Environmental Compliance 101

The Occupational Safety and Health Administration (OSHA) is responsible for assuring safe and healthful working conditions for workers in the United States. One tool in achieving this objective is to develop and enforce regulatory standards. Subsequently many regulations have been promulgated which are required to be fulfilled by businesses and employers. One such regulation is the development of a Fire Prevention Plan under the requirements (29 CFR 1910.39) for general industry. 

If a facility falls under the requirements of the general industry standards and has greater than 10 employees, the facility may be required to develop a written Fire Prevention Plan. Per the regulatory standards, the minimum elements of a properly prepared plan must include the following:

1. A list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard
2. Procedures to control accumulations of flammable and combustible waste materials
3. Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials
4. The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires
5. The name or job title of employees responsible for the control of fuel source hazards

If your facility is applicable to the general industry standards of OSHA, the first question is, do you need to have a Fire Prevention Plan? During the hundreds of safety audits conducted by August Mack, we have discovered that many facilities are not aware of this potential requirement. Or more often, they refer to another safety plan they have prepared indicating it fulfills this requirement. Facilities can integrate plans but if the five required elements cited above are not in the integrated plan, the facility is not fully complying with this specific regulation if a plan is required.

Finally, if the facility has prepared a Fire Prevention Plan and it contains the required elements, is it up-to-date? If you have specific individuals identified by name for elements #4 and #5 above, are these people still at your facility and fulfilling this role? Again, during our many audits, we have found plans were developed many years ago and have not been kept up-to-date. The regulatory agencies expect safety plans to be “living documents” and will be updated as changes occur at the facility.

In conclusion, if you are charged with the safety responsibilities at your facility and your facility falls under the general industry standards of OSHA, you should ask yourself three questions:

1. Does the facility need a Fire Prevention Plan?
2. If so, does it contain the required five minimum elements?
3. If it has the required elements, is it up-to-date?

If the regulatory inspector comes knocking on your door, you will rest easier knowing you can answer these three questions.