In the event of an emergency, safety equipment must be accessible and operational, and signage must be visible in order to guide and provide information to employees.
A very common violation to the Occupational Safety and Health Administration (OSHA) standards is blocked access to emergency egress, fire extinguisher inspections incomplete, electrical panels blocked, exit signs missing, evacuation lighting inoperative, postings not in-place, and first-aid kits missing or inaccessible. Unfortunately, this is something I witness everyday while completing inspections.
In this article we will take a walk through a typical workplace, and discuss safety equipment requirements, signage, postings, and clearances. Having safety equipment, signage and informational postings is a requirement of OSHA as well as local building codes.
Emergency Action Plan
In previous articles, we have discussed Emergency Action Plans in detail. The Emergency Action Plan (EAP) must be posted in the workplace so that employees can utilize the plan during an emergency. As an employer, you must ensure that the EAP is easily accessible to your employees. The EAP is a detailed document that includes the following information:
• Evacuation procedures and exit routes
• First-aid kit locations
• Fire extinguisher locations
• Procedures that account for all employees after they evacuate
• Procedures for reporting emergencies
• Procedures for shutting down critical plant operations and equipment before evacuation
• Procedures for rescues and medical duties
• Designated employees to assist in evacuations
• Names or job titles of employees to contact for more information about the plan
Fire Extinguishers and Suppression Equipment
Fire extinguishers are one of the most common safety equipment components that are in violation of either OSHA or local fire codes.
Fire extinguishers are required in every workplace. The type of fire extinguisher, location, and number required, depends on the classes, and the amount of flammable materials, found in the workplace.
OSHA Standard 1910.157(d)(1)
Portable fire extinguishers shall be provided for employee use and selected and distributed based on the classes of anticipated workplace fires and on the size and degree of hazard which would affect their use.
Fire extinguishers must be mounted at a level between 3.5 to 5 feet from the ground. Fire extinguishers cannot be blocked by equipment, tools, hoses or electrical cords. (Figure #1) An obstructed fire extinguisher is sure to merit a citation. Although there are no real clearance measurements in the laws, generally it is recommended to maintain 24" in width and 36" in depth clearance in front of fire extinguishers.
Fire extinguishers must be inspected monthly by a qualified person and serviced annually by a certified fire extinguisher service. The monthly inspection must be documented, and the following be inspected:
• The extinguisher is visible, unobstructed and in its designated location.
• The locking pin is intact and the tamper seal is unbroken.
• The pressure gauge or indicator is in the charged / green operable range or position.
• The operational instructions on the nameplate are clean and legible
• Serviced within the last 12 months
• Initial and date the back of the tag. (See Figure #2).
For more information about fire extinguisher requirements, see the following link: https://www.osha.gov/SLTC/etools/evacuation/portable_ placement.html
Fire hose cabinets, sprinkler system controls, fire alarm manual pull handles and fire department connections (FDCs) require clearances for accessibility as well. Interior fire suppression equipment requires a minimum of 36" in most cases. All fire suppression equipment, and the pathway to the equipment must be unobstructed. Fire suppression equipment must either be in clear sight or marked to clearly see the equipment location.
In large structures, such as those commonly found in the wood products industry, equipment, machinery and walls, can obstruct the view of the equipment. Therefore, signage, and or color coding must be used to easily identify the location. When color coding is used, you will need to have the color coding identification in your policies and procedures, as well as incorporated into your employee safety training.
On the exterior of the building, FDCs must be accessible by the fire department. The equipment must be clearly visible and be labeled. Fire suppression equipment and FDCs are regulated by OSHA, the National Fire Protection Association and may also be subject to local fire codes. Therefore, I highly recommend that you invite the local fire department inspector to complete a walk-through of your workplace to ensure compliance. This would be a great training opportunity for your safety committee.
Emergency Exits and Evacuation
One of the most common violations I find in relationship to emergency exits is inoperative evacuation and exit lighting. Employers need to make the inspection of emergency egress and exits part of their quarterly safety inspections. Exit routes that are blocked, exit signs that are missing, and/or evacuation lighting that is inoperative, will earn you a citation from OSHA or the fire marshal. The back-up batteries in evacuation lighting often fail. Therefore, when the lights go out, there is no visible exit lighting, or evacuation lights. There is a test button either on the side or on the bottom of the fixture. (See Figure #3) Push the button to check if the back-up battery is operational, and if it doesn’t work, install a new battery as soon as possible.
