OSHA’s Fire Prevention Plan standard at 29 CFR 1910.39 requires employers to develop and implement a written fire prevention plan that addresses fire hazards, ignition source controls, and housekeeping procedures. The fire prevention plan works in conjunction with the Emergency Action Plan (29 CFR 1910.38) to provide comprehensive fire safety. Beyond OSHA’s minimum requirements, NFPA standards (particularly NFPA 1, NFPA 10, NFPA 25, and NFPA 101) establish detailed requirements for fire protection systems, equipment maintenance, and life safety. A comprehensive fire prevention program audit evaluates whether your facility has adequately identified fire hazards, implemented controls to prevent fires, maintained fire protection equipment, and trained employees on fire prevention responsibilities.
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29 CFR 1910.39 — Fire Prevention Plans
The OSHA fire prevention plan standard requires employers to have a written plan that includes a list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their controls, the type of fire protection equipment necessary, and procedures for maintenance of safeguards. The plan must also identify personnel responsible for maintaining equipment to prevent or control ignition sources and for controlling fuel source hazards. The plan must be available for employee review.
29 CFR 1910.157 — Portable Fire Extinguishers
This standard requires employers to provide portable fire extinguishers and mount, locate, and identify them so they are readily accessible. Employers must also ensure that extinguishers are maintained, serviced, and inspected per NFPA 10. If the employer has established an EAP and designates certain employees to use fire extinguishers, only those employees need training. If the employer provides extinguishers for employee use, initial and annual training on use is required.
NFPA 1 — Fire Code and NFPA 101 — Life Safety Code
NFPA 1 is a comprehensive fire code adopted by many jurisdictions covering fire prevention, fire protection systems, hazardous materials, and building processes. NFPA 101 (Life Safety Code) addresses building construction, protection, and occupancy features to minimize danger from fire, smoke, fumes, and panic. Together these codes establish requirements for means of egress, fire alarm and detection systems, sprinkler systems, and fire-safe building operations.
Written Fire Prevention Plan
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Plan documentation | A written fire prevention plan exists per 29 CFR 1910.39(b). The plan includes a list of all major workplace fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control procedures, type of fire protection equipment necessary to control each major hazard, and procedures for regular maintenance of safeguards. The plan is kept in the workplace and available for employee review per 1910.39(b)(2). |
| Responsible personnel | The plan identifies personnel responsible for maintenance of equipment and systems to prevent or control sources of ignition or fires per 1910.39(b)(3). Personnel responsible for controlling fuel source hazards are also identified. Contact information for responsible personnel is current. |
| Employee information and training | The employer has informed employees of the fire hazards they are exposed to per 1910.39(c). Employees have been trained on the parts of the fire prevention plan necessary for their own safety. The employer reviews the plan with each employee when initially assigned, when the plan changes, and when duties change. Training is documented. |
Fire Hazard Assessment and Controls
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Fire hazard identification | A systematic fire hazard assessment has been conducted identifying all sources of fuel, ignition, and oxidizers in the workplace. Assessment covers flammable/combustible liquids storage, electrical equipment, hot work areas, heating equipment, smoking areas, cooking equipment, chemical storage, and any other fire hazards specific to the facility. Assessment is documented and updated when conditions change. |
| Ignition source controls | Controls are implemented for each identified ignition source. Electrical equipment is properly maintained and meets NFPA 70 (NEC) requirements. Heating equipment has appropriate clearances from combustibles. Smoking is restricted to designated areas. Static electricity grounding and bonding procedures are in place for flammable liquid handling. Open flame operations are controlled through hot work permit procedures. |
| Hot work permit program | A hot work permit program is established for welding, cutting, brazing, and other spark/flame-producing operations per NFPA 51B. Permits specify the work area, fire hazards, protective measures, fire watch requirements, and authorization. A fire watch is maintained for at least 30 minutes after hot work completion (60 minutes per NFPA 51B). The hot work area is inspected before, during, and after operations. |
| Flammable materials management | Flammable and combustible liquids are stored in approved containers and cabinets per NFPA 30 and 29 CFR 1910.106. Storage quantities comply with maximum allowable quantities. Flammable liquid transfer uses proper bonding and grounding. Safety data sheets are available for all flammable materials. Incompatible materials are segregated. |
Fire Protection Systems and Equipment
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Fire extinguisher program | Portable fire extinguishers are provided, mounted, located, and identified per 29 CFR 1910.157. Extinguishers are selected for the type of fire hazard in the area (Class A, B, C, D, K). Travel distances do not exceed 75 feet for Class A and 50 feet for Class B hazards. Monthly visual inspections are conducted and documented. Annual maintenance is performed by a certified technician per NFPA 10. |
