Must You Provide Classroom Type Instruction to Satisfy 29cfr1910.157g
Does OSHA Require Hands On or Classroom Style Training For Fire Extinguishers?
Scenario: You are the safety manager of a medium sized manufacturing company. In the past, you provided annual fire extinguisher training to a number of employees who have been designated able to fight incipient stage fires as part of your emergency action plan. Your policy has been to supply portable fire extinguishers and designate certain employees as authorized to use them to fight fires. All other employees in the fire area are required to evacuate the affected area immediately upon the sounding of a fire alarm. You have always been of the belief that this choice implicitly requires you to establish an emergency action plan meeting the requirements of [1910.38] and comply with the requirements in 1910.157(c), (e), (f), (g)(3) and (g)(4) regarding general requirements for fire extinguishers as well as inspection, maintenance and testing, hydrostatic testing, and training. Your fire extinguisher training has always consisted of classroom instruction and a practical hands on element for those designated to fight incipient fires.
Your company hired a new Human Recourses Manager to whom you now report. This manager tells you that going forward you are to provide educational materials, without classroom instruction, through the use of instruction sheets or flyers for those designated to fight incipient stage fires with the fire extinguishers provided by your employer. You believe your boss is wrong and you use 29cfr1910.157(g) as your argument. Are you correct?
Answer: In a letter of Interpretation by OSHA involving emergency action plans and the use of fire extinguishers the following is stated:
29 CFR 1910.157(g)(1) [and (2)] requires that, where an employer has provided portable fire extinguishers for employee use in the workplace, he 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 and training in the use of appropriate equipment. The education shall be provided upon initial employment and at least annually thereafter. In meeting the requirements of these standards, the employer may provide educational materials, without classroom instruction, through the use of employee notice campaigns using instruction sheets or flyers or similar types of informal programs; or he may provide on site training which exposes employees to the actual “feeling” of fire fighting by simulated fires for training employees in the proper use of extinguishers.