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Subject: Re: [DCHAS-L] Fire extinguisher use in chem labs by instructors
Date: Thursday, December 3, 2015 10:28:32 PM
Author: "Clark, Eric J." <clarkej**At_Symbol_Here**LATTC.EDU> 		Next by Date:
Subject: Re: [DCHAS-L] Fire extinguisher use in chem labs by instructors
Date: Fri, 4 Dec 2015 05:46:16 +0000
Author: Michael D Ahler

From: ILPI Support <info**At_Symbol_Here**ilpi.com>
Subject: Re: [DCHAS-L] Fire extinguisher use in chem labs by instructors
Date: Thu, 3 Dec 2015 22:55:06 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 891834E3-7FAF-49F7-BBDC-DB362393E904**At_Symbol_Here**ilpi.com
In-Reply-To <58C74A3BBE6D644C8538C5848AC53025D51AC22A**At_Symbol_Here**EROS.westerntc.edu>


Probably the most directly pertinent OSHA reg is 29 CFR 1910.156 - Fire brigades.  See https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9811&p_text_version=FALSE

The fire extinguishers ARE required to be present under every fire code.   The employer can set a policy of whether they are for employee use.  For example, one can imagine a workplace so potentially hazardous that it would be imprudent to try and fight the fire with an extinguisher, so the employer will require an immediate evacuation.  Or maybe that only certainly technically qualified employees have the training and skill to use the extinguishers (example: a teaching lab).  Paragraphs a and b spell it out pretty clearly.

1910.157(a)
Scope and application.
 The requirements of this section apply to the placement, use, maintenance, and testing of portable fire extinguishers provided for the use of employees. Paragraph (d) of this section does not apply to extinguishers provided for employee use on the outside of workplace buildings or structures. Where extinguishers are provided but are not intended for employee use and the employer has an emergency action plan and a fire prevention plan that meet the requirements of 29 CFR 1910.38 and 29 CFR 1910.39 respectively, then only the requirements of paragraphs (e) and (f) of this section apply.
1910.157(b)
Exemptions.
1910.157(b)(1)
Where the employer has established and implemented a written fire safety policy which requires the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal and which includes an emergency action plan and a fire prevention plan which meet the requirements of 29 CFR 1910.38 and 29 CFR 1910.39 respectively, and when extinguishers are not available in the workplace, the employer is exempt from all requirements of this section unless a specific standard in part 1910 requires that a portable fire extinguisher be provided.
..1910.157(b)(2)

1910.157(b)(2)
Where the employer has an emergency action plan meeting the requirements of 1910.38 which designates certain employees to be the only employees authorized to use the available portable fire extinguishers, and which requires all other employees in the fire area to immediately evacuate the affected work area upon the sounding of the fire alarm, the employer is exempt from the 
Now the key point to answering your question.  It the employer decides that employees are permitted to use the extinguishers, then the training and education requirements of paragraph (g) kick in and so yes, they must be trained:

1910.157(g)(1)
Where the employer has provided portable fire extinguishers for employee 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 fire fighting.
1910.157(g)(2)
The employer shall provide the education required in paragraph (g)(1) of this section upon initial employment and at least annually thereafter.
1910.157(g)(3)
The employer shall provide employees who have been designated to use fire fighting equipment as part of an emergency action plan with training in the use of the appropriate equipment.
1910.157(g)(4)
The employer shall provide the training required in paragraph (g)(3) of this section upon initial assignment to the designated group of employees and at least annually thereafter. 
A formal decision on restricting employee use would fall under 29 CFR 1910.38, Emergency Action Plans, https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9726&p_table=STANDARDS  For an organization of 10 or more employees, a written plan is required and it will spell out the procedures that will be followed as well as exit, egress etc. etc.  Training for orderly and safe evacuation is part of that plan.

That is dovetailed with 29 CFR 1910.39, Fire Prevention Plans, https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=12887   This is short and fairly self-explanatory.   The plan must include  "the type of fire protection equipment necessary to control each major hazard"   What I find most compelling here is paragraph d:

1910.39(d)
Employee information.
 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.

