Standard Interpretations - Table of Contents
• Standard Number: 1910.155; 1910.155)(c)(27) ; 1910.157; 1910.157(d)(3)1910.157(e) ; 1910.157(e)(2)

This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within the original correspondence.

November 29, 2006

Mr. Daniel J. Roberts
Manager, Industrial Safety
Exelon Nuclear, Exelon Corporation
4300 Winfield Road
Warrenville, IL 60555

Dear Mr. Roberts:

Thank you for your letter of June 23, 2006, in which you inquire whether OSHA would agree to reduce the prescribed frequency of inspections for portable fire extinguishers under 29 CFR 1910.157(e)(2) from monthly to quarterly. You asked if a reduction in frequency would be acceptable "provided it was made in accordance with a 'performance based' methodology that provided reasonable assurance that the extinguishers are maintained fully charged and operable, and probable continuance of that condition until the inspection."

In §1910.157, OSHA's standard for portable fire extinguishers used in general industry, paragraph (e) addresses inspection, maintenance, and testing. Paragraph (e)(2) of §1910.157 requires that "[p]ortable extinguishers or hose used in lieu thereof under paragraph (d)(3) of this section shall be visually inspected monthly." In addition, the burden posed by the inspection contemplated by the standard (as defined in §1910.155(c)(27)) is modest: "a visual check of fire protection systems and equipment to ensure that they are