Most work fires are preventable. This Program sets out a strategy you can implement over a 30-day period (and beyond) to prevent work fires, fatalities, injuries and costly OSHA citations. What This Gameplan Does & Doesn’t Cover There are two fundamental elements of workplace fire safety: preventing fires and being prepared to respond to them in case they break out. The focus of this Gameplan is Prevention. Fire Evacuation and Response is covered under a separate Gameplan. There is also a separate Gameplan covering use, maintenance and inspection of Portable Fire Extinguishers. Step One: Perform Hazard Assessment (Day 1-5) The first step in preventing workplace fires is to do an assessment to identify and evaluate fire hazards in your workplace. Methods to use include: Identifying all flammable, combustible or explosive substances in the workplace; Evaluating how these various materials are used, handled and stored; Identifying all ignition sources, i.e., things that can cause flammable, combustible or explosive substances to ignite; Identifying all work operations involving fire hazards, such as welding and hot work; Observing workers performing these operations; Identifying other fire hazards; Evaluating the fire safety aspects of the building’s construction, e.g., ease of ingress and egress, use of fire-resistant materials, occupancy levels, installation of sprinklers, etc.; Evaluating current fire alarm and notification equipment and methods; Evaluating whether adequate fire extinguishers and firefighting equipment are on hand; Evaluating the effectiveness of current fire safety and response procedures; Interviewing workers and supervisors about fire hazards; Reviewing written records of worker complaints or safety committee recommendations involving fire safety. Implementation Strategy: In carrying out your hazard assessment, be on the lookout for the risk factors that can cause fires, including: Unsafe storage, use and handling of flammable, combustible or explosive substances; Unsafe conducting of hot work and other hazardous operations; Overloading of electrical outlets; Frayed or damaged wiring or electrical equipment; Proximity of hazardous substances to heat or ignition sources; Accumulations of combustible dusts, fumes or vapors in the air; Accumulations of dangerous debris such as oily rags; Failure of workers to follow good housekeeping practices; Lack of fire safety awareness on the part of workers. 1 Tools & Implementation * See “Legal Briefing: OSHA Fire Prevention Rules” to find out what fire prevention measures OSHA requires * See “How to Do a Fire Safety Hazard Assessment” for step-by-step hazard assessment instructions; * Use the “Fire Safety Assessment” form to carry out your hazard assessment; * Use the “Portable Fire Extinguisher Inspection Checklist” to evaluate fire extinguishers during your assessment. Step Two: Select Safety Controls (Day 6-15) The next step is to take appropriate measures to manage the fire hazards you identify in your assessment. General Strategy: Implement a Fire Prevention Plan OSHA (Sec. 1910.39) requires you to create and implement a written Fire Prevention Plan (FPP) if you use, store, handle, manufacture or process hazardous substances subject to their own OSHA substancespecific standards, including: Ethylene Oxide; Methylenedianiline; or 1,3 Butadiene. Even if you’re not subject to one of these standards, it’s advisable to have an FPP that’s available for workers to review and sets out the measures you use to prevent fires at your workplace. Such measures should include: First Choice: Elimination: If it’s reasonably practicable, totally eliminate the hazard, e.g., by eliminating hazardous substances or operations that pose fire hazards. Second Choice: Management & Control: Total elimination of fire hazards won’t be an achievable or realistic option for most employers. If elimination isn’t reasonably practicable and you have to accept the fact that workers will be exposed to fire hazards, you must take measures to control or minimize those hazards. Level 1: Engineering Controls: Start with engineering controls or mechanical equipment and systems that do something to physically minimize hazards at a workplace. Engineering controls for fire include: Installation of HVAC and ventilation systems in buildings and chemical storage areas; Building design features that reduce the risk of fires, e.g., use of fireproof materials; Insulation of electrical equipment and other potential ignition sources; Installation of fire alarms, smoke detectors and other detection or warning devices; Installation of sprinklers and other fire suppression systems; Furnishing portable fire extinguishers and other firefighting equipment (Note that use, inspection and maintenance of portable fire extinguishers is covered in a separate Gameplan). 