Sprinkler-system maintenance citation policy

OSHA archive notice: "This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only."

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.