Fire watch requirements

The written fire watch policy must state the required training, duties, equipment, and PPE for employees assigned to fire watch duty. Specifically, the policy must cover the training employees must be given (see 1915.508(c)), the duties they will perform, the equipment they will be given, and the personal protective equipment that must be made available and worn as required by 29 CFR Part 1915, Subpart I. Employers should keep the policy current and readily available for supervisors and fire-watch personnel as required by 1915.504(a).

Employees assigned to fire watch must receive the fire-watch training described in 1915.508(c). That training must enable them to detect fires in areas exposed to hot work, to attempt to extinguish small (incipient) fires within their equipment and training capability, to alert others if a fire is beyond the incipient stage, and to activate the alarm if they cannot control the fire; these duties are referenced in 1915.504(c)(2).

Employers must provide the fire-watch employees the equipment identified in the written policy and make required personal protective equipment available and ensure it is worn in accordance with 29 CFR Part 1915, Subpart I and 1915.504(a)(3)-(4). Employers are required to pay for required PPE (subject to narrow exceptions) under OSHA's employer-payment rules; see OSHA's guidance on employer payment for PPE in the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13 for practical details.

A fire watch must be posted whenever hot work involves hazards that cannot be eliminated or fully protected against, including when: the hot work is on or near materials (insulation, combustible coatings, sandwich-type construction) that cannot be removed or shielded; combustible materials may be ignited on the opposite side of bulkheads, decks, or sandwich construction; hot work is close enough to cause ignition by radiation or conduction of insulated pipes or combustible coatings; hot work is close to unprotected combustible pipe or cable runs; or a Marine Chemist, Coast Guard-authorized person, or shipyard Competent Person requires it. See the specific triggers at 1915.504(b)(4)–(8) and related subsections in 1915.504(b).

It means you must post a fire watch when hot work occurs where nearby combustible materials (like insulation, combustible coatings, or sandwich construction) cannot be physically removed, cut back, or protected with flameproof shielding to prevent ignition. In those circumstances the hazard cannot be adequately controlled by removal or shielding, so a fire watch is required under 1915.504(b)(4).

You must consider whether heat radiation or conduction from the hot work can raise adjacent insulated pipes, bulkheads, decks, partitions, overheads, or combustible materials and coatings to temperatures that could ignite them; if so, a fire watch is required under 1915.504(b)(6)(i)-(ii). Practically, this means evaluating distance, exposure time, type of thermal source, and whether thermal shielding or insulation can prevent heat transfer—if these controls are insufficient, post a fire watch as required by 1915.504(b).

When hot work is performed so near unprotected combustible piping or cable runs that sparks, heat radiation, or conduction could ignite those runs, you must post a fire watch. The determination is based on proximity and the likelihood of ignition; if you cannot protect or shield the runs, a fire watch is required per 1915.504(b)(7).

A Marine Chemist, a Coast Guard-authorized person, or a shipyard Competent Person may require a fire watch to be posted. The definition and authority of a Competent Person in shipyard operations—who can recognize hazards and specify necessary protection—is explained in OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18 and the requirement is stated in 1915.504(b)(8).

No—an employer must not assign other duties to a fire watch while the hot work is in progress. Fire-watch personnel must focus solely on their fire-watch responsibilities during hot work as required by 1915.504(c)(1).

It means fire-watch personnel must be positioned and equipped so they can see the whole area they are watching and reach any part of that area quickly to respond or to use firefighting equipment. If a single person cannot achieve clear view and immediate access, the employer must assign additional watchers or provide means (mirrors, cameras, access points) to ensure compliance with 1915.504(c)(2)(i).

Fire-watch employees must be able to communicate quickly and reliably with workers performing hot work, using voice, radio, hand signals, or other effective means so they can warn workers of danger or order work stopped, as required by 1915.504(c)(2)(ii).

Yes—a fire-watch employee must be authorized to stop work if necessary and to restore safe conditions in the hot work area. Employers must give this authority and ensure fire-watch personnel understand when and how to stop work under 1915.504(c)(2)(iii).

