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OSHA 1926.24

Fire protection requirements

Subpart C

13 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.24, what does "ensure the availability of the fire protection and suppression equipment required by Subpart F" mean in practical terms?

It means the employer must make sure the specific fire protection and suppression equipment identified in OSHA's fire protection rules for construction is present and usable at the job site. In practice employers should consult the applicable Subpart F requirements to identify required equipment, keep that equipment on site and in working order, and promptly replace or repair needed items. See 1926.24 for the employer responsibility to provide that equipment.

Under 1926.24, does the fire protection requirement apply when a job involves post-fire remediation that may disturb asbestos?

Yes — the employer must maintain an effective fire protection and prevention program at the job site even during remediation work, and if the remediation disturbs asbestos-containing materials the employer must also comply with the asbestos-in-construction rules. 1926.24 requires a fire protection program for all phases of work, and OSHA has clarified that asbestos remediation activities are covered by the construction asbestos standard, 29 CFR 1926.1101 (see OSHA's letter on asbestos remediation protocols at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14).

Under 1926.24, does OSHA explicitly require the fire protection and prevention program to be written?

The text of 1926.24 requires employers to develop and maintain an effective program but does not itself spell out that the program must be in writing. 1926.24 requires the employer to develop and maintain the program. Employers often document programs in writing so the program can be implemented, audited, and communicated clearly, but the requirement for a written document is not explicit in the 1926.24 text provided.

Under 1926.24, must employers provide training so workers know how to use fire protection or suppression equipment?

1926.24 requires employers to develop and maintain an effective fire protection and prevention program and ensure the availability of required equipment, but it does not itself lay out specific training steps. 1926.24 establishes the employer's program responsibility. To make a program effective, employers should include appropriate training and drills; OSHA guidance on emergency response and PPE assessments also highlights the need to evaluate hazards and implement worker protections and training (see OSHA's PPE hazard assessment letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28).

Under 1926.24, am I required to have portable fire extinguishers on the site?

You must provide whatever fire protection and suppression equipment the applicable Subpart F provisions require; if Subpart F requires portable fire extinguishers for your situation, then you must have them available. 1926.24 requires employers to ensure availability of equipment required by Subpart F, so consult the Subpart F requirements for the specific equipment list at https://www.osha.gov/laws-regs/regulations/standardnumber/1926.

Under 1926.24, who is the "employer" when multiple contractors or subcontractors work on the same construction site?

1926.24 assigns responsibility to the employer to develop and maintain the fire protection program for the job site, meaning each employer is responsible for meeting the standard for their employees; coordination among general contractors and subcontractors is typically necessary to ensure a site-wide effective program. 1926.24 places responsibility on the employer to develop and maintain the program. For multi-employer sites, practical compliance usually involves the controlling contractor coordinating site-wide fire protection so all employers on site can meet their obligations.

Under 1926.24, should fire protection planning include first aid and CPR arrangements for emergencies?

Yes — an effective fire protection and prevention program should include planning for worker emergencies, which commonly covers first aid and CPR access, though 1926.24 itself focuses on fire protection and does not prescribe CPR training specifics. 1926.24 requires employers to maintain an effective fire program. OSHA guidance on first aid and CPR notes that some standards require first-aid and CPR training and recommends including appropriate emergency medical response in workplace programs (see OSHA's CPR retraining letter at https://www.osha.gov/laws-regs/standardinterpretations/2023-02-23).

Under 1926.24, must the fire protection program address hazards created by hazardous materials (for example, materials that may release asbestos when burned)?

Yes — the employer's fire protection program must be effective for the hazards present at the job site; if a fire or remediation could involve hazardous materials such as asbestos, the employer must address those hazards and comply with the applicable standards. 1926.24 requires development and maintenance of an effective program, and OSHA has clarified that asbestos disturbance during remediation falls under the construction asbestos standard 29 CFR 1926.1101 (see https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14).

Under 1926.24, is a formal hazard assessment required to determine needed fire suppression equipment and PPE for fire risks?

1926.24 requires an effective fire protection program and availability of required suppression equipment, but it does not itself set a specific hazard-assessment paperwork requirement. However, hazard assessments are a recognized part of determining appropriate protections — OSHA's PPE hazard assessment guidance explains employers must assess workplace hazards when selecting PPE and gives resources for doing so (see the PPE hazard assessment letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28). Employers should perform hazard assessments to identify fire risks and the necessary suppression equipment and PPE to make their 1926.24 program effective.

Under 1926.24, can an employer meet the standard by having only a single type of suppression system for all job phases?

Not necessarily — an employer must ensure availability of the fire protection and suppression equipment required for the hazards and phases of work at the job site; what is required depends on the hazards and the Subpart F requirements for those hazards. 1926.24 requires employers to provide the equipment required by Subpart F, so employers should consult Subpart F and assess the site's changing risks to determine whether more than one type of suppression or protection is needed.

Under 1926.24, where can I find the specific fire protection and suppression equipment requirements that apply to construction?

You should consult OSHA's Subpart F (Fire Protection and Prevention) requirements within 29 CFR 1926 to find the specific equipment and performance rules that apply to construction work. The employer duty is in 1926.24, and the detailed Subpart F provisions are found through OSHA's 29 CFR 1926 regulatory pages at https://www.osha.gov/laws-regs/regulations/standardnumber/1926.