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OSHA 1910.156

Fire brigades requirements

Subpart L

29 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.156(a)(1)-(2), when does the fire brigades standard apply and who is excluded?

The fire brigades standard applies when an employer establishes a fire brigade at the workplace; it covers organization, training, and PPE requirements for those brigades. See 1910.156(a)(1) and the application rules in 1910.156(a)(2).

  • The rule covers industrial fire departments, private or contractual fire departments, and employer-established fire brigades.
  • Personal protective equipment requirements apply only to members performing interior structural firefighting.
  • The standard does not apply to airport crash rescue or forest firefighting operations; those activities are excluded by 1910.156(a)(2).

Under 1910.156(b)(1), what must an employer include in the written organizational statement for a fire brigade?

The employer must prepare and keep a written organizational statement that establishes the existence and basic structure of the fire brigade and describe training, size, and functions. See 1910.156(b)(1).

  • Required elements include: a statement that the fire brigade exists; the basic organizational structure; the type, amount, and frequency of training; expected number of members; and the functions the brigade will perform.
  • The organizational statement must be available for inspection by OSHA (the Assistant Secretary) and by employees or their representatives as specified in 1910.156(b)(1).

Under 1910.156(b)(2), what medical restrictions apply to employees expected to perform interior structural firefighting?

Employees expected to perform interior structural firefighting must be physically capable and cannot be allowed to participate if they have known heart disease, epilepsy, or emphysema unless they provide a physician's certificate of fitness. See 1910.156(b)(2).

  • The employer must assure physical capability for duties assigned during emergencies.
  • A physician's certificate is required for employees with the specified conditions before they may participate.
  • For employees assigned before September 15, 1980, the medical restriction became effective on September 15, 1990, per the timing language in 1910.156(b)(2).

Under 1910.156(c)(1)-(2), when must fire brigade members be trained and how often?

All fire brigade members must be trained before they perform emergency activities, and training must be frequent enough to ensure safe, satisfactory performance—at least annually for all members and at least quarterly for those expected to perform interior structural firefighting. See 1910.156(c)(1) and 1910.156(c)(2).

  • Leaders and instructors must receive more comprehensive training than general members (1910.156(c)(1)).
  • Quarterly refresher training or education is required for members expected to do interior structural firefighting (1910.156(c)(2)).

Under 1910.156(c)(3)-(4), what quality standards and special hazards must fire brigade training include?

Fire brigade training must be comparable in quality to established fire training schools and must inform members about special hazards and written procedures for dealing with them. See 1910.156(c)(3) and 1910.156(c)(4).

  • Training programs should be similar to those at recognized institutions (examples are listed in 1910.156(c)(3)).
  • Employers must inform members about hazards such as flammable liquids/gases, toxic chemicals, radioactive sources, and water-reactive materials, and provide written procedures for emergency actions involving those hazards (1910.156(c)(4)).

Under 1910.156(d), how often must firefighting equipment and portable extinguishers be inspected and removed from service if unserviceable?

Firefighting equipment must be maintained and inspected at least annually, and portable fire extinguishers and respirators must be inspected at least monthly; damaged or unserviceable equipment must be removed from service and replaced. See 1910.156(d).

  • Annual inspections apply to firefighting equipment generally.
  • Portable extinguishers and respirators require monthly inspection per 1910.156(d).
  • Any equipment found damaged or unserviceable must be taken out of service and replaced immediately (1910.156(d)).

Under 1910.156(e)(1)(i), must employers provide protective clothing for interior structural firefighting and who pays for it?

Yes — under 1910.156(e)(1)(i) the employer must provide protective clothing at no cost to the employee and ensure its use for interior structural firefighting. See 1910.156(e)(1)(i).

  • Clothing ordered after July 1, 1981, must meet the paragraph's requirements, and by July 1, 1985 all members must wear compliant protective clothing when performing interior structural firefighting (1910.156(e)(1)(i)).
  • Employers must assure members actually wear the required gear during interior operations.

Under 1910.156(e)(1)(ii), what body parts must protective clothing cover for interior structural firefighting?

Protective clothing must protect the head, body, and extremities and include at least foot and leg protection, hand protection, body protection, and eye/face/head protection. See 1910.156(e)(1)(ii).

