Fire brigade guidelines

No — an employer is not required to organize a fire brigade, but if they do, the fire brigade rules apply. The appendix makes clear that organizing a fire brigade is voluntary, and when an employer chooses to organize one the requirements of 1910.156 apply.

• Cite: 1910.156.

The organizational statement must include the basic items listed in 1910.156(b)(1); the appendix suggests additional helpful details. The appendix recommends adding a description of brigade duties, line authority of officers, numbers of officers and instructors, and a list and description of awards or recognition available to members.

• Required: see 1910.156(b)(1).
• Suggested additions: organizational duties, chain of command, staffing counts, training instructor info, and recognition programs (see 1910 Subpart L Appendix A).

All fire brigade members must receive hands-on training at least annually. The appendix states that a minimum of hands-on training is required annually for every fire brigade member, with more frequent or additional training where members perform more hazardous duties.

• Cite: 1910.156(c) and 1910 Subpart L Appendix A.

Fire brigade members expected to perform interior structural firefighting must receive training at least quarterly. The appendix requires at least quarterly training or education sessions for interior structural firefighters, in addition to the annual hands-on requirement.

• Cite: 1910.156(c) and 1910 Subpart L Appendix A.

Yes — equivalent recent training from an outside fire service can be accepted if it was provided within the past year and is documented. The appendix says employers do not need to duplicate training a member received as a volunteer firefighter as long as the training occurred within the past year and documentation shows the member received it.

• Cite: 1910.156(c) and 1910 Subpart L Appendix A.

In addition to hands-on drills, the appendix recommends classroom instruction, review of emergency action procedures, pre-fire planning, special-hazards review, and self-contained breathing apparatus practice. These methods help match training to the brigade's expected functions and workplace hazards.

• Cite: 1910.156(c) and 1910 Subpart L Appendix A.

Yes — employees who cannot meet the physical capability requirement may remain brigade members but must not perform interior structural firefighting. The appendix says such members may be assigned less stressful duties like training administration, recordkeeping, fire prevention inspections, maintenance, or pump operations.

• Cite: 1910.156(b) and 1910 Subpart L Appendix A.

Physical capability can be determined by job-specific physical performance tests or by a physician's examination who knows the duties expected of the member. The appendix explains both options and recommends participation in physical fitness programs.

• Cite: 1910.156(b) and 1910 Subpart L Appendix A.

Instructors should be more highly trained than the members they teach and be qualified in the brigade functions, hazards, communication, teaching methods, and motivation. The appendix suggests consulting sources such as NFPA-1041 and training schools to determine instructor qualifications.

• Cite: 1910.156(c) and 1910 Subpart L Appendix A.

Members assigned to control and extinguish incipient stage fires should be trained in the use of fire extinguishers, standpipes, and other assigned equipment, plus first aid and procedures for special hazards; training should include classroom instruction and simulated operation under emergency conditions. The appendix emphasizes both classroom and practical training for these duties.

• Cite: 1910.156(c) and 1910 Subpart L Appendix A.

Hands-on training must occur at least annually, and some functions (especially for interior firefighting and rescue) should be reviewed quarterly or even monthly/weekly as needed to maintain proficiency. The appendix sets the annual minimum but advises more frequent drills for critical skills.

• Cite: 1910.156(c) and 1910 Subpart L Appendix A.

Pre-fire planning is recommended to be done with the local fire department and/or the workplace fire brigade so responders know the workplace layout and hazards; involvement with the local fire department or fire prevention bureau is encouraged to improve coordination. The appendix suggests this cooperative planning to help both internal brigades and external responders.

• Cite: 1910.156 and 1910 Subpart L Appendix A.

Firefighting equipment (except portable extinguishers and respirators) must be inspected at least annually; portable fire extinguishers and respirators must be inspected at least monthly. The appendix gives these inspection intervals to help keep equipment serviceable and remove damaged items from service.

• Cite: 1910.156 and 1910 Subpart L Appendix A.

