A fire prevention plan must be in writing, be kept in the workplace, and be made available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to employees. [29 CFR 1910.39(b)]
At a minimum, your fire prevention plan must include:
- A list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard. [29 CFR 1910.39(c)(1)]
- Procedures to control accumulations of flammable and combustible waste materials. [29 CFR 1910.39(c)(2)]
- Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials. [29 CFR 1910.39(c)(3)]
- The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires. [29 CFR 1910.39(c)(4)]
- The name or job title of employees responsible for the control of fuel source hazards. [29 CFR 1910.39(c)(5)]
An employer must inform employees upon initial assignment to a job of the fire hazards to which they are exposed. An employer must also review with each employee those parts of the fire prevention plan necessary for self-protection. [29 CFR 1910.39(d)]
Fire is a chemical reaction that requires three elements to be present for the reaction to take place and continue. The three elements are:
- Heat, or an ignition source
These three elements typically are referred to as the “fire triangle”.
Fire prevention requires segregating the three elements of the fire triangle. In practice, a method to achieve that goal is to post—and enforce—no smoking signs around flammable liquids and gases and have fire watches on all work involving torch-applied materials of a minimum of two hours after the last torch is turned off.
Flammable and Combustible Liquids
Proper storage and handling of flammable and combustible liquids will help prevent fires from occurring; only approved, closed containers for storage of flammable or combustible liquids may be used under OSHA rules. Such containers include safety cans or containers approved by the U.S. Department of Transportation. A safety can is a container that has a self-closing lid, internal-pressure relief and flame arrestor with a capacity of not more than 5 gallons. Inexpensive, plastic cans without those features previously mentioned, such as those typically bought at hardware stores or gas stations, are not approved for use in roofing operations. However, manufacturers do sell plastic containers that meet the OSHA requirements for safety cans. Flammable liquids that are extremely viscous, or difficult to pour, like single ply adhesive, can be left in their original shipping containers. Similarly, OSHA allows the use of original containers of flammable liquids that are in quantities of one gallon or less. Static electricity may be generated when transferring liquids, gases or solids through pipes or hoses. It is important to dissipate this electric charge when handling flammable and combustible materials.
Liquefied Petroleum Gas
Liquefied petroleum gas (LP gas) is used widely in the roofing industry to heat kettles and torches. Because LP gas is a compressed gas, fairly large quantities can be stored in relatively small containers. As a point of reference, LP gas expands at a ratio of 270-to-1. This means that one liquid drop of LP gas would expand to a gas state 270 times greater in volume. LP gas collects in low-lying areas because its vapor density is heavier than air. Employees should be warned that if they suspect a leak in a cylinder, they must not use fire to attempt to find the hole. Instead, they are to use soapy water and look for bubbles.
Employees should not attempt to extinguish fires involving LP gas. If an LP gas fire breaks out, employees should evacuate the area immediately and call the fire department. Fighting an LP gas fire requires specialized training that only the fire department can provide.
Fire Alarm Devices
OSHA requires an alarm system be established by an employer to alert workers on the job site and local fire departments of fire emergencies. Jobsite telephones and employee entrances must have alarm codes and reporting instructions at employee entrances.
The use of fire extinguishers in the workplace is based on company policy regarding employee firefighting found in the Emergency Action Plan and local fire code. Therefore, OSHA does not require every employee to be trained in use or required to use them.
OSHA standard 29 CFR 1910.157(a) and (b) contemplate three possible choices which an employer may make to comply with the intent of the standard:
OPTION 1: Require total evacuation of employees from the workplace upon the sounding of a fire alarm.
OPTION 2: Provide portable fire extinguishers and designate certain employees as authorized to use them to fight fires.
OPTION 3: Provide portable fire extinguishers and permit all employees to use them to fight fires.
OSHA’s fire protection standards are performance-oriented standards designed to provide the employer greater flexibility in compliance. The intent of the standard is to minimize employee exposure to hazardous situations involving fire in the workplace and to provide for fire protection equipment and services for safe evacuation or rescue of employees endangered by fire in the workplace. OSHA believes that employers who choose to evacuate the workplace rather than to provide fire extinguishers for employee use in fighting fires will most effectively minimize the potential for fire-related injuries to employees.
Where the employer has provided portable fire extinguishers for use in the workplace, the employer shall also provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage firefighting. Training is required upon employment and at least annually thereafter. It is recommended the training session cover how to determine when a fire is too big to handle; what type of extinguisher to use; and the PASS system of early-stage firefighting. It also is recommended that live fire training be conducted periodically (this level of training is not needed each year). Live training exposes employees to the pressure released from a fire extinguisher when the handle is squeezed and provides hands-on practice extinguishing a fire. Some local fire departments and most fire extinguisher suppliers offer this type of training.
Spencer-SHE has been providing Safety, Health and Environmental Compliance Guidance since 1980. We offer safety compliance training for flammables, combustibles, and fire prevention, as well as hazardous materials security training.
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