2 Note: Your engineering controls must meet the safety standards set out in not just OSHA but local building and fire codes. Level 2: Work/Administrative Controls: The next layer of hazard control is use of “work” or “administrative controls affecting how different work operations are carried out. At a minimum, you must develop and implement safe work procedures for: Proper handling, use and storage of hazardous materials; Controlling ignition sources; Carrying out welding, hot work and other operations involving high risk of fire and explosion; Controlling accumulations of flammable and combustible waste materials; Regular fire inspections; Regular maintenance of safeguards installed on heat-producing equipment to prevent accidental ignitions; Implementation of an emergency evacuation and action plan for responding to fires and other workplace emergencies (Note that fire evacuation and response is covered in a separate Gameplan). You should also have policies requiring workers to follow good housekeeping practices and use their tools and equipment safely. Level 3: PPE & Protective Clothing: Workers exposed to risk of fire and explosion must be equipped with and use appropriate PPE and protective clothing. Workers who perform interior structural firefighting must be furnished, at no cost to themselves: Foot and leg protection; Protective footwear; Body protection; Gloves or glove systems; Head, eye and face protection; and Respiratory protective equipment. Note: Each of these items of PPE and protective equipment must meet specific criteria set out in the OSHA standard. General Implementation Strategy: Engineering, work controls and PPE are not mutually exclusive, i.e., not either-or, and should be used in combination with each other. Tools & Implementation * See “How to Create a Fire Prevention Plan” to create and implement your own FPP; * Use the “Model Fire Prevention Plan” to design or improve your own FPP; 3 * Use the “Fire Prevention Plan Self-Assessment Checklist” to evaluate whether your FPP meets OSHA requirements; * See “What Design and Construction Controls Are Required to Manage Fire Hazards?” for step-by-step instructions in selecting engineering controls related to building design; * See “How to Comply with Portable Fire Extinguisher Requirements” for step-by-step instructions on meeting OSHA requirements; * Use the “Model Portable Fire Extinguisher Policy” to ensure proper inspection, maintenance and use of portable fire extinguishers; * Use the “Portable Fire Extinguishers Self-Assessment Inspection Checklist” to ensure appropriate inspections of portable fire extinguishers; * See “How to Comply with Fixed Fire Extinguisher Requirements” for step-by-step instructions on meeting OSHA requirements; * Use the “Model Fixed Fire Extinguisher Policy” to ensure proper inspection, maintenance and use of fixed fire extinguishers; * Use the “Fixed Fire Extinguishers Self-Assessment Inspection Checklist” to ensure appropriate inspections of fixed fire extinguishers; * See “How to Comply with Standpipe & Hose System Requirements” for step-by-step instructions on meeting OSHA requirements; * Use the “Standpipe & Hose System Self-Assessment Inspection Checklist” to ensure appropriate inspections of hoses and standpipes; * See “How to Comply with Automatic Sprinkler System Requirements” for step-by-step instructions on meeting OSHA requirements; * Use the “Automatic Sprinkler System Self-Assessment Inspection Checklist” to ensure appropriate inspections of sprinkler systems; * See “How to Comply with Automatic Fire Detection System Requirements” for step-by-step instructions on meeting OSHA requirements; * Use the “Automatic Fire Detection System Self-Assessment Inspection Checklist” to ensure appropriate inspections of detection systems; * See “16 Things to Do to Comply with Employee Alarm Systems” for step-by-step instructions on fire alarm compliance; * Use the “Model Employee Alarm System Policy” to ensure proper installation, use and maintenance of fire alarm systems; * Use the “Employee Alarm Systems Self-Assessment Inspection Checklist” to ensure appropriate inspections of fire alarm systems; * See “How to Create a Fire Safety & Housekeeping Policy” to find out how to instill fire safety awareness in your workers; * Use the “Model Fire Safety & Housekeeping Policy” to implement your own policy or improve your existing one; * See “How to Comply with Fire Fighter PPE Requirements” for step-by-step instructions on meeting OSHA PPE and protective equipment