No — full protective clothing is not required for every brigade member; the protective clothing requirements apply only to members who perform interior structural firefighting operations. The appendix clarifies that protective ensembles should match the hazards expected and are specifically required for interior structural operations, not for all outside firefighting or specialized activities.

• Cite: 1910.156(e) and 1910 Subpart L Appendix A.

Fire brigade members may meet foot-and-leg protection either by wearing long fire‑resistive coats with fully extended boots or by wearing shorter fire‑resistive coats with protective trousers and protective shoes or shorter boots. The appendix explicitly gives this option to reflect interdependence of protective clothing elements.

• Cite: 1910.156(e)(3) and 1910 Subpart L Appendix A.

Body protection can be achieved by either a fire‑resistive coat with fully extended boots or by a fire‑resistive coat with protective trousers; garments meeting NFPA 1971–1975 for structural firefighters are acceptable. The appendix accepts coated-and-trouser combinations that comply with NFPA 1971-1975 as meeting the standard.

• Cite: 1910.156(e)(3) and 1910 Subpart L Appendix A.

The lining of protective coats is required to be permanently attached to the outer shell, although limited stitching at the neck with removable fasteners elsewhere is allowed to facilitate cleaning; detachable winter liners are not considered the required "permanent" lining. The appendix explains the acceptable attachment methods and clarifies that the reference to permanent lining does not mean seasonal winter liners.

• Cite: 1910.156(e)(3) and 1910 Subpart L Appendix A.

Hand protection requirements may be met by using protective gloves or an approved glove system appropriate to the hazard. The appendix states that the hand protection paragraph can be satisfied with gloves or glove systems designed for the expected exposures.

• Cite: 1910.156(e) and 1910 Subpart L Appendix A.

Yes — employers should develop written procedures for special hazards and train brigade members on those procedures and keep them updated. The appendix emphasizes written procedures for situations involving flammable liquids/gases, toxic chemicals, water‑reactive substances, etc., and requires training so brigade members know how to handle those hazards.

• Cite: 1910.156 and 1910 Subpart L Appendix A.

Yes — brigade leaders and instructors should receive more formal and continuing education; the appendix suggests consulting fire service training sources such as NFPA guidance and university extension fire schools for recommended qualifications and continuing education. Employers are encouraged to use recognized training schools and publications to develop leadership and instructor training programs.

• Cite: 1910.156(c) and 1910 Subpart L Appendix A.

A glove system is a combination of two gloves worn together: an inner thermal-insulating pair and an outer pair that protects against flame, cuts, and punctures.

• The inner glove provides heat insulation to protect the hand from high temperatures.
• The outer glove provides protection against flame, cuts, and punctures while allowing the inner glove to insulate.
• Employers should select gloves that balance protection with dexterity and feel so firefighters can handle tools and victims; guidance on dexterity test methods is available in NIOSH publications cited in the fire brigade guidance.

See 1910.156 for the fire brigade glove system discussion.

Yes. Head protective devices that meet NFPA No. 1972 are acceptable to meet the head protection requirements, and they are required to be provided with ear flaps so the flaps are available when needed.

• OSHA’s fire brigade guidance specifically states that head protective devices meeting NFPA 1972 are acceptable as meeting the standard’s head protection requirement.
• The guidance also requires that head protective devices be provided with ear flaps and recommends ear protection during interior structural firefighting.

See 1910.156(e). You can also consult OSHA’s head protection interpretation addressing when head protection is required under related standards at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2.

Yes. Face shields that are part of head protective devices may meet eye and face protection requirements as long as they meet the requirements of 1910.133.

• The fire brigade guidance explicitly notes that many helmets are equipped with face shields and that such face shields are permissible if they comply with the eye-and-face standard.
• Full facepieces, helmets, or hoods of approved respiratory equipment that meet 1910.134 and 1910.156(f) are also acceptable for eye/face protection.

Fire brigade members must wear respiratory protection when working inside buildings or confined spaces where toxic products of combustion or oxygen deficiency are likely, and during emergency responses involving unknown contaminants or concentrations.

