Guide to Creating a Fire Prevention Plan [OSHA 1910.39]

Contents

What is a Fire Prevention Plan?
Core Requirements of OSHA 1910.39 Standard
Additional Requirements to Include in Your OSHA Fire Prevention Plan
1. Unique Hazards:
2. Employee Training:
Difference Between a Fire Prevention Plan & An Emergency Action Plan
Ensure OSHA FPP Standard Compliance with Creative Safety Supply

Fire prevention in the workplace is one of the most important areas of focus for OSHA. With that goal in mind, OSHA has a series of requirements focused on fire prevention. These standards help show employers how they can reduce the risk of fire and how they can ensure employees will be as safe as possible should a fire break out. The regulations for compliance are found under section 1910.39 of OSHA.

When working to be compliant with these regulations, employers must start by creating a fire prevention plan. Here, we cover the mandatory requirements of a fire prevention plan set by OSHA 1910.39 and how to enforce them within your working space.

What is a Fire Prevention Plan?

A fire prevention plan is a written document outlined by OSHA-provided requirements that serves as a baseline for preventing fires from occurring in the first place. It is recommended that employers have a written fire prevention plan in the following circumstances:

If your organization or working space has 10 or more employees present, each of whom has received training to fight the incipient stages of a fire (the initial stages before it spreads).
If the nature of the work is deemed as high-risk (construction) or if your employees regularly engage with hazardous materials, like Ethylene Oxide, Methylenedianiline, or 1, 3-Butadiene.
If fire-extinguishing tools or alarms are present to minimize the spread of a fire.

To design an OSHA-compliant fire prevention plan, incorporating its requirements is a critical step.

Core Requirements of OSHA 1910.39 Standard

OSHA offers basic, non-negotiable requirements that should be the baseline of every fire prevention plan.

Written Fire Prevention Plan

The fire prevention plan must be kept in writing, should be present at the workplace, and be available for review by all employees at any time. Employers with 10 or fewer employees reserve the right to orally communicate the plan.

Many employers have a physical copy of their fire prevention plan in their office and also make it available digitally, either on their corporate website or on their internal intranet. As a written plan, the fire prevention plan must use language that the average person can easily understand.

Includes Major Fire Hazards

All of the major fire hazards that exist in the facility must be identified. Along with each of the hazards, there must be instructions for how these hazards should be handled and stored. Detailed information, such as how the hazards could ignite and what fire protection is needed when working with them, should be included as well.

The following are some examples of ignition sources that should be included:

Heat Sources: Any sources of heat, such as space heaters, furnace vents, ovens, combustion engines, and machines that produce heat.

Open Flames: Welding torches, gas furnaces, gas ovens, lighters (smoking areas).

Sparks: Metal saws, wood saws that cut materials that potentially contain nails or screws, and metal drills.

Chemical Ignition: Any chemicals that can combust under normal conditions.

Avoiding Flammable & Combustible Waste Buildup

A set of procedures should exist that identifies the steps to take to ensure there is not an unsafe buildup of flammable and/or combustible waste materials. Included in these procedures should be how and when these waste materials will be safely removed from the area. To do so, employees must understand the classification of combustible materials:

Class A Materials: Class A includes materials that won't ignite on their own, but when exposed to a sufficient heat source, will continue burning. Examples include paper, cloth, and wood.

Class B Materials: All gases, liquids, greases, and other similar materials that can burn when exposed to flame, heat, or other ignition sources.

Class C Materials: Class C materials are any equipment or materials that use electricity. The electrical current can cause a fire very quickly should there be damage or other malfunction. Arc flashes, for example, are a serious risk of class C materials.

Class D Materials: Any material that is volatile and can ignite quickly falls under this class. This includes sodium, potassium, zirconium, and magnesium.

Maintain & Safeguard Information:

All procedures regarding the maintenance and safeguards used on any heat-producing equipment to prevent accidental ignition of combustible materials need to be clearly identified in the fire prevention plan.

Responsible Maintenance Parties:

The names and/or job titles of all employees responsible for the equipment used to prevent or control the ignition of fires. This includes maintenance personnel who work on heat-producing machines.

Parties Responsible for Fuel Source Hazards:

The names and/or job titles of all employees responsible for controlling any fuel sources that could be potential fire hazards.

Hazard Awareness For Each Employee:

Employers must notify each employee of all the potential hazards they may be exposed to and review each aspect of the fire prevention plan with each employee for self-protection. Ensuring each employee understands the unique prerequisites of fire prevention can establish a considerable degree of fire safety in the workplace.

Additional Requirements to Include in Your OSHA Fire Prevention Plan

While OSHA does provide a generic outline for a fire prevention plan, employers must analyze and customize their plan to reflect the exact chemicals, processes, and equipment used in their workplace. Consider adding the following specifications:

Unique Hazards:

If your facility has unique risks such as confined spaces, hidden environmental dangers, or a server room suppression system, your fire prevention plan must reflect such specifications, ensuring each employee is aware of potential hazards before employment. This helps avoid confusion and eliminates the risk of life-threatening injuries or death.

Employee Training:

The employees working in the facility who have any responsibility for either maintaining heat sources or keeping fuel sources safe need to have the proper training so they know how to keep their areas safe. Having a strong understanding of things like how much heat a given machine should be producing, how to measure this heat, and ignition points for fuel sources is critical to avoiding fires.

While employees with direct responsibilities for fire prevention should undergo extensive training, all employees should be educated on general fire prevention strategies. OSHA doesn't have specific requirements in place since training needs vary greatly from facility to facility. Some standard training that employees should have, however, includes:

Emergency Exit: Knowing where to go should a fire occur.
Fire Drills: Surprise fire drills should be a part of all employee training.
Assembly and Accountability: Knowing exactly where to report outside the building so supervisors can quickly account for everyone.
Fire Extinguishers: Employees should all be trained on how to properly use fire extinguishers. This includes what type of fire extinguisher is needed based on the source of the fire.

The employer can identify other training needs based on the risks associated with the facility itself.

Difference Between a Fire Prevention Plan & An Emergency Action Plan

Fire prevention plans and emergency action plans are workplace documents designed to enhance workplace safety. OSHA provides minimum guidelines for each plan, signifying their importance. Let's take a look at how they differ from each other:

A fire prevention plan focuses on proactive measures to avert potential fire hazards and stop small fires from spreading. Proactive in nature, it aims to eliminate fire hazards, control ignition sources, and prevent fires from occurring in the first place. Key requirements provided by OSHA 1910.39 include hazard identification, emergency and exit routes, and fire suppression equipment.

An emergency action plan details the exact procedures for safely reacting, responding, and evacuating during an active emergency. This plan aims to organize and facilitate safe employee actions during emergencies, thereby minimizing injuries, structural damage, and confusion. OSHA 1910.38 requires protocols for reporting, employee training, critical operations, and more.

While the two plans serve two distinct purposes, both complement each other and are often required to ensure compliance with OSHA’s 1910 Subpart E App - Exit Routes, Emergency Action Plans, and Fire Prevention Plans.

Ensure OSHA FPP Standard Compliance with Creative Safety Supply

Ensuring compliance with OSHA's Fire Prevention Plan (FPP) standard not only requires maintaining a written document but also requires clear fire hazard communication tools like safety signs and an understanding of all relevant fire safety standards. These visual aids and regulatory frameworks are critical for identifying hazards and managing them. We at Creative Safety Supply provide the critical visual communication tools and an in-depth fire safety guide to help you map and control fire hazards before they threaten your workplace.

OSHA 1910.39 Fire Prevention