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OSHA 1910SubpartLAppB

National consensus standards crosswalk

Subpart L

21 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.157 (Portable Fire Extinguishers), is following ANSI/NFPA No. 10 an acceptable way to meet OSHA requirements for portable fire extinguishers?

Yes. ANSI/NFPA No. 10 is listed in OSHA's Appendix B as a national consensus standard that would be considered acceptable guidance for complying with the requirements of 1910.157 (Portable Fire Extinguishers); see Appendix B to Subpart L of Part 1910.

  • Using ANSI/NFPA No. 10 will help you meet OSHA expectations for selection, inspection, maintenance, and placement of portable extinguishers, but employers remain responsible for meeting the specific regulatory obligations in 1910.157.

Under 1910.159 (Sprinkler Systems), can employers use NFPA 13 and NFPA 13A guidance to design and maintain sprinkler systems?

Yes. NFPA 13 and NFPA 13A are listed in OSHA's Appendix B as consensus standards that provide acceptable guidance for complying with 1910.159 (Automatic Sprinkler Systems); see Appendix B to Subpart L of Part 1910.

  • Follow NFPA 13 for design and installation and NFPA 13A for maintenance recommendations, while ensuring you still meet the specific language and enforcement expectations of 1910.159.

Under 1910.156 (Fire Brigades), are ANSI/NFPA 1971 and 1972 appropriate consensus standards for firefighter protective clothing and helmets?

Yes. ANSI/NFPA 1971 (Protective Clothing for Structural Fire Fighters) and ANSI/NFPA 1972 (Structural Fire Fighter's Helmets) are listed in Appendix B as acceptable national consensus standards for topics covered in 1910.156 (Fire Brigades); see Appendix B to Subpart L of Part 1910.

  • Using these NFPA standards helps employers meet expectations for protective clothing and helmets, but employers must still verify those choices satisfy the duties and performance requirements spelled out in 1910.156.

Under 1910.163 (Foam Extinguishing Systems), which NFPA standards does OSHA reference as acceptable guidance?

NFPA 11, NFPA 11A, and NFPA 11B are referenced in OSHA's Appendix B as appropriate consensus standards for the topics in 1910.163 (Foam Extinguishing Systems); see Appendix B to Subpart L of Part 1910.

  • NFPA 11 covers foam systems generally, NFPA 11A covers high-expansion foam, and NFPA 11B covers synthetic foams and combined-agent systems; follow the applicable NFPA guidance while ensuring you meet the specific obligations of 1910.163.

Under 1910.160 (Fixed Extinguishing Systems, Foam), which consensus standards does Appendix B recommend for fixed foam systems?

ANSI/NFPA No. 11 and its related standards (such as ANSI/NFPA 11A and ANSI/NFPA 11B) are listed in Appendix B as acceptable guidance for complying with 1910.160 (Fixed Extinguishing Systems, Foam); see Appendix B to Subpart L of Part 1910.

  • Use the NFPA 11 series for design, installation, and operation of foam systems and ensure those practices satisfy the requirements of 1910.160.

Under 1910.164 (Fire Detection Systems) and 1910.165 (Employee Alarm Systems), can employers follow NFPA 72 and NFPA 101 guidance for signaling and life-safety features?

Yes. NFPA 72 (various parts) and NFPA 101 (Life Safety Code) are listed in Appendix B as consensus standards that would be considered acceptable guidance for the signaling and life-safety topics addressed in 1910.164 and 1910.165; see Appendix B to Subpart L of Part 1910.

  • NFPA 72 covers central, local, proprietary, and auxiliary signaling systems; NFPA 101 covers life-safety and egress considerations. Employers should apply the appropriate NFPA provisions while meeting the explicit requirements of the applicable OSHA sections.

Under 1910.158 (Standpipe and Hose Systems), which NFPA standards are listed by OSHA's Appendix B as acceptable references?

OSHA's Appendix B lists numerous NFPA standards for topics covered by 1910.158, including NFPA standards on pumps, water tanks, outside protection, hose connections, and related subjects; see Appendix B to Subpart L of Part 1910.