• The fire brigade guidance requires respirators for interior operations, confined spaces, and emergency situations where contaminants are unknown.
• OSHA’s Respiratory Protection standard at 1910.134 contains the employer duties for programs, medical evaluations, fit testing, and IDLH procedures.
• For issues involving oxygen-deficient atmospheres, OSHA’s interpretation clarifies that oxygen-deficient atmospheres are considered IDLH under 1910.134(d)(2)(iii) and civilian employees covered by OSHA must follow those requirements (see https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16).

Yes. The guidance recommends wearing a flame-resistant protective head covering such as a hood or snood, provided it will not adversely affect the respirator facepiece seal.

• A flame-resistant hood helps protect the sides of the face and hair during interior structural firefighting.
• The hood must not interfere with the respirator seal; full facepieces or hoods that meet 1910.134 and 1910.156(f) are acceptable as eye/face protection and respiratory protection.

No. Buddy-breathing devices and quick-disconnect valves are not required on SCBA, but they are acceptable and can be useful accessories if they do not damage or obstruct the apparatus.

• The fire brigade guidance states SCBA are not required to have buddy-breathing devices or quick-disconnect valves, but these accessories may be useful for emergency escape or aid as long as they don’t restrict airflow or obstruct normal operation.
• Employers are encouraged to provide an alternative means of escape (buddy-breathing or an ESCBA) for emergencies. See 1910.156(f).

Yes. Employers may provide an escape-only SCBA (ESCBA) for emergency escape, and the guidance suggests that ESCBA units be of at least 5 minutes service life.

• The guidance encourages offering an alternative respiratory means for emergency escape if the primary SCBA becomes inoperative, and suggests ESCBA units have at least a 5-minute rated service life.
• See the discussion in 1910.156(f).

Yes. Approved apparatus that can be switched to positive-pressure mode are acceptable, and if used for interior structural firefighting the apparatus must be in positive-pressure mode while performing those operations; conversions using manufacturer-approved kits by trained persons are also acceptable.

• The guidance accepts SCBA that can be switched from demand to positive-pressure provided they are in the positive-pressure mode during interior structural firefighting.
• It also allows conversion to positive-pressure type when performed by trained personnel using manufacturer- or NIOSH-approved kits and instructions. See 1910.156(f) and the employer obligations in 1910.134.

Negative-pressure SCBA with a rated service life of more than 2 hours may be used only when they achieve a minimum protection factor of 5,000 as determined by an acceptable quantitative fit test performed on each individual, and this allowance applies until positive-pressure long-duration SCBA are certified by NIOSH/MSHA, after which there is an 18-month phase-in.

• The fire brigade guidance explains that until NIOSH/MSHA certifies positive-pressure units with >2-hour service life, negative-pressure units with >2-hour life and a minimum PF of 5,000 (via quantitative fit testing) are acceptable.
• After the certification of positive-pressure long-duration units, negative-pressure units remain acceptable for up to 18 months before replacement is required. See 1910.156(f) and 1910.134 for respiratory program requirements.

Protection factor is the ratio of contaminant concentration outside the respirator to the concentration inside the facepiece, and the guidance requires a minimum protection factor of 5,000 for long-duration negative-pressure SCBA to be acceptable.

• The fire brigade guidance defines PF as Concentration outside respirator divided by Concentration inside facepiece and explains this is determined by quantitative fit testing.
• For long-duration negative-pressure apparatus used where >2 hours are needed, a PF of at least 5,000 (measured by an acceptable quantitative fit test on each individual) is required. See 1910.156(f) and 1910.134.

An acceptable quantitative fit test should include donning by a medically and physically able, trained wearer; a preliminary qualitative fit check; a period of physical activity simulating firefighting work; exposure to a known concentration test atmosphere without readjusting the apparatus; and a set of specified breathing and motion exercises while monitoring inside-facepiece contaminant concentration.

