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OSHA 1915.507

Land-side fire protection systems

Subpart P

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.507(a), what are the employer's responsibilities for land-side fire protection systems?

The employer must ensure all fixed and portable fire protection systems needed to meet an OSHA standard for employee safety in land-side facilities meet the requirements of 1915.507.

  • This includes buildings, structures, and equipment on shore (land-side) that protect employees from fire hazards. See 1915.507(a).
  • Employers must follow the specific selection, installation, inspection, maintenance, and testing rules in the rest of 1915.507 for portable and fixed systems.

Under 1915.507(b)(1), which standard must employers follow when selecting and maintaining portable fire extinguishers?

Employers must select, install, inspect, maintain, and test portable fire extinguishers according to NFPA 10-2002 as incorporated by reference in 1915.5.

  • The requirement is stated in 1915.507(b)(1) and the incorporation of NFPA 10-2002 is made through 1915.5.
  • Follow NFPA 10 schedules and procedures (type, placement, inspection intervals, maintenance, and testing) to meet OSHA compliance.

Under 1915.507(b)(2), can Class II or Class III hose systems be used as portable fire extinguishers and what must be followed?

Yes — employers may use Class II or Class III hose systems as portable fire extinguishers if they follow the specific recommendations in NFPA 14-2003 for standpipe and hose systems.

  • That permission and requirement are in 1915.507(b)(2) and NFPA 14-2003 is incorporated by reference under 1915.5.
  • In practice this means design, installation, inspection, maintenance, and testing must meet NFPA 14 guidance (e.g., hose length, pressure, and connection locations) before treating a standpipe/hose as a portable extinguisher.

Under 1915.507(c)(1), must components and extinguishing agents for fixed systems be approved by an NRTL?

Yes — any fixed extinguishing system component or agent must be approved by an OSHA Nationally Recognized Testing Laboratory (NRTL) for the specific hazards it will control.

  • The requirement appears in 1915.507(c)(1) and NRTL recognition requirements are set out in 1910.7.
  • Ensure the listed NRTL has evaluated the exact equipment/agent for the hazard class you expect (for example, CO2 system components for a CO2 hazard).

Under 1915.507(c)(2), what must an employer do if a fire extinguishing system stops working?

The employer must notify employees and take necessary precautions to keep employees safe from fire until the extinguishing system is working again.

  • This duty is stated in 1915.507(c)(2).
  • "Necessary precautions" can include temporary shutdown of hazardous operations, restricting access to high‑risk areas, providing alternative firefighting coverage, or evacuating affected areas until the system is repaired.

Under 1915.507(c)(3), who must perform repairs to fire extinguishing systems and equipment?

All repairs to fire extinguishing systems and equipment must be done by a qualified technician or mechanic.

  • This requirement is in 1915.507(c)(3).
  • "Qualified" means the person has the training, experience, and manufacturer or industry-recognized competency to perform the repair safely and restore the system to serviceable condition.

Under 1915.507(c)(4) and 1915.12, what must an employer do before an employee enters areas where an extinguishing system discharge leaves a hazardous atmosphere?

The employer must provide proper personal protective equipment (PPE) or safeguards to prevent entry until the atmosphere is safe, and follow the safe-entry requirements in 1915.12 when entering spaces with dangerous atmospheres.

  • This immediate duty appears in 1915.507(c)(4) and additional safe‑entry rules are referenced to 1915.12.
  • Practical steps include: testing the atmosphere, using appropriate respirators or supplied-air, establishing an entry permit if required, and training employees on hazards and rescue procedures.

Under 1915.507(c)(5), what signage must be posted where fixed extinguishing systems use hazardous concentrations of agents?

The employer must post hazard warning or caution signs at both the entrance to and inside of areas protected by fixed extinguishing systems that use agents at concentrations known to be hazardous to employee safety or health.

  • See 1915.507(c)(5).
  • Signs should clearly identify the hazard (type of agent), entry restrictions, required PPE, and emergency procedures so employees are warned before entering such areas.

Under 1915.507(c)(6), what standards apply to automatic fire detection systems and alarms?

Automatic fire detection systems and emergency alarms must be selected, installed, inspected, maintained, and tested in accordance with NFPA 72-2002 as incorporated by reference in 1915.5.

  • That requirement is spelled out in 1915.507(c)(6) and NFPA 72-2002 is incorporated via 1915.5.
  • Follow NFPA 72 schedules and procedures for detectors, notification devices, and routine testing to remain compliant.

Under 1915.507(d), which NFPA standards must employers follow for fixed extinguishing systems types?

Employers must select, install, maintain, inspect, and test fixed extinguishing systems according to the NFPA standards listed in 1915.507(d).

  • Standpipe and hose systems: 1915.507(d)(1) → NFPA 14-2003.

  • Automatic sprinkler systems: 1915.507(d)(2) → NFPA 25-2002 and either NFPA 13-2002 or NFPA 750-2003.

  • Water or foam fixed systems: 1915.507(d)(3) → NFPA 15-2001 and NFPA 11-2005.

