Have you ever seen a fire extinguisher with a HAZCOM label (e.g., NFPA 704 or HMIS) and thought to yourself…that is overkill?
Well, actually, it is not overkill, and it may be a requirement for the facility under the HAZCOM standard when the extinguisher contains a hazardous chemical. OSHA defines compressed gas as a physical hazard, and therefore, most, if not all, of your fire extinguishers, technically need to be labeled under your HAZCOM program.
Are you telling me I have to go out and put an HMIS or NFPA Diamond on ALL my fire extinguishers? It depends. If your FE’s are already labeled by the manufacturer, as most are, then the answer is NO! However, we came across a large chemical complex that did their annual maintenance and refills in-house. They had their certification from the state fire marshall and everything. Because they were doing it in-house, they had gotten a bit lax and were not ensuring the original manufacturer’s label was intact. Keep in mind that extinguishers have a very long service life, and the original labels wear off, especially in harsh environments.
In 1993, OSHA posted this LOI to clarify the labeling of extinguishers.
Question No. 1: Does Subpart Z apply to fire extinguishers?
Response: Subpart Z of the Hazard Communication Standard does apply to fire extinguishers. In terms of labeling requirements under the Hazard Communication Standard (HCS), only those fire extinguishers that contain hazardous chemicals are required to be labeled. A compressed gas is defined as a physical hazard in the HCS. Therefore, those fire extinguishers containing compressed gas are required to be labeled under the HCS.
Question No. 2: If Subpart Z does not apply, is OSHA contemplating any regulations which will?
Response: Another OSHA standard 29 CFR 1910.157, Portable Fire Extinguishers, applies to the placement, use, maintenance, and testing of portable fire extinguishers provided for employee use. This standard specifies requirements such as, hydrostatic testing of fire extinguisher shells and training and education on use and hazards associated with incipient stage fire fighting. A copy of that standard is enclosed for your reference.
Question No. 3: Is OSHA in any way involved in the issue of the HMIS system as applied to fire extinguishers.
Response: As stated in the response to Question No. 2, OSHA has jurisdiction over fire extinguishers for employee use. Consequently, during compliance inspections fire extinguishers are evaluated against the applicable standards. In terms of HMIS labeling system, the agency does not require the HMIS for fire extinguishers or any other container. OSHA has stated in its directive of the Hazard Communication Standard (CPL 2-2.38 C) that:
“The standard’s preamble recognizes the existence of numerous labeling systems that are currently in use in industry. Examples include the HMIS (Hazardous Materials Information System), NFPA (National Fire Protection Association) and ANSI (American National Standards Institute) systems. Some of these systems rely on a numerical and/or alphabetic codes to convey the hazards. Although these labeling systems may not convey the target organ effects, the intent of the standard is to permit the use of these systems for implant labeling as long as the written Hazard Communication Program adequately addresses the issue.”