  • The employer must assure protective clothing provides full coverage of those areas when members perform interior structural firefighting (1910.156(e)(1)(ii)).

Under 1910.156(e)(2), what choices and performance tests apply to foot and leg protection for fire brigade members?

Foot and leg protection may be either fully extended boots that protect the legs or protective shoes/boots worn with protective trousers, and footwear must meet Class 75 requirements, be water-resistant at least 5 inches above the heel, have slip-resistant soles, and pass a midsole penetration test. See 1910.156(e)(2)(i), 1910.156(e)(2)(ii), and 1910.156(e)(2)(iii).

  • Options: (A) fully extended boots meeting leg protection requirements, or (B) protective shoes/boots with protective trousers (1910.156(e)(2)(i)(A)-(B)).
  • Footwear must meet 1910.136 Class 75 performance and be water-resistant at least 5 inches above heel with slip-resistant outer soles (1910.156(e)(2)(ii)).
  • Footwear must resist midsole penetration by a size 8D common nail under 300 lb static force per 1910.156(e)(2)(iii).

Under 1910.156(e)(3), what body protection options are acceptable and what NFPA equivalency is required?

Body protection must be coordinated with foot and leg protection and can be either a fire-resistive coat with fully extended boots or a fire-resistive coat with protective trousers; performance must be at least equivalent to NFPA standards for structural firefighting. See 1910.156(e)(3)(i)(A)-(B) and 1910.156(e)(3)(ii).

  • Acceptable methods include: (A) fire-resistive coat plus fully extended boots, or (B) fire-resistive coat plus protective trousers (1910.156(e)(3)(i)(A)-(B)).
  • Construction, performance, and testing of coats and trousers must be at least equivalent to NFPA No. 1971-1975, with specific permissible variations listed in 1910.156(e)(3)(ii).

Under 1910.156(e)(3)(ii)(B), what oven test requirement applies to the outer shell of fire-resistive garments?

The outer shell of fire-resistive garments may discolor but must not separate or melt when placed in a forced-air laboratory oven at 500 °F (260 °C) for five minutes. See 1910.156(e)(3)(ii)(B).

  • This is one of the permissible variations from NFPA requirements specified in 1910.156(e)(3)(ii).
  • The rule focuses on preventing outer-shell separation or melting under the specified test conditions.

Under 1910.156(e)(4), what test criteria must firefighting gloves meet for cut, puncture, and heat penetration?

Firefighting gloves must resist surface cuts, resist puncture to specified forces/velocities, and limit internal palm temperatures under heat exposure per the NIOSH test methods incorporated in [1910.156(e)(4)(i)-(ii)]. See 1910.156(e)(4)(i) and 1910.156(e)(4)(ii).

  • Cut resistance: materials must resist a blade (60° edge, .001 in radius) under 16 lbf at ≥60 in/min (1910.156(e)(4)(i)(A)).
  • Puncture resistance: palm materials must resist penetration by a penetrometer (4d lath nail simulation) under 13.2 lbf at ≥20 in/min (1910.156(e)(4)(i)(B)).
  • Heat penetration: internal palm temperature must not exceed 135 °F (57 °C) after a 5-second exposure to 932 °F at 4 psi (1910.156(e)(4)(i)(C)).
  • Exterior glove materials must be flame resistant and tested per 1910.156(e)(4)(ii).

Under 1910.156(e)(4)(iii), when must gloves include wristlets and what length is required?

When the fire-resistive coat design does not otherwise protect the wrists, gloves must have wristlets at least 4.0 inches (10.2 cm) long to protect the wrist area when the arms are extended upward and outward. See 1910.156(e)(4)(iii).

  • Employers should choose glove/coating combinations so wrist areas remain protected during typical firefighting movements (1910.156(e)(4)(iii)).

Under 1910.156(e)(5), what head, eye, and face protection is required for fire brigade members?

Head protection must be a protective head device with ear flaps and chin strap meeting the incorporated Model Performance Criteria, and eye/face protection must comply with [1910.133] or be provided by full facepieces/helmets/hoods that meet [1910.134] and paragraph (f). See 1910.156(e)(5)(i)-(iii).

