Scenario: You are the safety manager of a fairly large, light industrial and warehousing operation. There are approximately 200 fire extinguishers throughout your complex of several buildings, supplied and serviced by an outside vendor. However, your company maintenance department has the responsibility for conducting monthly visual inspections of them. Currently, each extinguisher has an inspection tag attached and the maintenance personnel who inspect the extinguishers dates and initials the tag once they conduct their visual check. While you are training your maintenance personnel on how to inspect a fire extinguisher your maintenance manager comes to you with a request. He has looked at the OSHA standard concerning monthly inspections and shows you the citation: “OSHA 1910.157(e)(2) Portable extinguishers or hose used in lieu thereof under paragraph (d)(3) of this section shall be visually inspected monthly.” He points out that nothing in the standard requires this monthly inspection be documented, and requests your permission to discontinue the practice of initialing and dating the inspection tags attached to each extinguisher. If not documenting the inspections is unacceptable, he requests permission to just keep a file stating the extinguishers have been inspected, the date they were inspected, and by whom.
Question: Does OSHA require documentation of the monthly inspection and if so, what form of documentation is acceptable?
Answer: A letter of interpretation from OSHA dated November 29, 2006 to Mr. Daniel J. Roberts, Manager of Industrial Safety with Exelon Nuclear, Exelon Corporation, may shed some light on the answer. Mr. Roberts was asking OSHA if he could reduce the frequency of his monthly visual inspections. OSHA references the 2002 edition of the National Fire Protection Association (NFPA) Standard No. 10, “Portable Fire Extinguishers,” which states that: “Fire extinguishers shall be inspected when initially placed in service and thereafter at approximately 30-day intervals. Fire extinguishers shall be inspected, manually or by electronic monitoring, at more frequent intervals when circumstances require.” So as you can see when delving into the minutia for fire extinguishers, OSHA refers back to NFPA 10 and considers it as a consensus standard.
If you take a look at the current NFPA10 Standard for Portable Fire Extinguishers, it states in 7.2.4 Frequent Inspections (which is described as the monthly visual inspections earlier in the chapter) that these inspections must be recorded and when done manually, the date conducted and the initials of the individual conducting the inspection must be provided. It allows for the records to be kept on the tag attached to the fire extinguisher, on an inspection checklist kept on file, or in an electronic format. It goes on to state records must be kept to demonstrate that at least the last 12 months of inspections have been conducted.
So the answer is yes, you must document the inspections. However, the information can be kept on file rather than attached to the extinguisher. Either way, you need to have some record available if OSHA should ask.
Click below on link below to download a monthly fire extinguisher inspection checklist showing how to inspect a fire extinguisher: