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OSHA 1915SubpartPAppA

Model Fire Safety Plan Guidance

Subpart P

22 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.502 and Appendix A to Subpart P, what is the main purpose of a Fire Safety Plan?

The purpose of a Fire Safety Plan is to inform employees how the employer will reduce fire risks and what equipment and procedures employees should use if a fire occurs. Appendix A provides a model plan to help employers meet the requirement in 1915.502 and explains topics such as hazards, alarm systems, evacuation routes, and employee awareness. Employers should use the model items in Appendix A to Subpart P of Part 1915 to create a plan tailored to their workplace conditions.

Under 1915.502, what specific workplace fire hazards should a Fire Safety Plan identify and control?

A Fire Safety Plan must identify potential ignition sources, fuel sources, and conditions that could let a fire spread, and describe how each hazard will be controlled. Appendix A lists examples employers should cover, such as measures to contain fires, ignition-source controls, and types of fire protection systems; these are consistent with the employer obligations in 1915.502 and the model topics in Appendix A.

  • Include specific ignition sources (e.g., hot work, electrical faults).
  • Describe fuel control (e.g., housekeeping, storage of flammables).
  • State who inspects and maintains controls and how often.

Under 1915.502 and Appendix A, who should be named as responsible for maintaining fire protection equipment and systems?

The Fire Safety Plan must describe the personnel responsible for maintaining fire protection equipment, alarms, and systems and specify their duties. Appendix A explicitly calls for a description of the personnel responsible for maintaining equipment and alarms as part of the plan to meet 1915.502 requirements, and employers must ensure those roles are clear and assigned. For guidance on assigning competent staff, see OSHA's interpretation on competent persons in shipyards, Competent person requirements in shipyards (April 18, 2016).

Under 1915.502, what should the Fire Safety Plan say about alarm systems and how to report fires?

The plan must describe the work site emergency alarm system, procedures for reporting fires, and provide demonstrations if more than one alarm type exists. Appendix A lists these items as required content to satisfy 1915.502 and to make sure employees recognize alarms and know the exact steps to report a fire.

  • Describe alarm signals and what each means.
  • Give the phone numbers or radio channels for reporting fires.
  • Explain who must report and how to confirm a report was received.

Under 1915.502 and Appendix A, what information must a Fire Safety Plan include about evacuation procedures?

The plan must include emergency escape procedures, assigned evacuation routes, methods to account for all employees after evacuation, and guidance on different evacuation types and employee roles. These elements are included in Appendix A as a model to satisfy the requirements of 1915.502.

  • Map primary and alternate escape routes.
  • Describe how supervisors will perform head counts or use rosters.
  • Clarify when to shelter in place versus full evacuation.

Under 1915.502 and Appendix A, how should a Fire Safety Plan address helping physically impaired employees during an evacuation?

The Fire Safety Plan must include procedures to assist physically impaired employees during evacuation, specifying who will help them and how. Appendix A lists 'helping physically impaired employees' as a required topic to ensure all workers can evacuate safely in compliance with 1915.502.

  • Assign trained buddies or evacuation assistants.
  • Identify refuge areas if full evacuation is not immediately possible.
  • Include equipment needs (e.g., evacuation chairs) and training for assistants.

Under 1915.502, does Appendix A require employers to teach selected employees how to use fire protection equipment?

Yes; the model plan advises employers to train selected employees in the correct use of fire protection equipment. Appendix A specifically lists 'teaching selected employees how to use fire protection equipment' as part of the model Fire Safety Plan to help meet 1915.502 requirements. Employers should document who is trained, what equipment they are trained on, and how often refresher training occurs.

Under 1915.502 and Appendix A, what should an employer document about the level of firefighting capability present on a vessel or facility?

The Fire Safety Plan should describe the level of firefighting capability available on the facility, vessel, or vessel section so employees understand what firefighting actions are expected and what professional response will occur. Appendix A includes 'the level of firefighting capability present in the facility, vessel, or vessel section' as a model plan topic to comply with 1915.502.

  • State whether employees will perform only initial extinguisher use or limited response.
  • Note presence of trained fire brigades or reliance on external fire departments.

Under 1915.502, is the model Fire Safety Plan in Appendix A mandatory or optional, and how should employers use it?

The model Fire Safety Plan in Appendix A is non-mandatory guidance; employers may use it as a template but must ensure their actual plan meets the requirements of 1915.502. Appendix A is explicitly labeled 'Model Fire Safety Plan (Non-Mandatory)' and is intended to assist employers in preparing a compliant plan rather than impose additional mandatory text, as reflected in Appendix A to Subpart P of Part 1915.

Under 1915.502 and Appendix A, what procedures should be included for reporting a fire once it is discovered?

The plan must state clear step-by-step procedures for reporting a discovered fire, including who to notify, how to notify (voice, radio, alarm pull), and what basic information to give. Appendix A lists 'procedures for reporting fires' as a core element to meet 1915.502.

  • Tell employees to sound the alarm and call the designated emergency number.
  • Require location, size, and whether people are trapped be reported.
  • Include backup reporting methods if primary means fail.

Under 1915.502 and Appendix A, how often should employers demonstrate alarm procedures to employees?

