- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
January 14, 1999
| MEMORANDUM FOR: | RUTH MCCULLY Regional Administrator |
| FROM: | Richard E. Fairfax Director Directorate of Compliance Programs |
| SUBJECT: | Citation Policy Regarding Automatic Sprinkler Systems. |
This is in response to your memorandum of October 15, regarding OSHA's citation policy for maintaining sprinkler systems. Specifically, you requested a clarification as to whether it would be an employer's obligation to maintain an automatic sprinkler system, in situations where the sprinkler system at issue is not actually required by a particular OSHA standard.
Please note that the lack of maintenance on a sprinkler system which is not required by an OSHA standard would not constitute a violation, except if the system poses a new hazard.
With regard to your specific example regarding §1910.252(a)(2)(vi)(B), this standard prohibits the performance of welding and cutting in an area equipped with an inoperable sprinkler system. Therefore, the standard implies that welding and cutting should be performed in areas with properly functioning sprinkler systems. The lack of an operable sprinkler system, in this case, would constitute a violation. On the other hand, if an operation did not require the presence of a properly functioning sprinkler system according to a particular standard, the existence of an impaired sprinkler system would not constitute a violation.
Thank you for your inquiry. If you need further assistance, please contact Alcmene Haloftis of my staff at 202-693-1850.