Hazard communication labels for fire extinguishers

May 15, 1993

Mr. John L. Dowell III
BFPE International
[Recipient address omitted]
Dear Mr. Dowell:

Thank you for your letter of February 11, requesting interpretation of the labeling requirement specified in the Hazard Communication Standard (29 CFR 1919.1200(f)) as it pertains to fire extinguishers. Your three questions are answered below in the order they were presented in the letter.

Question No. 1: Does Subpart Z apply to fire extinguishers?

Response: Subpart Z of the Hazard Communication Standard does apply to fire extinguishers. In terms of labeling requirements under the Hazard Communication Standard (HCS), only those fire extinguishers that contain hazardous chemicals are required to be labeled. A compressed gas is defined as a physical hazard in the HCS. Therefore, those fire extinguishers containing compressed gas are required to be labeled under the HCS.

Question No. 2: If Subpart Z does not apply, is OSHA contemplating any regulations which will?

Response: Another OSHA standard 29 CFR 1910.157, Portable Fire Extinguishers, applies to the placement, use, maintenance, and testing of portable fire extinguishers provided for employee use. This standard specifies requirements such as, hydrostatic testing of fire extinguisher shells and training and education on use and hazards associated with incipient stage fire fighting. A copy of that standard is enclosed for your reference.

Question No. 3: Is OSHA in any way involved in the issue of the HMIS system as applied to fire extinguishers.

Response: As stated in the response to Question No. 2, OSHA has jurisdiction over fire extinguishers for employee use. Consequently, during compliance inspections fire extinguishers are evaluated against the applicable standards. In terms of HMIS labeling system, the agency does not require the HMIS for fire extinguishers or any other container. OSHA has stated in its directive of the Hazard Communication Standard (CPL 2-2.38 C) that:

"The standard's preamble recognizes the existence of numerous labeling systems that are currently in use in industry. Examples include the HMIS (Hazardous Materials Information System), NFPA (National Fire Protection Association) and ANSI (American National Standards Institute) systems. Some of these systems rely on a numerical and/or alphabetic codes to convey the hazards. Although these labeling systems may not convey the target organ effects, the intent of the standard is to permit the use of these systems for implant labeling as long as the written Hazard Communication Program adequately addresses the issue."

We hope this information will be of assistance to you, and if you have any additional questions please contact [the Office of Health Enforcement at (202) 693-2190].

Sincerely,
Roger A. Clark, Director
Directorate of Compliance Programs

Enclosure

[Requester letter reproduced on OSHA page; omitted here.]

[Corrected 12/6/2024]