  • Dry chemical systems: 1915.507(d)(4) → NFPA 17-2002.

  • Gaseous extinguishing systems: 1915.507(d)(5) → NFPA 12-2005, NFPA 12A-2004, and NFPA 2001-2004.

  • These NFPA standards are incorporated by reference through 1915.5. Follow the specific NFPA provisions for design, inspection intervals, testing, and maintenance.

Under 1915.507(d)(2), what are the inspection and maintenance requirements for automatic sprinkler systems?

Automatic sprinkler systems must be inspected, tested, and maintained per NFPA 25-2002 and must be installed per NFPA 13-2002 or NFPA 750-2003 as appropriate.

  • This is required by 1915.507(d)(2) with NFPA standards incorporated by 1915.5.
  • Follow NFPA 25 inspection/test/maintenance schedules (e.g., weekly/quarterly/annual checks, internal piping inspections, flow and alarm devices testing) to maintain compliance and system readiness.

Under 1915.507(b), how should an employer determine inspection frequency for portable extinguishers?

Employers must follow the inspection and testing intervals and procedures set out in NFPA 10-2002, which is incorporated by reference in 1915.5.

  • See 1915.507(b)(1) and 1915.5.
  • In practice NFPA 10 requires monthly visual checks, annual maintenance inspections, periodic hydrostatic testing, and recharge after use. Employers should adopt NFPA 10 schedules and keep inspection records as appropriate.

Under 1915.507(c)(1), where can employers confirm that a testing laboratory is OSHA-recognized as an NRTL?

Employers can confirm Nationally Recognized Testing Laboratory (NRTL) recognition through OSHA's NRTL program requirements in 1910.7.

  • The obligation to use NRTL-approved components is in 1915.507(c)(1).
  • Check OSHA's current NRTL list and the scope of each NRTL's recognition (devices and hazards covered) as required by 1910.7 to ensure the specific product/agent is covered.

Under 1915.507(c)(2), does an employer have to evacuate employees when a fixed extinguishing system is inoperative?

Not always; the employer must notify employees and take necessary precautions to ensure employee safety, which could include evacuation if other controls cannot provide equivalent protection.

  • The duty to notify and protect employees while systems are out of service is in 1915.507(c)(2).
  • Appropriate precautions depend on the hazard: temporary shutdown, restricted access, alternate suppression coverage, increased fire watches, or evacuation may all be acceptable measures depending on risk.

Under 1915.507(c)(3), what documentation or evidence helps demonstrate that a repair person is a "qualified technician"?

Evidence that a repairer is a qualified technician includes training certificates, manufacturer authorization, licensing, and documented experience specific to the system type being repaired.

  • The requirement that repairs be made by a qualified technician appears in 1915.507(c)(3).
  • Keep records of qualifications (training records, certification, employer competency evaluations, and manufacturer service authorization) to show the individual is competent for the repair work.

Under 1915.507(d)(3), what standards apply to fixed water or foam fire protection systems?

Fixed systems that use water or foam must comply with NFPA 15-2001 for water spray systems and NFPA 11-2005 for low-, medium-, and high-expansion foam systems as listed in 1915.507(d)(3).

  • See 1915.507(d)(3) and the incorporation of NFPA standards via 1915.5.
  • Follow the NFPA design, installation, inspection and maintenance requirements (e.g., nozzle spacing, foam proportioning, regular testing) applicable to the system type.

Under 1915.507(d)(4), what governs fixed dry chemical extinguishing systems?

Fixed dry chemical extinguishing systems must comply with NFPA 17-2002 for design, installation, inspection, and maintenance.

  • The requirement is in 1915.507(d)(4) and NFPA 17-2002 is incorporated by reference under 1915.5.
  • Follow NFPA 17 guidance (e.g., agent selection, cylinder testing intervals, discharge controls) to ensure system reliability and OSHA compliance.

Under 1915.507(d)(5), which standards govern gaseous extinguishing systems and what should employers check for these systems?

Gaseous extinguishing systems are governed by NFPA 12-2005 for CO2 systems, NFPA 12A-2004 for Halon 1301, and NFPA 2001-2004 for clean agent systems as listed in 1915.507(d)(5).

  • Employers should check system design, agent concentration calculations, discharge timing, alarms, interlocks, and inspection/testing schedules in accordance with the applicable NFPA standard and the incorporation in 1915.5.
  • Also ensure NRTL approval for system components per 1915.507(c)(1).

Under 1915.507(c)(4) and OSHA guidance on head protection, must employers provide head protection when employees enter discharge areas where hazardous agents may be present?

Yes — employers must provide appropriate protective equipment when employees face potential head hazards or other hazards while entering discharge areas, and must also provide PPE or safeguards for hazardous atmospheres per 1915.507(c)(4).

  • The fixed-system entry requirement is in 1915.507(c)(4).
  • OSHA has clarified that employers must assess hazards and provide head protection where there is potential for head injury; see the OSHA interpretation on head protection at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2. Employers must evaluate all hazards (chemical, mechanical, falling objects) and supply PPE that addresses those hazards.