What OSHA Says

The Occupational Safety and Health Administration (OSHA) requires that an employer furnish to each employee a place of employment that is free from recognized hazards that cause or have the potential to cause death or physical harm.

Article 29 CFR 1910 Subpart L of the Occupational Safety and Health Act contains the fire protection standards for general industry and requires each employer to develop a fire escape plan and an inspection checklist on fire protection. The plan and checklist must consider the fire hazards and the fire protection provided in the workplace. The article also requires that the employer provide a fire alarm system as part of the fire protection plan.

Additionally, the OSHA standards use NFPA 72, the National Fire Alarm and Signaling Code, and NFPA 70, the National Electrical Code, as the referenced codes that pertain to fire alarm system installation. Specifically, Section 1910.164(a) Scope and Application, applies to all automatic fire detection systems installed to meet the requirements of the OSHA standards.

OSHA requires that the alarm notification appliances provide an audible or visible signal of sufficient intensity so that all employees in the affected portion of the workplace can perceive the signal above ambient noise or light levels. The fire alarm system may use tactile devices to alert those employees who could not otherwise recognize the audible or visible alarm signal.

OSHA requires the employer to ensure all devices and equipment constructed and installed to comply with the OSHA standard are approved for their intended purpose. Similar wording is in the current edition of NFPA 72.

The OSHA standard requires that employers restore all fire detection systems and components to a normal operating condition as promptly as possible after each test or alarm. To comply with this requirement, the employer must have spare detection devices and components available on the premises or from a local supplier in sufficient quantities and locations for prompt restoration of the system. Such components must include those that normally are destroyed in the process of testing or detecting fires.

The employer must also maintain all systems in an operable condition, except during repairs or maintenance. To meet this requirement, the employer must test and adjust fire detectors and detection systems as often as needed to maintain proper reliability and operating condition. However, factory-calibrated detectors need no adjustment after installation.

The employer is responsible for placing a trained person knowledgeable in the operations and functions of the system to perform the service, maintenance and testing of fire detection systems, including cleaning and necessary sensitivity adjustments to ensure the systems remain fully operational.

Many OSHA requirements also appear in NFPA 72 2010. The difference between the documents rests in the fact that the OSHA standard is a federal law that specifies the required systems, and NFPA 72 2010 contains the application, installation, inspection, testing and maintenance requirements for fire alarm and signaling systems.

The OSHA standard requirements sometimes exceed those found in NFPA 72. For example, the employer must ensure that any fire detection equipment installed outdoors, or in the presence of corrosive atmospheres, have protection from corrosion. Therefore, the employer must provide a canopy, hood or other suitable protection for detection equipment requiring protection from the weather. The OSHA standard also requires employers to locate or otherwise protect detection equipment in order to preserve it from mechanical or physical impact, which might render it inoperable.

Ultimately, the design and installation of fire detection systems for the purpose of employee alarm notification and evacuation must provide a warning for emergency action and safe escape of employees. In addition, the employer cannot delay alarm notification or actions initiated by fire detector actuation for more than 30 seconds, unless such a delay is necessary for the immediate safety of employees. When an employer deems such a delay necessary, the employer must provide a full explanation included as part of an emergency action plan that meets the requirements of Section 1910.38 of the CFR.

For a contractor involved in the installation and maintenance of fire alarm systems, the OSHA standards provide a unique marketing opportunity to industrial clients that allows you to help your clients meet their obligations to provide a safe workplace for their employees. You should also realize the importance of understanding the requirements of both NFPA 72 2010 and the OSHA regulation 29 CFR 1910 Subpart L to ensure your fire alarm system installation will comply with both documents.

MOORE, a licensed fire protection engineer, frequent speaker and an expert in the life safety field, is a past chair of the NFPA 72 Technical Correlating Committee. Moore is a principal with Hughes Associates Inc. at the Warwick, R.I., office. He can be reached at wmoore@haifire.com.

About the Author

Wayne D. Moore

Fire/Life Safety Columnist
Wayne D. Moore, a licensed fire protection engineer, frequent speaker and an expert in the life safety field, is a principal member and past chair of NFPA 72, Chapter 24. Moore is a vice president with JENSEN HUGHES at the Warwick, R.I., office. He c...

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