A fire-watch must remain in the hot work area for at least 30 minutes after hot work is completed unless the employer or its representative surveys the exposed area and determines there is no further fire hazard. The 30-minute minimum (or earlier release after an employer survey) is specified in 1915.504(c)(2)(iv).

Fire-watch employees must be trained to detect fires in areas exposed to hot work and, within the limits of their training and the capability of the available equipment, must attempt to extinguish incipient stage fires. If a fire is beyond their ability to control, they must alert others and activate the alarm, as required by 1915.504(c)(2)(v)-(vi). Fire-watch training qualifications and limits on extinguishing actions are further detailed in 1915.508(c).

If a fire watch cannot extinguish a fire in the exposed area, they must immediately alert employees of any fire beyond the incipient stage and activate the alarm. These obligations are stated in 1915.504(c)(2)(vii)-(viii).

It means the employer must assign fire-watch duty only to employees who can perform the required tasks without physical limitation—able to stand and survey the area, use firefighting equipment, communicate, and stop work if necessary. The standard requires physical capability in 1915.504(c)(3). OSHA letters, such as the crane-operator interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2013-09-13, emphasize that employers must ensure employees assigned to safety-critical duties can perform them without unscheduled interruption.

Fire-watch duties include maintaining a clear view of the hot work area, communicating with workers exposed to hot work, stopping work if necessary, remaining for at least 30 minutes after completion (unless the area is surveyed and cleared), detecting fires in exposed areas, attempting to extinguish incipient fires within their training and equipment capability, alerting others if the fire is beyond the incipient stage, and activating the alarm if unable to extinguish the fire. These duties are described in 1915.504(a)(2) and 1915.504(c)(2).

Posting fire watches means the employer must station trained, equipped fire-watch personnel at locations and times where the hazards of hot work require continuous observation and immediate response, as described in 1915.504(b). Practically, this includes assigning enough watchers to provide clear views and access to all exposed areas, providing communication devices and extinguisher equipment, and documenting assignments in the written fire-watch policy under 1915.504(a).

Yes—if the employer or its representative surveys the exposed area after hot work and determines there is no further fire hazard, the fire-watch may leave before the 30-minute minimum. Otherwise, the fire-watch must remain for at least 30 minutes as required by 1915.504(c)(2)(iv).

If a single fire watcher cannot maintain a clear view of the entire area, the employer must assign additional fire-watch personnel or provide means (for example, repositioning, mirrors, cameras, or lookout points) to ensure all exposed areas are visible and accessible, as required by 1915.504(c)(2)(i).

Acceptable methods include voice communication, two-way radios, dedicated hand signals, horns/whistles, or other reliable systems that enable immediate contact and clear direction to stop work; the fire watch must also be authorized by the employer to use those methods to stop hot work and restore safe conditions, per 1915.504(c)(2)(ii)-(iii).

A fire watch should attempt to extinguish only incipient stage fires that are within the capability of the available equipment and within the fire watch's training qualifications; the limits of training and equipment are set out in 1915.504(c)(2)(vi) and in the fire-watch training requirements at 1915.508(c). If a fire exceeds those limits, the fire watch must alert others and activate the alarm.

PPE for fire-watch employees is governed by 29 CFR Part 1915, Subpart I (personal protective equipment) and the requirement to make PPE available is in 1915.504(a)(4). See 1915 Subpart I for specific PPE requirements, and remember employers must generally pay for required PPE as clarified in OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13.

Fire-watch training must cover detection of fires in areas exposed to hot work, how to attempt to extinguish incipient fires consistent with available equipment and training qualifications, how to alert others and activate alarms if fires cannot be controlled, and other job-specific emergency procedures; these training details are specified in 1915.508(c) and are referenced by 1915.504(a)(1).

When hot work could ignite combustible materials on the opposite side of bulkheads, decks, overheads, or sandwich construction, you must either remove or shield the combustibles, provide a fire watch, or take equivalent measures to prevent ignition; the risk of ignition by conduction or radiation triggers the fire-watch requirement in 1915.504(b)(5).