• The guidance lists these elements: (1) a trained, medically capable wearer dons SCBA with a device to monitor inside-facepiece concentration; (2) perform a qualitative fit check such as negative-pressure or isoamyl acetate tests; (3) perform physical activity reflecting firefighting (e.g., running-in-place); (4) place wearer in a test atmosphere with known contaminant concentration without readjustment; (5) perform the required breathing and head-motion exercises while recording concentrations to compute PF.
• The PF is calculated by dividing the known contaminant concentration outside by the measured concentration inside the facepiece; tests should be conducted at least three times with about one hour between tests. See 1910.156(f) and 1910.134 for program requirements.

If the employer chooses to evacuate all employees from the workplace during a fire emergency and provides no extinguishers, the portable fire extinguisher requirements do not apply to that workplace.

• 1910.157 explains that the standard is written to allow three employer options; if the employer elects total evacuation and does not provide extinguishers, the extinguisher rules in the section do not apply.
• Employers must document their emergency plan and ensure employees are trained in the chosen evacuation-only approach.

Yes. When the employer permits only certain designated employees (for example, a fire brigade) to fight fires, the employer is exempt from the standard distribution requirements, but those designated employees must be trained, know extinguisher locations, and extinguishers must be placed in convenient, known locations.

• The fire brigade guidance states employers who permit certain employees to remain to fight incipient fires or operate critical equipment are exempt from the distribution rules, provided designated employees are trained and familiar with extinguisher locations.
• Examples of acceptable locations include mounting extinguishers on the brigade’s apparatus or in a fire truck or cart; NFPA 10 offers additional distribution guidance. See 1910.157 for scope and exemptions.

If the employer allows all employees to use portable fire extinguishers, the full requirements of 1910.157 apply, including distribution, mounting, inspection, and training provisions.

• When all employees are permitted to fight fires with extinguishers, the standard’s distribution tables and inspection/mounting rules apply to ensure adequate coverage and accessibility.
• Employers must provide appropriate training so employees can use extinguishers safely and know when evacuation is the safer option.

OSHA allows flexible mounting of extinguishers as long as they are accessible without using other portable devices; extinguishers must be reachable without using ladders or other portable devices that could be moved or taken away.

• The guidance explains OSHA intends flexibility so extinguishers are accessible quickly and employees are not put at risk retrieving them.
• Employers must ensure extinguishers are accessible without using portable devices such as ladders, because those devices could be removed and make the extinguisher unavailable in an emergency. See 1910.157.

Yes. Helmets provided to fire brigade members are required to be provided with ear flaps so they are available if needed, and the guidance recommends wearing ear protection during interior structural firefighting.

• The fire brigade guidance specifically requires ear flaps to be part of head protective devices and recommends using ear protection while fighting interior fires to reduce noise-related injury risk.
• For head protection requirements more generally, see 1910.156(e) and OSHA’s head protection interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2.

Yes. Full facepieces, helmets, or hoods of approved breathing apparatus that meet 1910.134 and the fire brigade paragraph on respiratory protection are acceptable to satisfy eye and face protection requirements under 1910.133.

• The guidance states that such approved respiratory devices may serve as eye/face protection when they meet the respiratory standard and the applicable eye/face standard.
• Employers must ensure those devices are properly certified, maintained, and do not impair required protective functions.

OSHA suggests mounting extinguishers in convenient, known places for the brigade—examples include on the fire truck or cart used by the brigade when it responds, rather than following the standard distribution grid.

• The guidance says that when designated employees or a brigade will respond, the employer must ensure extinguishers are located where those employees know to find them; acceptable practices include mounting them on brigade apparatus, carts, or similar mobile equipment.
• Employers should still ensure accessibility and that brigade members are trained in locations and use; see 1910.157.

Employers must select and place portable extinguishers based on the type and class of fire hazards present so the degree of protection matches the workplace hazards. See 1910.157 for the requirement and Appendix A guidance recommending extinguisher types for each class.

