Tuesday, October 1, 2013

Is Hands-on Fire Extinguisher Training Required?

One question I get  asked a lot during mock-OSHA inspections is whether or not the Federal OSHA standards for portable fire extinguishers requires employees to do “hands on” training with extinguishers. And the answer is not as simple as “yes” or “no”; a better answer would be, “it depends”.
 
First of all, the assumption is that unless you told them otherwise, it is reasonable to assume that any employee at your workplace could pick up a portable fire extinguisher hanging in their work area and try to use it to extinguish a fire should one start.  Therefore, 1910.157(g)(1) states that “Where the employer has provided portable fire extinguishers for employee use in the workplace, the employer shall also provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage fire-fighting.”  The standard goes on to explain in paragraph (g)(2) that the education required in paragraph (g)(1) “must be provided to employees upon initial employment and at least annually thereafter.”
   
So does “education” require hands-on training? If you refer to the definitions for Subpart L that appear in 1910.155, you will find that paragraph (c)(14) defines "Education" as . . . . .
 
 
 

15 comments:

  1. Curtis, I really appreciate your free blogs and tool-box articles. I found the following in the OSHA Fact Sheet "Fire Safety in the Workplace", "If you expect your workers to use portable fire extinguishers, you must provide hands-on training in using this equipment".

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    1. Thank you for your comments. The entire text of that paragraph in the OSHA Fact Sheet you referenced is:

      "Do employers have to provide portable fire extinguishers? No. But if you do, you must establish an educational program to familiarize your workers with the general principles of fire extinguisher use. If you expect your workers to use portable fire extinguishers, you must provide hands-on training in using this equipment."

      If you read this carefully, you will see this is consistent with my message in the blog, which is if you simply make extinguishers available for use, you must provide education, but if you expect (or designate, or assign) someone to use them, you must provide them hands-on training. Any other thoughts on this?

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  2. Great information. Debra

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  3. Hands on is the best experience to safe and accurate operation of these safety equipment that is clearly marked for fast retrieval, and accurate operations. If you do not put the fire extinguisher in their hands and they get the feel of how to operate when the time arises.....as small little trash can fire can erupt into a blazing inferno in minutes.

    Taught Public Fire Prevention and Education for over 10 years. Hands on is the best training method for deliverance of material topic and clear understanding on how too.

    Tell someone how to fish and they will go hungry
    Teach Someone To Fish and they'll never go hungry

    I can tell a firefighter recruit how to operate a fire hose.....it's not until they actually have the hose in their hands and they learn how to operate the hose correctly. Roy Poteete

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  4. In terms of OSHA's Subpart L, see 1910.155 for the definitions of education and training. This 1980 Subpart is the "grandfather" of performance standards as employers have several options that they may choose from in terms of incipient stage fire fighting (ISFF, which is also defined in the 1910.155 standard).

    That is, education is required when all employees are to perform ISFF pursuant to 1910.157(g)(1) and (g)(2). And pursuant to 1910.157(g)(3) and (g)(4), training is required when an employer designates certain employees who are responsible for ISFF activities. Two other options are available and include the utilization of a fire bridge for ISFF, which means an employer must train employees in ISFF in accordance with 1910.156. Lastly, an employer may choose to totally evacuate a workplace in the event of a fire if they comply with emergency action [1910.38] and fire prevention [1910.39] plans [pursuant to 1910.157(b)(1).]

    Wow, this seems like a bunch of stuff to consider. However, OSHA provided employers with a number of options in their 1st performance standard -- i.e., in order to provide flexibility while protecting employees.

    FYI, I revised the OSHA "FIGHT -- NO FIGHT" decision tree that was initially issued by the Agency in 1980. You may find and use this flowchart on my Ocean View Safety FaceBook page at: https://www.facebook.com/pages/Ocean-View-Safety/401270106587310

    Hope this helps.
    Walter Siegfried CSP, MS

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  5. This clarification for fire protection training was very useful. Thanks for giving several workplace scenarios! Brad

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  6. Thanks Curtis for the info!

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  7. This is a good article but I do think that you should be more clear when discussing the requirement for a "fire watch" when welding. I know that this is not a Welding, Cutting, and Brazing article but simply stating that 1910.252 requires a fire watch when welding or cutting is being performed is a partially incorrect statement. OSHA requires fire watchers only when certain conditions exist. If the below situations do not exist, no fire watchers are required when welding, then 1910.157(g) does not come in to play. Unless of course, the employer is requiring that employees use fire extinguishers in the workplace.

    1910.252(a)(2)(iii)(A)
    Fire watchers shall be required whenever welding or cutting is performed in locations where other than a minor fire might develop, or any of the following conditions exist:
    1910.252(a)(2)(iii)(A)(1)
    Appreciable combustible material, in building construction or contents, closer than 35 feet (10.7 m) to the point of operation.
    1910.252(a)(2)(iii)(A)(2)
    Appreciable combustibles are more than 35 feet (10.7 m) away but are easily ignited by sparks.
    1910.252(a)(2)(iii)(A)(3)
    Wall or floor openings within a 35-foot (10.7 m) radius expose combustible material in adjacent areas including concealed spaces in walls or floors.
    1910.252(a)(2)(iii)(A)(4)
    Combustible materials are adjacent to the opposite side of metal partitions, walls, ceilings, or roofs and are likely to be ignited by conduction or radiation.

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    1. Good point. When I stated in the blog that the OSHA standards for welding and cutting "mandate that a trained fire-watch be stationed nearby when hot work is being conducted", I was operating under the assumption that the readers would understand that "hot work" does not comprise "all" welding/cutting operations, just those which are conducted in areas not designated for regular welding and cutting. So if you are welding in your welding shop, that would not be covered, but if you were welding inside an office building (for example, to add a steel support above a dropped ceiling to support a new overhead projector), then the hot-work rules would apply (including the use of a trained fire watch. Thanks for the clarification.

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  8. excellent source of info

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  9. So my EHS person does annual training, but it does not include any Fire Extinguisher training, he simply says employees are not allowed to use the extinguishers they are for the Fire Department. My response to that is the Fire Department has these large trucks and hoses they use to fight fires and that the extinguishers are for internal use on potential small fires that could be extinguished before becoming large fires. Is there a standard EHS directive that tells EHS people to make sure their employees are told they can't use Fire Extinguishers and if an employee does, what are the repercussions? I juts don't see a point in having them if we can't use them.

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    1. As explained in this post . . . If an employer writes into their emergency action plan and fire prevention plan (covered in 1910.38 and 1910.39, respectively) that all (or certain) employees will immediately evacuate the building in case of a fire and that no one is to use an extinguisher (and train those employees about the plans), then neither education or training is required in portable fire extinguisher use for those employees. This assumes, of course, that there is no situation existing that specifically mandates someone trained in portable fire extinguisher use be available, such as in the welding standard previously mentioned.

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  10. My question is, do you just have your employees practice with a fire extinguisher, or do you have to have someone certified as a trainer to do the hands on?

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    1. Only those employees assigned a job that requires them to use a fire extinguisher (such as a fire watch or fire brigade member) are Required by Federal OSHA to have hands on fire extinguisher training. Everyone else is just required to be provided with "information/education" such as the free toolbox talks and o line tutorials offered on our website. There are no "certified instructor" requirements, just someone who is knowledgeable in their use . . . Check with your fire extinguisher vendor or the local fire department, they often will provide the training for free!

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  11. If an employer has hazardous/ flammable chemicals in their workplace (minimal amounts), would the employer be required to train desingated employees for portable fire extinguisher use (like in the welding example)?

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