requirements for workers engaged in fire fighting operations. Step Three: Provide Fire Safety & Prevention Training (Day 16-20) 4 The next step is to provide fire safety and prevention training to workers. At a minimum, training should provide a review of your FPP, including these 12 items: The major fire hazards to which the workers are exposed; The methods used to control those hazards; The safe work procedures they must use to control each hazard; The housekeeping and sanitary requirements they’re expected to meet; How to conduct fire safety inspections and checks of their work area; Other general fire prevention information and education; The PPE and protective clothing they should wear; The alarm and detection systems in place to warn them of fires; How to report a fire; How to notify emergency personnel of a fire; The firefighting equipment necessary to control fire hazards; and The fire emergency and evacuation procedure (which OSHA calls the “Emergency Action Procedure”) and their role in carrying it out. You must also have a program to educate workers on general principles of fire extinguisher use and the hazards of “incipient stage firefighting,” i.e., fighting fires capable of being controlled or extinguished by portable fire extinguishers or similar equipment in their early stage without the need for protective clothing or respiratory protection. Fire extinguisher education must be provided to workers when they’re first hired and at least every year after that. Implementation Strategy: Use the SafetySmart training programs and resources, including the samples listed in the box below, to deliver effective and legally compliant general fire safety and prevention training. Also keep in mind that simply providing training isn’t enough. You must also ensure that workers actually understand and are capable of applying their training on the job. Methods of verifying the effectiveness of training include: Quizzing workers on the lesson after you deliver it (note that quizzes are included in all of the SafetySmart “Meeting Kits” and e-Learning courses listed in the box below); Making workers demonstrate the safe work procedures covered during the training; Making workers demonstrate proper use of the PPE covered during the training; and Observing workers on the job to ensure they’re actually following their training. Tools & Implementation For onsite training, use one or more of the following resources: * Meeting Kit: Make the Call for Help Perfectly Clear * Meeting Kit: Flammable, Flashpoint & Other Terms You Need to Know * Meeting Kit: Fire Safety Is Everyone’s Responsibility * Meeting Kit: Fire Safety Is Everyone’s Responsibility (Spanish version) 5 * Meeting Kit: Find the Fire Hazards * Meeting Kit: Know the Flammable Basics * Meeting Kit: Face Facts about Flammables * Meeting Kit: Aisleways, Storage and Fire Control * Meeting Kit: Prevent Workplace Fires * Meeting Kit: Obliterating Dust Explosions * Meeting Kit: Don’t Get Burned by Portable Heaters * Meeting Kit: Gasoline Is an Everyday Danger * Meeting Kit: Fire Is a Killer * Meeting Kit: Static Sparks Cause Explosions (Note: Meeting Kits include all the resources about a topic needed to deliver on-site training, typically including Leader Sheets, Handouts, PowerPoints and Quizzes) For online training, assign the following e-Learning courses: * Basic Fire Safety Course * Fire Safety Course in Spanish * Flame Resistant Clothing—Oil and Gas Industry Course For video training, use SafetySmart’s videos: * Flammable Liquids: Interactive Safety Video * Gory Story—Fire Prevention: Interactive Safety Video To document fire safety training, use the: * Model OSHA Training Log to document that safety training was provided and what it covered; and * Model OSHA Training Verification Form to document that you ensured that the training was effective. Step Four: Inspect, Monitor, Reinforce and Improve Your Fire Safety & Prevention Measures (Day 21-30 and forever after) The final step of the Program is to monitor your fire prevention and safety measures to ensure they’re effective and determine whether adjustments or corrective actions are necessary. Monitoring must be carried out on an ongoing and continuous basis. So even though we “schedule” it as starting on Day 21 and ending on Day 30, the monitoring process never ends. Monitoring should be done on a regular basis, e.g., fire inspections should be part of monthly work inspections and scheduled safety audits, and in response to red flags like: Worker complaints; Incident and injuries; Significant changes to operations, equipment, personnel etc. that weren’t accounted for or anticipated in the previous hazard assessment. 6