Employers

Are You Fire Ready?

If you expect your workers to use firefighting equipment, you should give them appropriate equipment and train them annually to use the equipment safely.

Industrial fires are one of the most dangerous and common workplace hazards. Data from the Bureau of Labor statistics say that fires and explosions account for up to 3 percent of workplace fatalities. And while the Occupational Safety and Health Administration addresses fire safety in specific standards, such as Fire Prevention Plans, Fire Detection Systems, and Employee Alarm Systems, OSHA is not the only authority that governs your facility when it comes to fire safety. State and local codes, as enforced by local fire authorities, also must be followed.

Fire Inspections
Your local fire authorities will inspect your facility once or twice a year, usually. Your liability insurance carrier may also do a walk-through of your property. Employers are often faced with such a bewildering array of different requirements from a variety of federal, state, and local agencies that fire and life safety can sometimes be overlooked and fire inspections are often viewed with trepidation. However, the employer should use these fire inspections, regardless of the source, as an opportunity to learn. Accompany the inspector and take the time to ask about ways to make your workplace safer. Ask any specific questions you might have or general questions about topics such as storage or use of particular products. Your local fire inspector also may direct you to other resources, such as arranging a visit from emergency responders to discuss first aid supplies or emergency medical procedures.

The Inspection Report
Fire inspection findings will be documented on the fire inspection report. Upon completion of the inspection, a copy of the report, including any violations, will be provided or sent to the employer.

Fees or citations may be assessed for violations, along with the timeframe for correcting them. A re-inspection may be scheduled to ensure that violations have been corrected.

The employer should keep the report and document all completed corrective actions.

Employee Training
Employers should train workers about fire hazards in the workplace and about what to do in a fire emergency. If you want your workers to only sound the alarm and evacuate, you should train them on how to sound the alarm and how to escape. If you expect your workers to use firefighting equipment, you should give them appropriate equipment and train them annually to use the equipment safely.

Emergency Evacuation Plans
Employers are to have an emergency action plan that explains evacuation routes and procedures employees should use in emergencies. It also should detail procedures for accounting for all evacuated employees when they reach the assembly area. The written plan must be available for employee review. Where needed, the plan must address special procedures for helping physically impaired employees; also, the plan must include procedures for those employees who must temporarily remain behind to shut down critical plant equipment before they evacuate.

The emergency action plan must include the preferred means of alerting employees of a fire emergency. The employee alarm system must be available and functional throughout the facility. The means of alerting employees must be distinct and only used for that purpose.

Employers must review the plan with newly assigned employees so they know correct actions in an emergency and with all employees when the plan is changed.

Fire Prevention Plans
OSHA standards that require fire prevention plans include the following:

  • Ethylene Oxide, 1910.1047
  • Methylenedianiline, 1910.1050
  • 1,3 Butadiene, 1910.1051

Employers covered by these standards must implement a fire prevention plan. All fire prevention plans must:

  • Be available for employee review
  • Include housekeeping procedures for storage and cleanup of flammable materials and flammable waste
  • Address handling and packaging of flammable waste. (Recycling of flammable waste such as paper is encouraged.)
  • Cover procedures for controlling workplace ignition sources such as smoking, welding, and burning
  • Provide for proper cleaning and maintenance of heat-producing equipment such as burners, heat exchangers, boilers, ovens, stoves, and fryers and require storage of flammables away from this equipment
  • Inform workers of the potential fire hazards of their jobs and plan procedures
  • Require plan review with all new employees and with all employees whenever the plan is changed

Fire Extinguishers
OSHA does not require that you provide fire extinguishers unless they are specifically required by an OSHA standard. However, fire extinguishers may be required by your local fire or building code. If you do provide fire extinguishers for your employees' use, you are required to train them on the general principles of fire extinguisher use and fire hazards. Fire extinguisher training must be done upon initial hire and at least annually thereafter and must include hands-on training.

The employer must inspect, maintain, and test all portable fire extinguishers in the workplace. This means a monthly visual inspection to determine that extinguishers are properly mounted and identified and are properly charged.

Fire extinguishers also require an annual maintenance check. Stored pressure extinguishers do not require an internal examination. Record the annual maintenance date and retain this record for one year after the last entry or the life of the shell, whichever is less.

Common issues include: missing extinguishers, extinguishers not properly mounted, failure to perform maintenance, or lack of maintenance records.

Exits and Exit Routes
If you talk to fire inspectors about exits and exit routes, there are common issues that they see frequently:

One issue is that of blocked exits. OSHA and the fire codes require that exit routes must be free and unobstructed and that no materials or equipment may be placed, either permanently or temporarily, within the exit route. Often, we are told that employees will inadvertently place materials or equipment in an exit route "just for a while." But that is still a violation.

If you have facilities that are located in areas that get snow and winter weather, you need to consider the condition of outside exit discharge routes. Employers commonly get cited because outside discharge routes have not been shoveled or there isn’t a clear path to the street, assembly area, or open space.

Illumination Testing and Maintenance
The lamps for emergency and exit lighting and exit door marking can burn out or the fixtures can be damaged. It is important that employers conduct routine inspections of exit lighting and signs to identify any issue and then take action to correct deficiencies.

The code being enforced by your local authorities will have the required inspection, testing, and maintenance schedule for emergency lighting and for exit sign lighting. Typically, inspection and testing is required every month.

Storage of Hazardous Materials
Another common problem is that of hazardous materials in the facility—specifically handling, use, storage, and disposal. One inspector we spoke with said that it isn't so much an issue of negligence, but incremental change. "You sometimes see where a facility starts using more hazardous material, or they change their storage location or the way they dispose of it changes. It usually isn't anything more than a lack of attention, a lack of knowledge," he said.

This can result in a facility not properly storing hazardous materials, storing larger amounts than are allowed, having inadequate ventilation in the storage area, or having a problem developwith how the waste materials are collected and stored prior to disposal.

Recordkeeping
Employers must maintain, and make available to the fire inspector, documentation and records associated with fire protection systems and services. A fire inspector will typically review these records during each routine inspection.

Records could include inspection and maintenance records for alarm systems, sprinklers, or fire extinguishers, or the company's safety data sheet file. Fire inspectors wish to see these records updated, stored, and organized so that they can be easily retrieved. "These facilities know we are going to be coming," one fire inspector told me, "and yet many of them still act surprised when we ask to see these records—the things we ask to look at each time."

Conclusion
Routine fire inspections are a fact of life. Knowing that the fire inspector will ask to see the same types of records each time and creating an up-to-date file of those records can make the process more effective and efficient.

Integrating fire safety into the workplace safety and health program, and addressing life and safety issues as they come up, helps to develop a safer and less stressful workplace, especially where fire safety is involved.

Common Violations
Some common hazards and code violations encountered by fire personnel conducting routine fire inspections include:

  • Address numbering visibility (6" numbers)
  • Locked/blocked/obstructed exits and doors
  • Non-functional emergency and exit lighting
  • Use of extension cords as permanent wiring
  • "Piggy-backed" power strips
  • Breaker panel clearance (30"W x 36"D x 78"H)
  • Combustible storage in mechanical rooms
  • Obstructed fire hydrants or fire department connections (FDCs)
  • Sprinkler head clearance to storage
  • Fire extinguishers not mounted on brackets
  • Lack of monthly alarm pull station testing

This article originally appeared in the March 2016 issue of Occupational Health & Safety.

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