Employers should demonstrate alarm procedures at least when employees are trained and whenever there are multiple alarm types or changes in alarm systems; Appendix A recommends demonstrations to ensure employees recognize and respond correctly, supporting compliance with 1915.502. While the appendix is non-mandatory, regular demonstrations are a best practice to keep staff familiar with alarm signals and response actions.

Under 1915.502 and Appendix A, what accounting procedures should be in the Fire Safety Plan to confirm all employees are safe after evacuation?

The Fire Safety Plan must include procedures to account for all employees after evacuation, such as roll calls, headcounts at assembly areas, or electronic check-in systems. Appendix A specifically lists 'procedures to account for all employees after completing an emergency evacuation' as a model plan component to meet 1915.502.

  • Designate supervisors to check specific groups or zones.
  • Keep up-to-date employee rosters at assembly points.
  • Establish communication back to incident commanders if someone is missing.

Under 1915.502, how should an employer describe escape routes and route assignments in the Fire Safety Plan (Appendix A)?

The Fire Safety Plan must identify emergency escape procedures and route assignments, showing primary and alternate routes and marking them for employees. Appendix A lists 'emergency escape procedures and route assignments' as essential plan content to satisfy 1915.502. Employers should make maps available, keep routes clear, and train employees on their assigned exit paths.

Under 1915.502 and Appendix A, what should be included about types of fire protection equipment and how they control fires?

The Fire Safety Plan should describe the types of fire protection equipment and systems on site and explain how each can be used to control a fire or limit its spread. Appendix A highlights 'types of fire protection equipment and systems that can control a fire' as a required model element consistent with 1915.502.

  • Identify portable extinguishers, fixed suppression systems, and alarms.
  • Explain which classes of fires each extinguisher can be used on.
  • Note limitations and when employees should evacuate rather than fight a fire.

Under 1915.502 and Appendix A, how should employers train employees to recognize potential ignition sources?

Employers should train employees to identify likely ignition sources (e.g., welding, hot work, electrical faults, open flames) and to follow control procedures; Appendix A includes 'potential ignition sources for fires and how to control them' as a model training topic to satisfy 1915.502. Training should be job-specific and include safe work practices and required permits (for example, hot work permits).

Under 1915.502 and Appendix A, what does the model plan say about measures to contain fires?

The model plan advises employers to list measures that will contain fires, such as compartmentalization, fire doors, portable extinguishers, suppression systems, and house-keeping to reduce fuels. Appendix A includes 'measures to contain fires' as part of the model Fire Safety Plan to meet 1915.502. Employers should match containment measures to the site layout and identified hazards.

Under 1915.502 and Appendix A, can an employer rely on outside emergency responders instead of training employees to use fire protection equipment?

Yes, an employer may rely on outside emergency responders for firefighting, but the Fire Safety Plan must clearly state the level of on-site capability and ensure employees are trained on what to do until responders arrive. Appendix A asks employers to describe the 'level of firefighting capability present in the facility, vessel, or vessel section' to comply with 1915.502. If employees are not expected to fight fires, they still need training on detection, reporting, evacuation, and initial safe actions.

Under 1915.502 and Appendix A, what employee awareness items should be part of routine training?

Employee awareness training should cover fire hazards, how to report fires, alarm signals, evacuation routes, use of extinguishers (if expected), and assistance for impaired coworkers. Appendix A lists 'employee awareness' as a model section to satisfy 1915.502. Keep training brief, practical, and documented, and refresh training when conditions or procedures change.

Under 1915.502 and Appendix A, how should an employer handle multiple alarm types at a work site?

If the workplace has more than one type of alarm, the Fire Safety Plan should include demonstrations and clear instructions so employees can recognize and respond to each alarm type. Appendix A specifically calls for 'a demonstration of alarm procedures, if more than one type exists' to meet the model guidance and support compliance with 1915.502. Employers should document demonstrations and ensure all shifts receive instruction.

Under 1915.502 and Appendix A, what records or documentation should the Fire Safety Plan keep to show compliance?

While Appendix A is non-mandatory guidance, employers should document the Fire Safety Plan, training records, equipment maintenance logs, alarm tests, and evacuation drills as evidence of implementing the plan and meeting 1915.502.

  • Keep training sign-in sheets with dates and topics.
  • Retain inspection and maintenance records for extinguishers and suppression systems.
  • Document evacuation drill dates, participants, and lessons learned.

Under 1915.502 and Appendix A, how should employers describe the level of expected employee firefighting actions in the plan?

The plan should state whether employees are expected to perform only initial actions (like using a portable fire extinguisher for very small fires) or to engage in more structured firefighting, and it should include required training and limitations. Appendix A asks employers to describe 'the level of firefighting capability present' so that roles and expectations are clear in line with 1915.502. Employers must ensure that any expectation for employees to fight fires matches their training, equipment, and safety.

Under 1915.502 and Appendix A, when should an employer revise the Fire Safety Plan?

Employers should revise the Fire Safety Plan whenever there are changes in work operations, new hazards, modifications to building layout or fire systems, or after drills or incidents reveal deficiencies. Appendix A is intended as a living model to help meet 1915.502, and regular review ensures the plan stays accurate and effective. Document each revision and retrain affected employees on changes.