Read those last four words and focus on them.  First, there's the legal requirement you asked about.  Second, and more importantly, I would argue under paragraph d) that there are clearly foreseeable instances in any laboratory where one might need to use an extinguisher for self-protection or to make an egress. For example, if an occupant is on fire an there is no shower immediately available.  Or a fire lies between a worker and an exit and the only way to escape would be to operate the extinguisher.  Or an student is lying unconscious on the floor and you need to fight a fire to get to them and pull them out before they burn to death.   I've encountered situations very near to those on more than one occasion, alas.

Drop me into your committee meeting and this is the stance I would take:

1. Not providing extinguishers in laboratories (or anywhere else for that matter) is an absurd notion, inherently dangerous, undoubtedly invites tremendous legal liability and almost certainly violates fire codes.  I would refuse to work in a lab not equipped with extinguishers.  Scratch that one.

2.. All persons with a formal laboratory supervisory role must be trained in extinguisher use.  It is their job to ensure the welfare and safety of those under their care.  That means TA's and, in turn, the lab instructor or PI.  Key here, however, is that nothing ever obligates an employee (or anyone else) to fight a fire or put themselves in peril.  But they MUST be trained to make that fight or flight decision - I have this summed up here: http://www.ilpi.com/safety/extinguishers.html#Using

3. Students working in research labs should receive training because there will be instances where they may find themselves in a peril situation.  Students in teaching labs where trained staff are always present do not require training because the hazards and risks are lower and they will be told to evacuate - in fact you will tell them not to attempt to fight a fire because they are not qualified.  For example, you don't want a first semester organic student trying to take charge if there's a fire in a teaching lab - imagine the conflict with an instructor or the issue of picking the wrong type of extinguisher.

4. Outside the realm of laboratories  and special hazard situations, we're in an office worker, janitorial etc. type of low-hazard, low-risk environment.  I would not require any training, but I would certainly offer it to anyone who wanted it.

Finally, have a prepare for the worst mindset.  And that means focus on over-preparing and overtraining.  In the unfortunate world we live in, keep in mind that a dry chemical powder extinguisher to the face would likely disable an active shooter who would not be expecting to have one discharged into his face at close range after breaking down the door to an office or classroom.   Knowing how to use an extinguisher would be key.

Good luck!

Rob Toreki

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On Dec 3, 2015, at 7:53 PM, "Osterby, Meg" <OsterbyM**At_Symbol_Here**WESTERNTC.EDU> wrote:

 
Hello all,
 
I am part of our college's safety committee and there has been a discussion ongoing in the committee about OSHA's requirements for availability and use of fire extinguishers in the workplace.  Some of the information we have found suggests that the option to not provide extinguishers, or train anyone to use them, is okay by OSHA.  However, in LaCrosse, the local fire codes require extinguishers to be present.  So the question is, if they are present, does it behoove us to train lab instructors (shop instructors, cooking instructors, etc.) in their use, and if we do, are those persons with the training required to use the extinguisher, if appropriate?  And, since we have to have the extinguishers, but one of the OSHA options we've been told is to train no-one and forbid their use, would that apply to chem teaching labs?  And if it does, why are they there?  I understand that as a chemical professional it is my duty to be knowledgeable and trained in the appropriate safety procedures for any chemical we use, but is that a legal requirement, and if it is, does it need to be in the person's job description?  And if so, how would that relate to fire extinguisher use?  If the college requires me to use one, does it need to put that in my job description?  The OSHA rule seems to make it clear that if they require that, they have to provide regular training, but beyond that, I'm lost.
 
Does anyone know how this works, and what the law requires our college to do?  We have been looking at a PP document we found on-line, which I've summarized the pertinent info from into a Word document, that I'd be happy to forward off the list-serve.  Frankly we are really confused.  Any help would be appreciated.
 
Thanks much,
Meg
 
Meg Osterby
Lead Chemistry Instructor
Western Technical College
400 7th St. N.
LaCrosse, WI 54601
osterbym**At_Symbol_Here**westerntc.edu
608-789-4714
 
"It's  better to be careful 100 times, than to be killed once." 
                                                    Mark Twain
 

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