It never ceases to amaze me how businesses will cut corners in fundamental safety protections. Recently, I came across fire extinguishers that were not “approved” by a Nationally Recognized Testing Laboratory (NRTL). This was discovered during a 5-year REVAL PHA after the facility suffered a failure of one of its extinguishers that caused damage to some PSM/RMP piping. The investigation failed to identify the failure in that the facility was buying substandard FEs to save $ and then failed to inspect and maintain these substandard FEs per 1910.157 and their state fire code, which requires NFPA 10 compliance.
Here is what OSHA says about fire extinguishers being “approved”…
(Emphasis by me)
1910.157(c)(2) Only APPROVED portable fire extinguishers shall be used to meet the requirements of this section.
OSHA also provides us with the following regarding an “approved” item:
1910.155(c)(3) Approved means acceptable to the Assistant Secretary under the following criteria:
1910.155(c)(3)(i) If it is accepted, or certified, or listed, or labeled or otherwise determined to be safe by a nationally recognized testing laboratory; or
1910.155(c)(3)(ii) With respect to an installation or equipment of a kind which no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency and found in compliance with the provisions of the applicable National Fire Protection Association Fire Code; or
1910.155(c)(3)(iii) With respect to custom-made equipment or related installations which are designed, fabricated for, and intended for use by its manufacturer on the basis of test data which the employer keeps and makes available for inspection to the Assistant Secretary.
1910.155(c)(3)(iv) For the purposes of paragraph (c)(3) of this section:
1910.155(c)(3)(iv)(A) Equipment is listed if it is of a kind mentioned in a list which is published by a nationally recognized testing laboratory which makes periodic inspections of the production of such equipment and which states that such equipment meets nationally recognized standards or has been tested and found safe for use in a specified manner;
1910.155(c)(3)(iv)(B) Equipment is labeled if there is attached to it a label, symbol, or other identifying mark of a nationally recognized testing laboratory which makes periodic inspections of the production of such equipment, and whose labeling indicates compliance with nationally recognized standards or tests to determine safe use in a specified manner;
1910.155(c)(3)(iv)(C) Equipment is accepted if it has been inspected and found by a nationally recognized testing laboratory to conform to specified plans or to procedures of applicable codes; and
1910.155(c)(3)(iv)(D) Equipment is certified if it has been tested and found by a nationally recognized testing laboratory to meet nationally recognized standards or to be safe for use in a specified manner or is of a kind whose production is periodically inspected by a nationally recognized testing laboratory, and if it bears a label, tag, or other record of certification.
1910.155(c)(3)(iv)(E) Refer to § 1910.7 for definition of nationally recognized testing laboratory.