| Fire alarm and detection systems | Fire alarm and detection systems are installed, maintained, and tested per NFPA 72. Alarm systems are audible throughout the facility. Smoke and heat detectors are appropriate for the environment and properly located. The system is inspected, tested, and maintained at required intervals (visual monthly, functional testing semi-annually/annually). System impairments are managed with alternative fire watch procedures. |
| Automatic sprinkler systems | If installed, automatic sprinkler systems are maintained and tested per NFPA 25. Weekly/monthly visual inspections of sprinkler heads, piping, and valves are conducted. Main drain tests are performed quarterly. Valve supervision ensures control valves remain open. Sprinkler head clearance of at least 18 inches below the deflector is maintained. System impairments are managed and documented. |
| Standpipe and fire hose systems | If installed, standpipe and fire hose systems are maintained and tested per NFPA 25. Hose connections are accessible and unobstructed. Fire hoses are inspected annually and pressure tested every five years. Standpipe pressure is verified during testing. Fire department connections are accessible, visible, and properly identified. |
Means of Egress and Life Safety
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Exit routes and signage | Exit routes are maintained free of obstructions per 29 CFR 1910.37 and NFPA 101. Exit doors open in the direction of travel, are not locked from inside, and have panic hardware where required. EXIT signs are illuminated, visible from all points, and maintained. Emergency lighting provides adequate illumination for at least 90 minutes during a power failure per NFPA 101. Exit route capacity is adequate for the occupant load. |
| Fire door maintenance | Fire-rated doors and assemblies are maintained in proper working condition. Self-closing mechanisms function properly. Fire doors are not propped or blocked open (unless held by magnetic hold-open devices connected to the fire alarm system). Door gaps and clearances meet fire rating requirements. Annual fire door inspections are conducted per NFPA 80. |
Housekeeping and Prevention Practices
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| General fire prevention housekeeping | Combustible materials are not allowed to accumulate. Waste and recyclable materials are properly stored and disposed of. Electrical panels have required clearance (36 inches per NEC). Storage does not obstruct sprinkler heads, fire extinguishers, alarm pull stations, or exit routes. Oily rags and flammable waste are stored in approved self-closing metal containers. |
| Electrical safety for fire prevention | Electrical systems are maintained to prevent fire hazards. Extension cords are not used as permanent wiring. Outlets are not overloaded. Damaged wiring, cords, and equipment are repaired or replaced promptly. Ground fault protection is provided where required. Electrical rooms are free of combustible storage. |
Program Review and Documentation
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Inspection and maintenance records | Records are maintained for all fire protection system inspections, testing, and maintenance per NFPA 25 (sprinklers), NFPA 10 (extinguishers), NFPA 72 (alarms), and NFPA 80 (fire doors). Records include date, inspector, findings, and any deficiencies corrected. Deficiency tracking demonstrates timely correction. |
| Annual program review | The fire prevention program is reviewed at least annually or whenever significant changes occur in facility operations, layout, or hazards. Review evaluates fire hazard assessment currency, control adequacy, equipment maintenance compliance, training completion, and incident/near-miss trends. Review findings drive program improvements. |
Corrective Actions
Common Issues and Responses
- No written fire prevention plan: Develop a written fire prevention plan addressing all requirements of 29 CFR 1910.39. Conduct a fire hazard assessment to identify all major hazards, ignition sources, and required controls. Designate responsible personnel and communicate the plan to all employees.
- Overdue fire extinguisher maintenance: Schedule immediate annual maintenance by a certified technician per NFPA 10. Resume monthly visual inspections. Replace or recharge extinguishers as needed. Six-year maintenance and 12-year hydrostatic testing must also be current.
- Blocked exits or missing EXIT signs: Clear all obstructions from exit routes immediately. Replace or repair non-functioning EXIT signs and emergency lighting. Verify exit doors operate properly with correct hardware. Conduct a building-wide egress audit.
- No hot work permit program: Establish a hot work permit program per NFPA 51B. Develop permit forms, train supervisors and fire watchers, identify restricted areas, and implement pre-work inspection and post-work fire watch procedures.
- Fire protection system impairments: Address all impairments to fire protection systems immediately. Implement fire watch procedures while systems are out of service. Notify the authority having jurisdiction and insurance carrier as required. Track impairment resolution with defined deadlines.
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Inspections
Digital fire extinguisher, alarm, sprinkler, and fire door inspection checklists with photo documentation.
Compliance Calendar
Schedule monthly, quarterly, semi-annual, and annual fire protection inspection and testing deadlines.
Training
Track fire extinguisher training, fire prevention plan reviews, fire watch certifications, and drill participation.
Task Management
Track fire protection system deficiencies and corrective actions with priority and deadline management.
Document Management
Centralized storage for fire prevention plans, inspection records, hot work permits, and system maintenance logs.
Emergency Planning
Integrated emergency action and fire prevention planning with drill scheduling and documentation.