  • Head devices must meet the August 1977 "Model Performance Criteria for Structural Firefighters' Helmets," incorporated by reference in 1910.156(e)(5)(i).
  • Eye/face devices must comply with 1910.133 for operations where flying or falling materials may cause injury (1910.156(e)(5)(ii)).
  • Full facepieces, helmets, or hoods of approved breathing apparatus that meet 1910.134 and paragraph (f) satisfy the eye and face protection requirement (1910.156(e)(5)(iii)).

Under 1910.156(f)(1)(i)-(ii), when must employers provide respirators for fire brigade members and what type is required inside buildings or confined spaces?

Employers must provide respirators that meet [1910.134] to each fire brigade member required to use them, and approved self-contained breathing apparatus (SCBA) with full-facepiece or approved helmet/hood must be used inside buildings or confined spaces where toxic combustion products or oxygen deficiency may be present. See 1910.156(f)(1)(i) and 1910.156(f)(1)(ii).

  • Respirators must meet the Respiratory Protection Standard at 1910.134 per 1910.156(f)(1)(i).
  • SCBA must be worn when toxic products of combustion or oxygen deficiency are possible, and during emergencies involving toxic substances (1910.156(f)(1)(ii)).

Under 1910.156(f)(1)(v)-(vi), what SCBA service-life rating and low-air alarm requirements apply?

Self-contained breathing apparatus (SCBA) for fire brigade members must have a minimum service-life rating of 30 minutes and be equipped with an audible alarm that sounds when remaining service life falls to 20–25% of rated time. See 1910.156(f)(1)(v) and 1910.156(f)(1)(vi).

  • The 30-minute minimum service-life rating follows NIOSH methods per 1910.156(f)(1)(v).
  • SCBA must have an automatic audible alarm indicating remaining service life within the 20–25% range of rated time (1910.156(f)(1)(vi)).

Under 1910.156(f)(2)(i)-(ii), when must positive-pressure SCBA be used for interior structural firefighting?

SCBA ordered after July 1, 1981, for interior structural firefighting must be pressure-demand or other positive-pressure type, and effective July 1, 1983, only positive-pressure SCBA may be worn during interior structural firefighting. See 1910.156(f)(2)(i)-(ii).

  • Employers may use SCBA that can switch from demand to positive-pressure mode, but such units must be in positive-pressure mode during interior operations (1910.156(f)(2)(ii)).
  • This requirement became mandatory for use effective July 1, 1983 (1910.156(f)(2)(i)).

Under 1910.156(f)(1)(iii), are non-NIOSH-certified accessories such as buddy-breathing devices permitted on SCBA?

Yes — approved SCBA may be equipped with a "buddy-breathing" device or a quick-disconnect valve even if those accessories are not certified by NIOSH, provided they do not damage or restrict the apparatus. See 1910.156(f)(1)(iii) and the accessory condition in 1910.156(f)(1).

  • Employers must ensure accessories do not cause damage, restrict airflow, or obstruct normal operation per 1910.156(f)(1).

Under 1910.156(f)(1)(iv), can SCBA be used with cylinders from other approved apparatus and what requirements apply?

Yes — approved SCBA may be used with approved cylinders from other approved SCBA provided the cylinders have the same capacity and pressure rating, and all compressed air cylinders must meet DOT and NIOSH criteria. See 1910.156(f)(1)(iv).

  • Cylinder interchangeability is allowed only when capacity and pressure rating match (1910.156(f)(1)(iv)).
  • All cylinders must comply with DOT and NIOSH requirements as stated in 1910.156(f)(1)(iv).

Under 1910.156(e)(2)(iii), what specific midsole penetration test must protective footwear pass?

Protective footwear must resist penetration of the midsole by a size 8D common nail when at least 300 pounds (1330 N) of static force is applied to the nail, tested as specified in 1910.156(e)(2)(iii).

  • The footwear test method is described in the regulation and referenced testing procedures (see 1910.156(e)(2)(iii)).

Under 1910.156(e)(5)(ii) and [1910.133], when must protective eye and face devices be used by fire brigade members?