• Class A (ordinary combustibles): water, foam, loaded stream, or multipurpose dry chemical.
• Class B (flammable liquids/gases): Halon 1301/1211, carbon dioxide, dry chemical, foam, or loaded stream.
• Class C (electrical): Halon 1301/1211, carbon dioxide, or dry chemical (selected for the underlying fuel).
• Class D (combustible metals): special dry powder agents or approved "universal" metal powders (e.g., Lith‑X, dry graphite, dry sodium chloride) since ordinary agents may worsen metal fires.

Employers should document the analysis that led to selection and distribution, and follow NFPA guidance where Appendix A recommends it. See 1910.157 and the Appendix A discussion of Class D agents.

Yes — an employer may substitute acceptable standpipe and hose systems for portable fire extinguishers if the substituted system provides equivalent coverage and accessibility. See 1910.157 and Appendix A guidance on substitution.

Key conditions from Appendix A:

• The hose system must reach around obstructions (columns, machinery) and into closets/enclosed areas so coverage equals that provided by portable units.
• Hose spacing must allow reach without portable ladders or other equipment (hose reels are encouraged).
• Class I large (2½") fire department–type hose systems may be exempted from some portable-extinguisher requirements because they serve different functions.

Document the equivalence analysis and maintain accessibility/maintenance consistent with the standard (see 1910.157).

The employer retains ultimate responsibility for inspection, maintenance, and testing of portable fire extinguishers but may use qualified outside contractors to perform the work. See 1910.157 and Appendix A.

Practical points:

• If using contractors, the employer must ensure the contractor is capable of performing the required inspection/maintenance/testing.
• If performed in-house, people doing the work must be trained to recognize inoperable condition and to perform required tasks.
• Hydrostatic testing is typically a specialty procedure and Appendix A recommends using qualified contractors or certified firms (e.g., DOT/MTB or recognized servicing firms) because of the hazards from pressurization and potential shell failure.

Follow the procedures and frequency in 1910.157 and document contractor qualifications or employee training.

Whenever an extinguisher is removed from service for inspection or repair, the employer must provide alternate equivalent protection for the area until the extinguisher is returned to service. See Appendix A guidance to 1910.157.

Examples of alternate equivalent protection listed in Appendix A:

• Replace the unit with one or more extinguishers of equivalent rating,
• Post a fire watch for the unprotected area,
• Restrict employee access to the unprotected area, or
• Provide a hose system ready for operation.

Document the temporary protection measure and ensure it provides comparable coverage until the extinguisher is returned to service.

Employers must ensure that any employee permitted to fight workplace fires is trained and educated so they can do so safely; training can be classroom-based, simulated fire exercises, or well-designed informal campaigns. See 1910.157 and Appendix A training guidance.

Training elements Appendix A recommends include:

• Recognizing fire classes and selecting the correct extinguisher type,
• Proper extinguisher operation and limitations, and
• Knowing when to evacuate and leave fire suppression to experienced firefighters.

Appendix A also lists sources for training and education (local fire departments, NFPA, state training programs, manufacturer schools) and notes simulated fires and hands‑on practice are acceptable parts of a program. Maintain training records and retrain as needed to keep skills current.

Employers must protect standpipe systems from mechanical and physical damage and store hose and nozzle equipment so they are accessible and shielded from weather or dirt. See 1910.158 and Appendix A guidance.

Specific expectations from Appendix A:

• Protect piping by enclosing it in building construction, locating in stairwells, or keeping it away from vehicle access.
• Store hose in cabinets or protective covers that are easily opened and kept free of obstructions so hose and nozzles are quickly accessible.
• When hose is installed in areas exposed to freezing conditions, employers may store hose in protective housings and connect when needed.

Follow the accessibility and protection guidance in 1910.158 and Appendix A.

Hose is unserviceable when deterioration prevents it from carrying water at required pressure/flow and nozzles should provide shutoff control and recommended pressures for good performance. See 1910.158 and Appendix A.

