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OSHA 1910.160

Fixed extinguishing systems scope

Subpart L

21 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.160(a)(1), which fixed extinguishing systems does this standard cover and which system is excluded?

Under 1910.160(a)(1) the rule covers all fixed extinguishing systems installed to meet a particular OSHA standard, but it excludes automatic sprinkler systems which are covered by 1910.159. See 1910.160(a)(1).

Under 1910.160(a)(2), when do fixed extinguishing systems that are not required by another OSHA standard still fall under 1910.160 rules?

Under 1910.160(a)(2) fixed systems not required by another OSHA rule are covered if their operation may expose employees to injury, death, or adverse health effects from the extinguishing agent; in that case they must meet the limited requirements in paragraphs (b)(4)–(b)(7) and (c). See 1910.160(a)(2).

Under 1910.160(a)(3), when are fixed extinguishing systems exempt from 1910.160 because of no employee exposure?

Under 1910.160(a)(3) systems that would otherwise be covered by paragraph (a)(2) are exempt if they are installed in areas where employees cannot be exposed during or after operation. See 1910.160(a)(3).

Under 1910.160(b)(1), what must fixed extinguishing system components and agents be designed and approved for?

Under 1910.160(b)(1) all fixed extinguishing system components and agents must be designed and approved for use on the specific fire hazards they are expected to control or extinguish. See 1910.160(b)(1).

Under 1910.160(b)(2), what must an employer do if a fixed extinguishing system becomes inoperable?

Under 1910.160(b)(2) the employer must notify employees, take temporary precautions to assure their safety until the system is restored, and ensure any defects are corrected by trained personnel. See 1910.160(b)(2).

Under 1910.160(b)(3), when is a discharge alarm required and what standard must it comply with?

Under 1910.160(b)(3) employers must provide a distinctive alarm or signaling system on all extinguishing systems in covered areas to indicate when the system is discharging, and that alarm must comply with 1910.165 and be perceivable above ambient noise or light; discharge alarms are not required when discharge is immediately recognizable. See 1910.160(b)(3).

Under 1910.160(b)(4) and (b)(5), what warning measures must employers provide around discharge areas and hazardous agent concentrations?

Under 1910.160(b)(4) and (b)(5) employers must provide effective safeguards to warn employees against entering hazardous discharge areas and post hazard warning or caution signs at entrances and inside areas protected by agents at concentrations known to be hazardous. See 1910.160(b)(4) and 1910.160(b)(5).

Under 1910.160(b)(6), how often must fixed extinguishing systems be inspected and who should perform the inspection?

Under 1910.160(b)(6) fixed systems must be inspected at least annually by a person knowledgeable in the system's design and function to ensure it is maintained in good operating condition. See 1910.160(b)(6).

Under 1910.160(b)(7) and (b)(8), what are the semi-annual check requirements for refillable and nonrefillable containers?

Under 1910.160(b)(7)–(b)(8) refillable containers must have weight and pressure checked at least semi-annually and be maintained if net content drops over 5% or pressure over 10%; factory-charged nonrefillable containers without pressure gauges must be weighed semi-annually and replaced if net weight loss exceeds 5%. See 1910.160(b)(7) and 1910.160(b)(8).

Under 1910.160(b)(9), what recordkeeping is required for inspection and maintenance dates of containers?

Under 1910.160(b)(9) employers must record inspection and maintenance dates on the container, on a tag attached to it, or in a central location, and must keep the record of the last semi-annual check until the next check or for the life of the container, whichever is less. See 1910.160(b)(9).

Under 1910.160(b)(10), who must be trained on fixed extinguishing systems and how often must training be reviewed?

Under 1910.160(b)(10) employers must train employees designated to inspect, maintain, operate, or repair fixed extinguishing systems and must review that training annually to keep those employees up-to-date in their functions. See 1910.160(b)(10).

Under 1910.160(b)(11), which extinguishing agents are explicitly prohibited where employees may be exposed?

Under 1910.160(b)(11) the employer must not use chlorobromomethane or carbon tetrachloride as extinguishing agents where employees may be exposed. See 1910.160(b)(11).

Under 1910.160(b)(12), what must employers do for systems installed in corrosive atmospheres?

Under 1910.160(b)(12) employers must ensure systems installed in corrosive atmospheres are constructed of non-corrosive material or otherwise protected against corrosion. See 1910.160(b)(12).

Under 1910.160(b)(13), what standard covers approval, installation, and maintenance of automatic detection equipment for extinguishing systems?

Under 1910.160(b)(13) automatic detection equipment must be approved, installed, and maintained in accordance with 1910.164. See 1910.160(b)(13).

Under 1910.160(b)(15) and (b)(16), what manual activation and identification is required for fixed extinguishing systems?

Under 1910.160(b)(15)–(b)(16) employers must provide at least one manual station for discharge activation of each fixed system and must identify manual operating devices as to the hazard they protect against. See 1910.160(b)(15) and 1910.160(b)(16).

Under 1910.160(b)(17), what personal protective equipment must an employer provide related to extinguishing agent discharges?

Under 1910.160(b)(17) the employer must provide and ensure use of personal protective equipment needed for immediate rescue of employees trapped in hazardous atmospheres created by an agent discharge. See 1910.160(b)(17).

Under 1910.160(c)(1), when must an employer provide an emergency action plan for areas protected by total flooding systems?

Under 1910.160(c)(1) the employer must provide an emergency action plan under 1910.38 for each area protected by a total flooding system that provides agent concentrations exceeding the maximum safe levels referenced in 1910.162(b)(5) and (b)(6). See 1910.160(c)(1).

Under 1910.160(c)(2), when are systems exempt from the total flooding system requirements in paragraph (c)?

Under 1910.160(c)(2) systems installed in areas where employees cannot enter during or after the system's operation are exempt from the paragraph (c) requirements. See 1910.160(c)(2).

Under 1910.160(c)(3) and (c)(4), what pre-discharge and automatic actuation requirements apply to total flooding systems with hazardous agent concentrations?

Under 1910.160(c)(3)–(c)(4) employers must provide a pre-discharge employee alarm that complies with 1910.165 and is perceivable above ambient conditions so employees can exit before discharge, and total flooding systems must automatically actuate by an approved fire detection device interconnected with that pre-discharge alarm. See 1910.160(c)(3) and 1910.160(c)(4).

How does 1910.160 interact with the sprinkler standard 1910.159 when both types of systems are present?

Under 1910.160(a)(1) automatic sprinkler systems are specifically excluded from this section and are covered by 1910.159; employers must follow 1910.159 for sprinklers and 1910.160 for other fixed extinguishing systems. See 1910.160(a)(1).

If a fixed extinguishing system uses an agent that creates oxygen-deficient conditions, what workplace planning should employers consider under 1910.160 and related standards?

If a fixed system can create oxygen-deficient or otherwise hazardous atmospheres, the employer must follow the warning, alarm, training, PPE, and emergency-planning requirements in 1910.160 (for example, 1910.160(b)(4)–(b)(5), (b)(10), (b)(17), and (c)(1)). Employers should also consider applicable respiratory protection and confined-space requirements in 1910.134 and other standards when planning for employee rescue and entry into affected areas.