Protective eye and face devices that comply with [1910.133] must be used during operations where flying or falling materials could cause eye and face injuries. See 1910.156(e)(5)(ii) and 1910.133.

  • Employers must provide appropriate eye/face protection for recognized hazards and ensure members use devices that meet [1910.133] performance requirements.
  • Full facepieces that meet [1910.134] and paragraph (f) are also acceptable as eye/face protection (1910.156(e)(5)(iii)).

Under 1910.156(b)(1), who can inspect the employer's organizational statement and where should it be kept?

The employer's written organizational statement must be made available for inspection by the Assistant Secretary (OSHA) and by employees or their designated representatives, so it should be maintained where it can be produced for inspection. See 1910.156(b)(1).

  • Keep the statement with safety program records or another accessible location so OSHA and employee representatives can inspect it on request (1910.156(b)(1)).

Under 1910.156(e)(5)(iii) and 1910.134, can an SCBA full facepiece substitute for separate eye and face protection?

Yes — full facepieces, helmets, or hoods of breathing apparatus that meet [1910.134] and paragraph (f) of the fire brigades standard are acceptable to meet eye and face protection requirements. See 1910.156(e)(5)(iii) and 1910.134.

  • Using an approved SCBA full facepiece satisfies both respiratory protection and eye/face protection when it meets the referenced standards (1910.156(e)(5)(iii)).

Using the head protection LOI (2024-06-06-2), when is head protection required for workers exposed to overhead hazards and what standards apply?

When workers are exposed to potential head injury from falling objects or overhead hazards, the employer must ensure they wear protective helmets that comply with incorporated ANSI standards; the employer must assess the workplace to determine if such hazards exist. See the head protection LOI at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2 and 1910.135 as referenced in that letter.

  • The LOI explains that head protection is required where there is potential for injury from falling objects (see https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2).
  • Helmets must meet one of the ANSI standards incorporated by reference per 1910.135 as noted in the LOI.

Under 1910.156(f)(2)(ii), may SCBA that switch from demand to positive-pressure mode be used for interior structural firefighting?

Yes — SCBA that can switch from demand to positive-pressure mode may be used, but they must be in the positive-pressure mode while fire brigade members are performing interior structural firefighting. See 1910.156(f)(2)(ii).

  • Employers should ensure equipment is used in the required positive-pressure configuration during interior operations (1910.156(f)(2)(ii)).

Under 1910.156(d), what should an employer do if firefighting equipment is found unserviceable during inspection?

If firefighting equipment is in damaged or unserviceable condition, the employer must remove it from service and replace it to assure safe operation, as required by 1910.156(d).

  • Implement procedures for tagging, segregating, and replacing unserviceable equipment immediately.
  • Keep records of inspections and corrective actions to demonstrate compliance with 1910.156(d).

Under 1910.156(c)(4), what must employers include in training regarding changes to special hazards at the workplace?

Employers must advise fire brigade members of any changes in special hazards (e.g., new flammable liquid storage, toxic chemicals) and include written procedures describing actions to take in those situations as part of training. See 1910.156(c)(4).

  • Update training and written procedures whenever hazards change to ensure members know new risks and response actions (1910.156(c)(4)).

Under 1910.156(f)(1)(vi), what audible alarm requirement helps firefighters know remaining SCBA service time?

SCBA must have an indicator that automatically sounds an audible alarm when remaining service life is reduced to within 20–25% of the rated service time, per 1910.156(f)(1)(vi).

  • That alarm provides a clear warning to exit or switch to an alternative air source before the SCBA is depleted (1910.156(f)(1)(vi)).

Under 1910.156(e)(3)(i)(A)-(B), how should employers choose between boots vs. trousers for leg protection?

Employers may achieve foot and leg protection either by providing fully extended boots that protect the legs or by providing protective shoes/boots in combination with protective trousers; they must ensure the selected method meets the coordination and protection requirements in [1910.156(e)(2)-(3)]. See 1910.156(e)(2)(i)(A)-(B).

  • If using protective trousers, ensure trousers meet the fire-resistive performance specified in 1910.156(e)(3)(ii).
  • If using fully extended boots, ensure boots meet the Class 75 and water-resistance/slip-resistance requirements in 1910.156(e)(2)(ii)-(iii).