The following is a list of OSHA requirements for emergency exits and egress that should be part of your quarterly and random inspections:
Requirements for Exits
• Exits must be separated from the workplace by fire-resistant materials – that is, a one-hour fire-resistance rating if the exit connects three or fewer stories, and a two-hour fire-resistance rating if the exit connects more than three floors.
• Exits can have only those openings necessary to allow access to the exit from occupied areas of the workplace or to the exit discharge. Openings must be protected by a self-closing, approved fire door that remains closed or automatically closes in an emergency.
• Keep the line-of-sight to exit signs clearly visible always.
• Install “EXIT” signs using plainly legible letters.
Safety Features for Exit Routes
• Keep exit routes free of explosives or highly flammable furnishings and other decorations.
• Arrange exit routes so employees will not have to travel toward a high-hazard area unless the path of travel is effectively shielded from the high-hazard area.
• Ensure that exit routes are free and unobstructed by materials, equipment, locked doors, or dead-end corridors.
• Provide lighting for exit routes adequate for employees with normal vision.
• Keep exit route doors free of decorations or signs that obscure their visibility of exit route doors.
• Post signs along the exit access indicating the direction of travel to the nearest exit and exit discharge if that direction is not immediately apparent.
• Mark doors or passages along an exit access that could be mistaken for an exit “Not an Exit” or with a sign identifying its use (such as “Closet”).
• Renew fire-retardant paints or solutions when needed.
• Maintain exit routes during construction, repairs or alterations.
First-Aid Kits
Inspection of first aid kits must be done during your quarterly safety inspection, as well as randomly to ensure that the kits are in-place and adequately supplied. It doesn’t take long for personnel to deplete a supply of bandages and other required items. Employers must have first aid supplies available to treat the injuries that would be reasonably expected in your workplace. The locations of first aid kits should be visible, and the kits must be easily available in close proximity to where their work tasks are being performed.
The supplies must be adequate for the number of employees that are employed in your workplace. The following is a list of the minimum first-aid supplies required at a workplace for up to 10 employees:
Count Supply item
6 3 x 3 Sterile pads
2 Absorbent pads
2 Rolls gauze
1 Box assorted
adhesive bandages
2 Triangle bandages
1 Space blanket
1 Pair scissors
1 Roll adhesive tape
1 Bottle individual eye wash solution
Personal protective equipment
2 Pair latex or Nitrile gloves
1 Pair safety glasses
1 Face mask
1 Biohazard bag or container
1 CPR barrier
Soap, cleaning solution, or towelette
Electrical Panels, Controls, and Power Disconnects
Electrical panels, controls and power disconnects must be easily accessible in the event of an emergency. Having a power disconnect blocked during an emergency shutdown could very well cost an employee’s life. Clearances and accessibility to electrical equipment must be inspected during your quarterly safety inspections and continuously monitored. Brooms, garbage containers and other tools seem to always find their way in front of electrical panels, controls, and power disconnects.
For voltage of 480 and below, clearances for electrical panels, controls, and power disconnects must be maintained at 36" in depth, 30" in width, and 6’ of overhead clearance to ensure access, safety and proper working clearances. Obviously, for large facilities, with expansive electrical equipment, the width must allow access in front of the entire length of the electrical equipment.
These measurements are simply for determining open space for emergency access, and not for determining electrical equipment placement. The National Electrical Code must be followed at all times.
Ensuring accessibility to emergency equipment, fire suppression equipment, emergency exits, electrical controls and first aid supplies can be the difference between life and death during an emergency situation. Information and signage must be posted to guide employees during emergency situations. Maintaining safety and emergency equipment, and ensuring proper clearances and access requires continuous monitoring. Don’t assume that because it was okay a few months ago that everything is fine today.
Editor’s Note: Jary Winstead is a safety consultant, author and trainer who serves a variety of industries including the forest products sector. He owns Work Safety Services LLC and can be reached at SAFEJARY@gmail.com.