  • Examples in Appendix B include NFPA No. 20 (Centrifugal Fire Pumps), NFPA No. 22 (Water Tanks), NFPA No. 24 (Outside Protection), NFPA No. 194 (Fire Hose Connections), and others that provide detailed guidance for design and maintenance consistent with 1910.158.

Under 1910.162 (Carbon Dioxide, Halon and Other Gaseous Extinguishing Systems), which consensus standards does Appendix B identify as useful guidance?

Appendix B lists ANSI/NFPA No. 12 (Carbon Dioxide Systems), ANSI/NFPA No. 12A (Halon 1301 Systems), and ANSI/NFPA No. 12B (Halon 1211 Systems) as consensus standards relevant to the subjects covered by 1910.162; see Appendix B to Subpart L of Part 1910.

  • These NFPA documents provide design, installation, and safety guidance for gaseous extinguishing systems; employers should use them alongside the legal requirements of 1910.162.

Under 1910.161 (Dry Chemical and Other Extinguishing Systems), does OSHA reference NFPA 17 and related standards for dry chemical systems?

Yes. Appendix B lists ANSI/NFPA No. 17 (Dry Chemical Systems) and related standards as consensus guidance applicable to 1910.161; see Appendix B to Subpart L of Part 1910.

  • NFPA 17 provides installation and maintenance guidance for dry chemical extinguishing systems that employers can follow to help meet the expectations of 1910.161.

Does using a consensus standard listed in Appendix B automatically guarantee OSHA compliance for a Subpart L requirement?

No. While following a consensus standard listed in Appendix B is considered acceptable guidance, it does not automatically guarantee OSHA compliance with the regulation's legal requirements; see Appendix B to Subpart L of Part 1910.

  • Appendix B indicates these national consensus standards "contain information and guidelines that would be considered acceptable in complying with requirements in the specific sections of subpart L," but employers remain responsible for meeting the exact language of the OSHA standard cited (for example, 1910.157).
  • If a consensus standard conflicts with an OSHA requirement, the OSHA regulation controls.

Under 1910.156 (Fire Brigades), can NFPA 1041 be used as guidance for fire service instructor qualifications?

Yes. NFPA 1041 (Fire Service Instructor Professional Qualifications) is listed in Appendix B as acceptable guidance for instructor qualifications referenced by 1910.156; see Appendix B to Subpart L of Part 1910.

  • NFPA 1041 provides competency-based criteria for training and instructor qualifications you can use to develop compliant training programs under 1910.156.

Under 1910.157, does NFPA 10 provide details on inspection and maintenance frequency for portable fire extinguishers that employers can follow?

Yes. NFPA 10 contains inspection, maintenance, and testing intervals for portable fire extinguishers and is listed in Appendix B as acceptable guidance for meeting parts of 1910.157; see Appendix B to Subpart L of Part 1910.

  • Use NFPA 10's recommended monthly inspections and annual maintenance as a recognized method to satisfy the practical inspection and maintenance expectations under 1910.157, while documenting the employer's compliance actions.

Under 1910.164 and 1910.165, is NFPA 72 (in its various parts) explicitly referenced by OSHA as acceptable consensus guidance for different signaling systems?

Yes. Appendix B lists parts of NFPA 72 (such as NFPA 72A, 72B, 72D, 72E) as acceptable consensus standards for the signaling systems addressed in 1910.164 and 1910.165; see Appendix B to Subpart L of Part 1910.

  • Apply the specific NFPA 72 part that matches your system type (central-station, proprietary, auxiliary, etc.), while ensuring that your implemented system also meets the regulatory requirements in the applicable OSHA sections.

Under 1910.162, are explosion suppression systems and water spray systems covered by any NFPA standards listed in Appendix B?

Yes. Appendix B lists NFPA standards such as NFPA 69 (Explosion Suppression Systems) and NFPA 15 (Water Spray Systems) as acceptable guidance for topics that relate to 1910.162 and related Subpart L sections; see Appendix B to Subpart L of Part 1910.

