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OSHA 1910.163

Water spray and foam systems

Subpart L

18 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.163(a), when does the fixed extinguishing systems standard apply instead of the automatic sprinkler standard?

Yes — 1910.163(a) applies to fixed systems that use water or a foam solution and are installed to meet a particular OSHA standard, while automatic sprinkler systems are covered separately under 1910.159. Employers must follow 1910.163 for fixed water spray or foam systems installed for a specific OSHA requirement, and must follow 1910.159 if the system is an automatic sprinkler system.

Under 1910.163(a), must fixed water spray and foam systems also meet requirements in 1910.160?

Yes — fixed water spray and foam systems installed to meet a particular OSHA standard must also comply with 1910.160, because 1910.163(a) explicitly requires that coverage. Follow both sections when you design, install, test, and maintain these systems.

Under 1910.163(b)(1), what does it mean to design a foam or water spray system to be "effective in at least controlling fire" in the protected area?

It means the system must be sized, located, and specified so it will control or limit the fire in the area or on the equipment it protects. 1910.163(b)(1) requires employers to assure system effectiveness, which in practice means selecting proper nozzle types, flow rates, discharge duration, foam concentrate and proportioning, and layout appropriate for the fuel and geometry of the hazard. Also consult 1910.160 for related requirements on design and testing.

Under 1910.163(b)(2), how must drainage from a water spray system be managed around work areas and egress routes?

You must direct drainage away from places where employees work and must not allow emergency egress through the drainage path. 1910.163(b)(2) requires employers to ensure drainage does not create hazards for workers or block escape routes; design drains, tiling, containment or rerouting so runoff does not flow across walkways or emergency exits.

Under 1910.163(b)(2), can an emergency egress route run through a water spray drain or containment flow path?

No — emergency egress must not be permitted through the drainage path of a water spray system. 1910.163(b)(2) explicitly prohibits allowing emergency egress through the drainage path, so plan egress layouts and drains so exits remain dry and unobstructed during a system discharge.

Under 1910.163(a), are fixed deluge or foam systems used to protect electrical transformers or other equipment covered by this standard?

Yes — if the fixed system uses water or foam and was installed to meet a particular OSHA standard, it falls under 1910.163(a). The employer must ensure the system is effective for the protected equipment and also meet the applicable requirements in 1910.160.

Under 1910.163 and 1910.160, are employers required to inspect and test fixed water spray and foam systems?

Yes — employers must follow inspection, testing, and maintenance requirements in 1910.160 for fixed extinguishing systems covered by 1910.163(a). Regular inspections and tests ensure the system will operate as designed and remain effective in controlling fires.

Under 1910.163(b)(1), does a water spray or foam system have to automatically detect and discharge, or can it be manual?

The standard does not require a specific activation method; it requires the system be designed to be effective in controlling fire. 1910.163(b)(1) and the related 1910.160 provisions mean you must choose automatic, manual, or combined activation based on what will reliably control the fire in your hazard scenario and meet testing and maintenance requirements.

Under 1910.163(b)(1), must employers ensure the foam concentrate and proportioning equipment are compatible with the hazard being protected?

Yes — employers must select foam concentrates, proportioning, and discharge equipment that will control the specific fire hazards in the protected area. 1910.163(b)(1) requires systems be effective for the protected hazards, and 1910.160 provides related design and testing expectations that support choosing compatible foam agents and equipment.

Under 1910.163(b)(2), what steps can employers take to prevent runoff from a system discharge from creating slip, trip, or contamination hazards in work areas?

Direct drainage away from work and provide containment or diversion so runoff does not create slip or contamination hazards. 1910.163(b)(2) requires drainage be directed away from employee work areas and egress. Practical steps include grading, drains routed outside pedestrian paths, temporary barriers, collection sumps, and procedures that keep employees clear of discharge and runoff.

Under 1910.163(a), are portable foam or water extinguishers covered by this fixed systems standard?

No — 1910.163(a) applies only to fixed extinguishing systems that use water or foam solutions. Portable handheld extinguishers are regulated under other OSHA requirements, not under 1910.163. Employers should consult the relevant portable extinguisher standards in 1910 for details.

Under 1910.163, how should an employer handle retrofitting or upgrading an older fixed foam or water spray system?

Employers must make sure the retrofit yields a system that is effective for the protected area and complies with 1910.163 and the applicable provisions of 1910.160. That means any upgrades affecting design, discharge rates, or drainage should be evaluated, tested, and documented to confirm they meet performance and drainage requirements.

Under 1910.163(b)(1), how should system designers choose a foam type for Class B fires involving hydrocarbon fuels vs. polar solvents?

Designers must select a foam type and proportioning system matched to the fuel characteristics so the system will control the fire. 1910.163(b)(1) requires effectiveness; because hydrocarbon and polar-solvent fires need different foam chemistries and application methods, choose compatible foam concentrates and verify performance per 1910.160.

Under 1910.163, if a fixed foam system discharges inside a building, what must employers do to protect employee evacuation routes?

Employers must ensure drainage and discharge do not interfere with evacuation — direct runoff away from work areas and make sure emergency egress is not through the drainage path. 1910.163(b)(2) requires drainage to be directed away from employee work areas and prohibits emergency egress through drainage paths, so plan building egress and containment accordingly.

Under 1910.163, what does "protected equipment" mean when the rule says systems must control fire in the protected area or on protected equipment?

It means the specific machines, tanks, storage racks, or process units that the system was designed to protect. 1910.163(b)(1) requires employers to assure systems are designed to control fires in the area or on the equipment explicitly identified for protection; design and testing should target those items' geometry, fuel loads, and exposure risks.

Under 1910.163 and 1910.160, are performance tests required after installing or modifying a fixed water spray or foam system?

Yes — after installation or modification you must verify the system performs as designed, following inspection and testing requirements that appear in 1910.160 and the effectiveness expectations of 1910.163(b)(1). Tests should confirm flow rates, coverage, foam quality and drainage behavior.

Under 1910.163, should employers include foam system discharges in their workplace emergency plans and training?

Yes — because fixed foam or water spray discharges can affect employee safety and egress, employers should include system operation, potential runoff, and evacuation routes in emergency plans and training. While 1910.163 focuses on system design and drainage, employers should integrate those system characteristics into workplace emergency procedures found elsewhere in 1910.

Under 1910.163(a), can a facility use both an automatic sprinkler system and a fixed foam or water spray system in the same area?

Yes — but each system must comply with its applicable standard: automatic sprinklers must meet 1910.159 and fixed water spray or foam systems must comply with 1910.163 and 1910.160. Coordinate the systems so they do not interfere with each other's effectiveness, and verify performance through testing.