Are You Required to Retire Your Older Portable Fire Estinguishers?
Recently we've received a number of questions about NFPA 10 - Maintenance code for portable fire extinguishers. In an effort to unify NFPA code with Underwriters Laboratory (UL), the latest version of NFPA 10 requires that PFE's manufactured before October 1984 shall be removed from service at the next 6 year maintenance interval or 12 year hydrotest, whichever comes first.
Does this mean that you need to retire and replace all of your older portable fire extinguishers? Well, OSHA does not reference UL 299 or UL711 and that is the crux of NFPA’s reasoning behind the retirement of the older extinguishers.
In their regs OSHA says:
1910.157(e)(4) The employer shall assure that stored pressure dry chemical extinguishers that require a 12-year hydrostatic test are emptied and subjected to applicable maintenance procedures every 6 years. Dry chemical extinguishers having non-refillable disposable containers are exempt from this requirement. When recharging or hydrostatic testing is performed, the 6-year requirement begins from that date.
In 29 CFR 1910 Subpart L - National Consensus Standards - 1910 Subpart L App B
OSHA references GUIDELINES where employers can go to receive GUIDANCE in complying with the REGULATIONS. These guidelines are non-mandatory as identified in OSHA’s comments:
NOTE: The following appendix to Subpart L serve as nonmandatory guidelines to assist employers in complying with the appropriate requirements of Subpart L.
ANSI/NFPA No. 10, Portable Fire Extinguishers.
So right now, OSHA does not require you to retire your older extinguishers, however OSHA does require that the PFE’s be maintained and in working order and depending on the age of the PFE’s it might be good to retire it, but it’s not required across the board.
The next question is "Does your local building code or municipality (or other authority having jurisdiction) recognize and enforce NFPA 10? If the answer is yes, you'll need to follow the NFPA standards.
One last thought: Does your company own the portable fire extinguishers and use simply use a third party vendor to maintain them? Of course in this scenario your company would be responsible to retire and replace them (at your cost) if local code has adopted NFPA 10.
More typically the vendor owns the extinguishers and you would lease them. This of course would make the retirement and replacement of the PFE’s the responsibility of the vendor.
Does this mean that you need to retire and replace all of your older portable fire extinguishers? Well, OSHA does not reference UL 299 or UL711 and that is the crux of NFPA’s reasoning behind the retirement of the older extinguishers.
In their regs OSHA says:
1910.157(e)(4) The employer shall assure that stored pressure dry chemical extinguishers that require a 12-year hydrostatic test are emptied and subjected to applicable maintenance procedures every 6 years. Dry chemical extinguishers having non-refillable disposable containers are exempt from this requirement. When recharging or hydrostatic testing is performed, the 6-year requirement begins from that date.
In 29 CFR 1910 Subpart L - National Consensus Standards - 1910 Subpart L App B
OSHA references GUIDELINES where employers can go to receive GUIDANCE in complying with the REGULATIONS. These guidelines are non-mandatory as identified in OSHA’s comments:
NOTE: The following appendix to Subpart L serve as nonmandatory guidelines to assist employers in complying with the appropriate requirements of Subpart L.
ANSI/NFPA No. 10, Portable Fire Extinguishers.
So right now, OSHA does not require you to retire your older extinguishers, however OSHA does require that the PFE’s be maintained and in working order and depending on the age of the PFE’s it might be good to retire it, but it’s not required across the board.
The next question is "Does your local building code or municipality (or other authority having jurisdiction) recognize and enforce NFPA 10? If the answer is yes, you'll need to follow the NFPA standards.
One last thought: Does your company own the portable fire extinguishers and use simply use a third party vendor to maintain them? Of course in this scenario your company would be responsible to retire and replace them (at your cost) if local code has adopted NFPA 10.
More typically the vendor owns the extinguishers and you would lease them. This of course would make the retirement and replacement of the PFE’s the responsibility of the vendor.
Labels: Fire Code, NFPA, OSHA, OSHA Compliance, Portable Fire Extinguisher
posted by David A. Casavant @ 12:29 AM
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