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OSHA 1910.165

Employee alarm systems scope

Subpart L

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.165(a)(1), to which alarms does the Employee Alarm Systems standard apply?

This standard applies to all employee emergency alarm systems that are installed to meet a particular OSHA standard. Employers must follow 1910.165(a)(1) for any alarm installed specifically to satisfy an OSHA requirement.

Under 1910.165(a)(2), do maintenance, testing, and inspection rules apply to local fire alarm systems that also alert employees?

Yes. Maintenance, testing, and inspection requirements in this section apply to all local fire alarm signaling systems used for alerting employees, even if the system has other functions. Employers must follow 1910.165(a)(2) to ensure those alerting functions are maintained and tested appropriately.

  • This means a fire alarm that also warns employees must be kept and tested according to the employee alarm maintenance/testing rules.

Under 1910.165(a)(3), what extra requirements apply to pre-discharge employee alarms?

Pre-discharge employee alarms installed to meet an OSHA standard must meet the specific requirements in paragraphs (b)(1) through (4), (c), and (d)(1) of the rule. Employers must ensure these alarms comply with 1910.165(a)(3).

  • That means follow the general requirements in (b) (warning purpose, audibility/visibility, distinctiveness, communication procedures), the installation/approval and restoration rules in (c), and the basic maintenance requirement in 1910.165(d)(1).

Under 1910.165(b)(1), what must an employee alarm provide?

An employee alarm must provide warning that allows the actions called for in the employer’s emergency action plan or provide enough reaction time for safe escape, or both. This requirement is in 1910.165(b)(1).

  • Align alarm timing and messages with your emergency action plan so employees can evacuate or take required steps safely.

Under 1910.165(b)(2), how loud or visible must an employee alarm be relative to ambient conditions?

The employee alarm must be capable of being perceived above ambient noise or light levels by all employees in the affected portions of the workplace. Employers must design alarms so they are noticeable over normal workplace sounds and lighting, as required by 1910.165(b)(2).

  • Consider sound level measurements and strobe intensity, and test alarms during typical work conditions to confirm perception.

Under 1910.165(b)(3), can employers use tactile devices for alarm notification?

Yes. Tactile devices (for example, vibration devices) may be used to alert employees who cannot recognize audible or visual alarms, as permitted by 1910.165(b)(3).

  • Use tactile devices where necessary (e.g., for employees who are deaf or in very noisy areas) and ensure they are reliable and distinct as an evacuation signal.

Under 1910.165(b)(3), how must employee alarms be designed so employees know to evacuate or follow the emergency plan?

Alarms must be distinctive and recognizable as the signal to evacuate or perform actions designated under the emergency action plan, per 1910.165(b)(3).

  • Use consistent tones, patterns, or messages and train employees so they know what each alarm signal means and what response is required.

Under 1910.165(b)(4), what communication and reporting procedures must employers explain to employees?

Employers must explain the preferred means of reporting emergencies (for example, manual pull boxes, public address systems, radios, or telephones) and post emergency phone numbers near telephones and on notice boards or other conspicuous locations when telephones serve as the reporting method, as required by 1910.165(b)(4).

  • If a communication system also serves as the employee alarm, make sure all emergency messages have priority over non-emergency messages.

Under 1910.165(b)(5), can employers with small workplaces rely on direct voice communications for sounding alarms?

Yes. Employers with 10 or fewer employees in a particular workplace may use direct voice communication as an acceptable alarm procedure provided all employees can hear it, under 1910.165(b)(5).

  • For larger workplaces, use a system that reliably notifies all affected employees.

Under 1910.165(c)(1), what does it mean that employee alarm devices must be "approved"?

Devices, components, combinations of devices, or systems constructed and installed to comply with this standard must be approved; common devices like steam whistles, air horns, strobe lights, or tactile devices meeting the section's requirements are considered approved under 1910.165(c)(1).

  • Choose alarm equipment that meets recognized industry performance expectations and document how the chosen device satisfies the approval requirement.

Under 1910.165(c)(2), what must employers do after testing an alarm or after an actual alarm?

Employers must restore all employee alarm systems to normal operating condition as promptly as possible after each test or alarm, and keep spare alarm devices and components in sufficient quantities and locations for prompt restoration, per 1910.165(c)(2).

  • Maintain an inventory of spare parts and a plan for quick replacement so alarms are not left out of service longer than necessary.

Under 1910.165(d)(1), when must employee alarm systems be kept in operating condition?

Employee alarm systems must be maintained in operating condition at all times except when they are undergoing repairs or maintenance, as required by 1910.165(d)(1).

  • When systems are out of service for repairs, provide a back-up means of alarm (see 1910.165(d)(3)).

Under 1910.165(d)(2), how often must unsupervised employee alarm systems be tested?

A test of the reliability and adequacy of non-supervised (unsupervised) employee alarm systems must be made every two months, according to 1910.165(d)(2).

  • Keep records or schedules showing tests occurred on the required schedule and address any deficiencies found.

Under 1910.165(d)(3), how should multi-actuation device systems be tested to avoid wearing a single device?

When testing a multi-actuation device system, a different actuation device must be used in each test so that no individual device is used for two consecutive tests, as stated in 1910.165(d)(3).

  • Rotate which pull stations or actuation points are tested to avoid repetitive wear and to verify all devices function.

Under 1910.165(d)(3), what backup alarm methods must be provided when systems are out of service?

Back-up means of alarm such as employee runners or telephones must be provided when systems are out of service, as required by 1910.165(d)(3).

  • Plan and drill backup notification procedures in advance so employees know how they will be alerted if the main system is down.

Under 1910.165(d)(4), what must employers do for alarm circuitry installed after January 1, 1981, that is capable of being supervised?

If employee alarm circuitry installed after January 1, 1981, is capable of being supervised, the employer must supervise it so it provides positive notification to assigned personnel whenever a deficiency exists, and supervised systems must be tested at least annually for reliability and adequacy, per 1910.165(d)(4).

  • Supervision typically means monitoring that indicates faults (loss of power, open circuits) so assigned staff are alerted to problems promptly.

Under 1910.165(d)(5), who must perform servicing, maintenance, and testing of employee alarm systems?

Servicing, maintenance, and testing must be performed by persons trained in the system’s designed operation and functions necessary for reliable and safe operation, under 1910.165(d)(5).

  • Keep training records and ensure technicians understand actuation methods, supervision features, and restoration procedures.

Under 1910.165(e), what are the requirements for manual actuation devices (pull stations)?

Manually operated actuation devices must be unobstructed, conspicuous, and readily accessible, as required by 1910.165(e).

  • Ensure pull stations are not blocked by storage, furniture, or locked doors, and post signage if needed to keep them visible and reachable.

Under 1910.165(b) and related provisions, what steps should an employer take to make an alarm system usable by employees with sensory impairments?

Employers should provide alarm signals that all affected workers can perceive, including tactile devices and visual strobes where needed, and make the alarm distinctive and recognizable so employees with hearing or vision impairments can respond, per 1910.165(b)(2) and 1910.165(b)(3).

  • Evaluate ambient conditions, provide multiple notification methods (audible, visual, tactile), and train employees on what each method means.