- Record Type:OSHA Instruction
- Current Directive Number:STD 01-09-002
- Old Directive Number:STD 1-9.2
- Title:29 CFR 1910.157(f)(2),(f)(2)(i) and (f)(4) Hydrostatic Testing of Dry Chemical Cartridge Portable Fire ...
- Information Date:
- Standard Number:
OSHA Instruction STD 1-9.2 August 5, 1981 Office of Compliance Programming
Subject: 29 CFR 1910.157(f)(2),(f)(2)(i) and (f)(4) Hydrostatic Testing of Dry Chemical Cartridge Portable Fire Extinguishers
A. Purpose. This instruction provides specified exceptions for fire extinguisher repairs and/or subsequent hydrostatic tests which do not meet the requirements of 29 CFR 1910.157(f)(2),(f)(2)(i) and (f) (4) and are performed under conditions imposed by the manufacturer.
B. Scope. This instruction applies OSHA-wide.
C. Action. Regional Administrators/Area Directors shall take action to ensure that 29 CFR 1910.157(f)(2),(f) (2)(i) and (f)(4) are enforced in accordance with E. of this instruction.
D. Federal Program Change. This instruction describes a Federal program change which affects State programs. Each Regional Administrator shall:
- 1. Ensure that this change is forwarded to each State designee.
- 2. Explain the technical content of the change to the State
designee as requested.
- 3. Ensure that State designees are asked to acknowledge receipt of
this Federal program change in writing, within 30 days of notification, to
the Regional Administrator. This acknowledgment should include a description
either of the State's plan to implement the change or of the reasons why the
change should not apply to that State.
- 4. Review policies, instructions and guidelines issued by the
State to determine that this change has been communicated to State program
personnel. Routine monitoring activities (accompanied inspections and case
file reviews) shall also be used to determine if this change has been
implemented in actual performance.
OSHA Instruction STD 1-9.2 August 5, 1981 Office of Compliance Programming
E. Guidelines. Repairs will be permitted on dry chemical, cartridge type extinguisher shells constructed of mild steel when such repairs are by silver brazing and are performed in conformance with the pertinent requirements of the extinguishers' manufacturer.
- 1. Repairs shall only be performed by trained persons deemed
competent and approved by the employer.
- 2. The employer shall have available and provide the Compliance
Officer the employer's written designation of the approved competent person
and the current manufacturer's instructions which provide for repairs, tests
and/or maintenance of any fire extinguishers covered by this
instruction.
- 3. After completion of allowable repairs, the unit shall be
hydrostatically tested in accordance with the manufacturers written test
instructions.
- 4. Allowable Repairs and Hydrostatic Test Requirements. The
following allowable repairs and test requirements are considered within the
scope of 29 CFR 1910.157 (f)(2),(f)(2)(i) and (f)(4):
- a. Hand Portable Mild Steel, Dry Chemical Cartridge Operated
Extinguishers. 1. Repairs shall be by means of silver brazing
only.
- 2. Silver brazing is restricted to extinguisher components
such as the carrying handle lug, nozzle holster nuts, hanger attachment,
visual seal attachment, etc., which are specifically within the
manufacturer's limitations.
- 3. Silver brazing shall not be allowed where the mild steel
shell is damaged as by tearing, etc., of the parent metal from the
shell.
OSHA Instruction STD 1-9.2 August 5, 1981 Office of Compliance Programming
- b. Wheeled Extinguishers.
- 1. Welding is restricted to such elements of the wheeled
conveyance as the handle, axle shroud, nitrogen cylinder stand, etc., which
are specifically within the manufacturer's limitations and do not affect the
safety factor.
- 2. Welding shall not be allowed where the mild steel shell is
damaged, as by the tearing, etc., of the parent metal from the
shell.
- 3. Hydrostatic testing as required in 29 CFR 1910.157 (f)(1),
(f)(2) and (f)(4) shall be conducted after allowable repairs are made
directly to the pressure vessel.
- NOTE: The manufacturer's instructions for allowable repairs
and hydrostatic testing are not exempted from other applicable OSHA standards
unless by a particular directive, variance or other official
notification.
F. Background. Presently, Subpart L, 29 CFR 1910.157(f) (2) (i), does not provide for exceptions when fire extinguishers have been repaired by soldering, welding, brazing or use of patching compounds.
- 1. The source for the development of the Subpart L standards
included NFPA 10-1970 and coordination with the NFPA during the recent
changes to NFPA 10. The provisions of NFPA 10-1978, 5-1.3 (examination of
cylinder condition) includes a note which states "For welding or brazing on
mild steel shells, consult the manufacturer of the extinguisher". These
recent changes reflect the intent of Appendix B to Subpart L which contains a
cross reference listing of current national consensus standards. These
standards contain information and guidelines which are considered acceptable
in complying with requirements in the specific sections of Subpart
L.
OSHA Instruction STD 1-9.2 August 5, 1981 Office of Compliance Programming
- 2. As indicated by the manufacturers instructions, specified
repairs can be made and subsequent hazards reduced by following the
procedures, limitations, standards and quality assurance which ensure
safety.
Thorne G. Auchter Assistant Secretary
DISTRIBUTION: National, Regional, and Area Offices All Compliance Officers State Designees NIOSH Regional Program Directors
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