extinguisher is removed from service for maintenance or recharging, alternate equivalent protection must be provided. A gap on the wall is not acceptable while the unit is at the service shop.

Hydrostatic testing intervals are in Table L-1 of paragraph (f), and (f)(2) lists the conditions that require testing regardless of interval — repair by soldering, welding, brazing or patching; damaged shell threads; corrosion that has caused pitting, including under a removable nameplate; an extinguisher that has been burned in a fire; and calcium chloride agent used in a stainless steel shell. Our fire extinguisher monthly log prints the monthly record this paragraph implies.

4 Training: two different obligations

Paragraph (g) contains two duties that are easy to conflate, and the distinction is the whole point of the section.

(g)(1) and (g)(2) — education for everyone. Where the employer has provided extinguishers for employee use, the employer must also provide an educational program to familiarize employees with the general principles of extinguisher use and the hazards involved with incipient stage fire fighting — on initial employment and at least annually thereafter.

(g)(3) and (g)(4) — training for the designated group. Employees designated to use firefighting equipment as part of an emergency action plan must be trained in the use of the appropriate equipment, on initial assignment to that group and at least annually thereafter.

Notice the wording. Everyone gets education about principles and about the hazards of fighting even a small fire. The designated few get training on the equipment. That is a deliberate distinction: OSHA is not encouraging general employees to fight fires, it is making sure that if extinguishers are on the wall, people know both how they work and why using one may be the wrong choice.

5 Using one, and knowing when not to

The mechanics take a sentence: pull the pin, aim at the base of the flames from the edge of the effective range, squeeze the handle, sweep side to side. The judgment takes longer, and it is four questions asked in order.

1. 1
   Has the alarm been raised and are people leaving? That happens first, always. Never instead of it.
2. 2
   Is the fire still small and contained? Roughly waste-basket scale. If it is into the racking or the packaging, the answer is no.
3. 3
   Is the extinguisher right for this fire, and big enough? Wrong class can make it worse — water on energized equipment, or anything but a Class D agent on combustible metal.
4. 4
   Is your back to a clear way out? If your exit is past the fire, you have already answered the question.

Any "no" means leave. One cylinder gives you seconds of discharge, and smoke — not flame — is what stops people getting out.

6 Closing the course

Five parts, and one thread through all of them: warehouse hazards are the ordinary work done at scale. Nothing in this course was exotic. Aisles that stay clear, a truck examined before it runs, an operator who has been evaluated, racks that are rated and undamaged, lifts designed at the right height, exits nobody stacks against — every item is a routine decision that has to be made the same way on a Tuesday in February as during peak.

The final exam covers all five parts, and four questions are flagged as safety-critical. Nothing is issued for completing it: it is a check on what stuck. If you want the practical side of the forklift material, the forklift operator practice test and the Forklift Operator Basics course go deeper on the machine itself — and neither of them, nor this course, substitutes for the training and evaluation your employer owes you under 1910.178(l).