Fire extinguisher inspection requirements: monthly, annual and hydrostatic

OSHA fire extinguisher requirements at a glance

OSHA requires a monthly visual inspection, an annual maintenance check, six-yearly maintenance for some dry chemical units, and periodic hydrostatic testing. The rule is 29 CFR 1910.157, and it starts by putting all of it on the employer: "The employer shall be responsible for the inspection, maintenance and testing of all portable fire extinguishers in the workplace" ((e)(1)).

While an extinguisher is away for maintenance or recharging, the employer must provide "alternate equivalent protection" ((e)(5)).

The monthly visual inspection

Every portable extinguisher must be "visually inspected monthly" ((e)(2)). OSHA doesn't list what the monthly inspection covers, but the rest of the standard tells you what it's protecting: extinguishers must be mounted, located and identified "so that they are readily accessible to employees without subjecting the employees to possible injury" ((c)(1)). A typical monthly check:

• in its assigned place, mounted, visible and not blocked;
• pressure gauge reading in the operable range;
• pin and tamper seal in place;
• no dents, corrosion, leaks or damage to the cylinder;
• hose and nozzle intact and clear;
• operating instructions on the label legible;
• the inspection tag or record dated and initialed.

Our free fire extinguisher inspection checklist has these as questions, ready to print or put on a QR code.

The annual maintenance check

Once a year, every portable extinguisher gets a maintenance check. Paragraph (e)(3): "The employer shall assure that portable fire extinguishers are subjected to an annual maintenance check. Stored pressure extinguishers do not require an internal examination. The employer shall record the annual maintenance date and retain this record for one year after the last entry or the life of the shell, whichever is less. The record shall be available to the Assistant Secretary upon request."

That's the one extinguisher record OSHA requires as routine. If a fire protection service company does the annual maintenance, it leaves a dated tag or report; keep it where you can find it.

Six-year maintenance and hydrostatic testing

Some extinguishers need more than an annual check. Under (e)(4), "stored pressure dry chemical extinguishers that require a 12-year hydrostatic test are emptied and subjected to applicable maintenance procedures every 6 years." Disposable, non-refillable dry chemical units are exempt, and the six-year clock restarts whenever the unit is recharged or hydrostatically tested.

Hydrostatic testing pressure-tests the shell, and the interval depends on the type, under Table L-1 of 1910.157:

The rule also requires a hydrostatic test "whenever they show new evidence of corrosion or mechanical injury" ((f)(4)). Testing must be done "by trained persons with suitable testing equipment and facilities" ((f)(1)), and shells that fail "shall be removed from service and from the workplace" ((f)(14)). The employer keeps a certification record with the test date, the tester's signature and the extinguisher's serial number or other identifier, until the next test or until the extinguisher leaves service ((f)(16)).

Who can inspect fire extinguishers

OSHA doesn't say who does the monthly or annual checks; it makes the employer responsible for both. In practice:

• Monthly: any employee who has been shown what to look for. It takes a minute or two per extinguisher.
• Annual maintenance: usually a fire protection service company. Your local fire code, often based on NFPA 10, the consensus standard for portable extinguishers, may require a certified or licensed technician.
• Hydrostatic testing: "trained persons with suitable testing equipment and facilities", which in practice means a service company.

Employees who may use extinguishers need education on their use and the hazards of fighting an incipient fire, on hire and at least once a year after that ((g)(1) and (g)(2)).

When OSHA's extinguisher rules apply

Section 1910.157 applies to portable extinguishers "provided for the use of employees" ((a)). Two cases change that:

• If extinguishers are provided but aren't intended for employee use, and you have an emergency action plan and a fire prevention plan meeting 1910.38 and 1910.39, only the inspection, maintenance and testing paragraphs, (e) and (f), apply ((a)). The monthly and annual checks still do.
• If you have a written policy of immediate, total evacuation on a fire alarm, with compliant emergency action and fire prevention plans, and no extinguishers in the workplace, you're exempt from the whole section unless another standard requires an extinguisher ((b)(1)).

This guide covers general industry; construction sites fall under the fire protection rules in Part 1926 instead.

Tags, NFPA 10 and digital records

The paper tag hanging from an extinguisher is a common way to show the monthly check, but OSHA's text doesn't require it: OSHA requires a record of the annual maintenance date. NFPA 10 has its own inspection, maintenance and record-keeping requirements, and your fire marshal may expect to see them followed, so check your local code.

A digital record does the same job as the tag, and more: who checked which extinguisher, when, and what they found, searchable months later. Keep the service company's annual tag on the extinguisher either way.

Monthly extinguisher checks on a phone

With CheckBadges, a QR sticker on each extinguisher, or one per floor or area with a question for each unit, opens its monthly checklist on the inspector's own phone, with no app or login. Each check is filed with their name and the time. A problem such as a low gauge or a broken seal needs a note, can carry a photo, and emails you straight away. Each sticker counts as one machine on your plan, so a building with many extinguishers is usually cheaper with one sticker per area. It's free for 3 stickers.