  • These NFPA documents offer design and safety guidance for suppression and water spray systems; employers should use them in combination with applicable OSHA requirements.

Under 1910.158, can NFPA 1231 be used for water supply considerations for suburban/rural firefighting operations?

Yes. NFPA 1231 (Water Supplies for Suburban and Rural Fire Fighting) is included in Appendix B as consensus guidance touching on water-supply issues associated with 1910.158; see Appendix B to Subpart L of Part 1910.

  • Use NFPA 1231 to plan and evaluate water-supply arrangements for areas not served by municipal water systems, while ensuring your overall system complies with the applicable OSHA standards.

Under 1910.135 (Head Protection), are crane operators required to wear protective helmets when there is a risk from overhead falling objects while operating cranes?

Yes. Employers must ensure crane operators wear protective helmets when there is potential for head injury from falling objects while operating cranes, as explained in OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2 which references the requirement for head protection when overhead hazards exist.

  • The interpretation explains that if an operator is exposed to overhead hazards (for example, lifting loads with a crane), the employer must provide and require head protection and may rely on the applicable consensus standards for helmet performance.

Under general fall-protection rules, does an HVAC worker who walks directly from a portable ladder onto a low-slope roof 12 feet above ground and walks to a work area 25 feet from the edge need fall protection while walking to the HVAC unit?

No. According to OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-1, an employee who steps off a portable ladder onto a low-slope roof and walks directly to a work area 25 feet from the edge is not automatically required to have fall protection while walking; however, different rules apply when work is performed near the roof edge or when the work is not infrequent and temporary.

  • The interpretation notes that fall protection may be required when work is performed within certain distances of the roof edge or when the work is not both infrequent and temporary, and directs employers to 1910.28(b)(13) (as discussed in the interpretation) for applicable requirements.

Do mobile ladder stand platforms used to access CNC machine tables need steps with specific rise, depth, and width, and where can I find those requirements?

Yes. OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-0 explains that mobile ladder stand platforms must meet the dimensional requirements found in the ladder and mobile platform rules, including a step width of at least 16 inches, step rise no more than 10 inches, and step depth of at least 7 inches.

  • The interpretation cites the specific ladder/platform provisions and also references guardrail and handrail thresholds based on platform height; review the cited interpretation for the full list of dimensional and guarding requirements.

If a maintenance task requires temporary energization for testing or positioning and cannot be done with the energy isolated, is there a permitted alternative to lockout/tagout?

Yes, but only under strict, temporary conditions. OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21 explains that [1910.147(f)(1)] allows temporary removal of lockout/tagout devices and re-energization when necessary to test or position machines, provided a detailed sequence is followed and effective employee protections (such as guarding) are in place.

  • The interpretation lists required steps (clear tools/materials, remove employees from hazard areas, remove LOTO devices per the procedure, energize for testing with effective protections, then de-energize and reapply LOTO if needed) to maintain employee safety during these transition periods.

For Process Safety Management (PSM) coverage under 1910.119, does storing many pre-charged air conditioners that together contain 10,000 pounds or more of a Category 1 flammable gas make the warehouse subject to PSM requirements?

Yes. OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06 concludes that storage of pre-charged units that together contain a Category 1 flammable gas on site in one location at or above the 10,000‑pound threshold constitutes a PSM-covered process under 1910.119.

  • The interpretation explains that "process" includes storage and on-site movement and that the aggregate weight in one location is what determines coverage, so affected facilities must evaluate and, if covered, comply with PSM requirements.

For measuring stair width under 1910.25(c)(4), should handrails be treated as obstructions when determining the required minimum stair width?

No. OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-17 clarifies that handrails are not considered vertical barriers or obstructions for purposes of measuring the minimum stair width required by [1910.25(c)(4)].

  • The stair width is measured between vertical barriers such as walls, guardrails, or stair rails; handrails do not reduce the required clear width between vertical barriers.