Examples of unserviceable hose from Appendix A:

• Dry‑rotted linen or hemp,
• Cross‑threaded couplings, or
• Punctured or otherwise deteriorated hose.

Nozzle guidance from Appendix A:

• Variable‑stream nozzles are recommended; a 100 psi (700 kPa) nozzle pressure is recommended for variable stream nozzles.
• For straight stream nozzles, 50 psi is recommended.
• Appendix A also recommends that nozzles allow the nozzle operator to shut off flow at the nozzle (e.g., shut‑off nozzle or globe valve between nozzle and hose).

Keep hose in serviceable condition, replace or repair defective hose, and document inspections as required in 1910.158.

Standpipe and hose systems designed and installed in accordance with NFPA Standard No. 14 are considered to comply with OSHA's 1910.158 requirements. Appendix A explicitly references NFPA 14 as acceptable design criteria.

Practical action: use NFPA 14 design/installation criteria and document that systems were installed and maintained per that standard to demonstrate compliance with 1910.158.

OSHA exempts from coverage automatic sprinkler systems that are not required by any OSHA standard and were installed solely for property protection with little or no employee exposure. See 1910.159 and Appendix A for the exemption.

Notes:

• If the sprinkler system is required by another OSHA standard or is installed in areas where employees could be exposed, the system falls under 1910.159.
• Employers should document the basis for any exemption (property‑only purpose and minimal employee exposure) in their safety files.

OSHA warns that many common extinguishing agents (water, some dry chemicals, gas) cannot control combustible metal (Class D) fires and recommends using agents specifically approved for metal fires or certain "universal" metal powders; water is generally not recommended except in specialized, controlled systems. See 1910.157 and Appendix A discussion of Class D fires.

Key guidance from Appendix A:

• Use extinguishers that employ agents specifically approved for the particular combustible metal; when necessary, certain universal agents (e.g., Lith‑X, dry sodium chloride, dry graphite, dry dolomite) may be used.
• Water applied to hot burning metal may decompose to hydrogen and oxygen and can intensify combustion; water is not generally accepted unless applied in very large quantities under controlled conditions (for example, automatic deluge systems in magnesium plants) per NFPA standards.

When combustible metal hazards exist, select appropriate Class D extinguishing agents and consult NFPA guidance and manufacturer recommendations as referenced in Appendix A and 1910.157.

You must provide equivalent protection whenever the primary water supply to a sprinkler system is shut down; acceptable measures include a manned fire watch with extinguishers or hose lines in place, a temporary secondary water supply (for example, a tank truck and pump or a fire pond with pumps), or evacuation implemented through an emergency action plan.

• Provide protection for the specific areas affected by the shutdown (the portion of the workplace protected by the out-of-service portion of the system).
• A fire watch must be staffed and equipped so personnel can respond quickly to any fire; portable extinguishers or hose lines should be available for immediate use.
• A temporary secondary water supply must be sized and located to protect the same area as the impaired system.
• Where equivalent protection cannot be assured, the employer may need to evacuate the workplace and follow an emergency action plan that specifies evacuation procedures.

This guidance is based on the requirements and examples described in 1910.159 and the explanatory recommendations in OSHA’s Fire Brigade Guidelines at Appendix A to Subpart L of 29 CFR 1910.

Yes — if a system’s discharge is not immediately apparent to employees, you must provide a distinctive alarm signal (for example, a bell, gong, whistle, horn, or flashing light) to warn employees that a fixed system is discharging.

• A separate distinctive alarm is required where the discharge could occur without anyone nearby noticing (for example, in remote or isolated locations).
• If the agent’s discharge itself is obviously audible or otherwise clearly announces the discharge (for example, a very loud releasing noise from a gaseous agent), a separate alarm may not be necessary.
• The alarm must be identifiable as a discharge alarm so employees know a release has occurred and what planned protective actions (evacuation, respirators, etc.) are needed.

This requirement and the examples are explained in 1910.160 and in the section on gaseous systems at 1910.162.