Fire extinguisher inspection checklist: monthly checks and annual maintenance

What the rules require, in short

OSHA says portable extinguishers "shall be visually inspected monthly" (1910.157(e)(2)) and "subjected to an annual maintenance check" (1910.157(e)(3)). NFPA 10 calls for a visual inspection when the unit is first placed in service and at least monthly after that, at a minimum of 30-day intervals (7.2.1), and lists what that inspection must verify (7.2.2). Maintenance, the hands-on annual job, is covered in NFPA 10 section 7.3 and is done by a trained person with the manufacturer's service manual.

Monthly inspection checklist

NFPA 10 describes an inspection as a quick check that the extinguisher is in its designated place, has not been actuated or tampered with, and has no obvious damage or condition that would stop it working. Work through each unit in this order:

1. Location: the extinguisher is in its designated place (NFPA 10 (2010) 7.2.2). OSHA also requires extinguishers to be kept in their designated places at all times except during use (1910.157(c)(4)).
2. Access and visibility: nothing blocks the path to it or hides it from view (7.2.2). Look for stacked stock, carts, furniture or a new wall that went up since the last visit.
3. Pressure gauge: the reading is in the proper range or position (7.2.2). A reading in the normal range alone does not prove the unit will perform as intended.
4. Fullness: confirmed by weighing or hefting (lifting) the unit (7.2.2).
5. Pin and tamper seal: the safety seal is in place and not broken or missing. The Minnesota guide lists this as another thing to look for and notes that a broken seal can mean someone used the unit and discharged too little to move the gauge.
6. Physical condition: no evidence of physical damage, corrosion, leakage or a clogged nozzle (also on the Minnesota guide's list). Look the hose over while you are there.
7. Operating instructions: the operating instructions are legible and face outward (NFPA 10 (2010) 6.1.3.9.1 and 6.1.3.10.3).
8. Tag and label: the maintenance tag is present, readable, and shows an annual service within the last year; check the 6 year and hydrostatic test labels for dates coming due.
9. Record it: write the date and the inspector's initials (see the recording section below).

Some units need more than a monthly look. The Minnesota guide gives examples: extinguishers often found blocked during monthly inspections, or located where they are exposed to tampering, theft or mechanical damage, may need to be inspected more frequently.

What a failed monthly check means

Problems found during the monthly inspection are corrected right away, and some of them trigger more than a fix in place:

• Rechargeable unit with the gauge out of the operable range, or fullness that cannot be confirmed by weighing or lifting: full maintenance is required (NFPA 10 (2010) 7.2.3.1).
• Nonrechargeable dry chemical unit with the gauge out of range, fullness not confirmed, or a push-to-test indicator that does not read correctly: remove it from use, discharge it, and destroy it or return it to the manufacturer (7.2.3.2). These units are marked with wording such as "Nonrechargeable" or "Discharge and Dispose of After Any Use".
• Any unit pulled for service: OSHA requires alternate equivalent protection while extinguishers are out for maintenance or recharging (1910.157(e)(5)), and NFPA 10 (2010) 7.1.3 expects a replacement suitable for the hazard and of at least equal rating.

Annual maintenance checklist

Annual maintenance is a thorough examination of the mechanical parts, extinguishing agent and expelling means of each unit (NFPA 10 (2010) 7.3.2, with more detail in Annex A.7.3.2). It goes beyond the monthly look and is done with the manufacturer's service manual and listed parts. A practical order:

1. Repeat every item on the monthly checklist.
2. Check the shell, valve, hose, nozzle and gauge against the manufacturer's service manual, and replace damaged parts with listed parts.
3. Confirm the agent and expelling means are in order for the extinguisher type. OSHA does not require an internal examination of stored pressure units at the annual check (1910.157(e)(3)), but NFPA 10 does require one annually for stored pressure loaded stream and antifreeze units (see the next item).
4. Check whether the unit is due for its 6 year maintenance or an internal examination. NFPA 10 sets some types on shorter cycles: for example, stored pressure loaded stream and antifreeze units annually, and CO2 and wet chemical units every 5 years (NFPA 10 (2010) 7.3.1.1.2, as summarized by the Minnesota guide).
5. Check the hydrostatic test date against the interval for the type. Nonrechargeable stored pressure units are not hydro tested; they come out of service 12 years from the date of manufacture (7.3.1.2.1.3).
6. Install a new tamper seal on rechargeable units after maintenance (7.3.2.2.1).
7. Hang a new tag or label and record the service (below).

Hydrostatic test dates to look for

Part of every inspection is reading the last hydro date and flagging units coming due. A few common rows from OSHA Table L-1:

The Table L-1 testing requirement does not apply to a unit that has been repaired by soldering, welding, brazing or patching compounds, has damaged threads, has corrosion that caused pitting, has been burned in a fire, or has had a calcium chloride agent used in a stainless steel shell (1910.157(f)(2)). Shells that fail the test or are not fit for testing are removed from service (1910.157(f)(14)). A unit that shows new evidence of corrosion or mechanical injury is hydrostatically tested without waiting for its interval (1910.157(f)(4)), and before any hydrostatic test the cylinder gets an internal and an external visual examination (1910.157(f)(3)).

Recording the inspection

• Monthly: record the date and the initials of the person who inspected, on a tag or label on the unit, on an inspection checklist kept on file, or electronically (NFPA 10 (2010) 7.2.4). Records cover every extinguisher inspected, including those that needed corrective action.
• Annual: the tag or label shows the month and year of maintenance, the name of the person who did it, and the name of the company (7.3.3). OSHA requires the annual maintenance date to be recorded and kept for one year after the last entry or the life of the shell, whichever is less (1910.157(e)(3)).
• 6 year maintenance: a metal or similar durable label at least 2 by 3.5 inches, with month and year punched, the technician's initials or name, and the company name (7.3.3.1).
• After an internal examination or recharge: a verification-of-service collar around the neck that cannot come off without removing the valve (7.3.3.2). Cartridge or cylinder operated units are exempt.
• Hydro test: OSHA requires proof of the test with the date, the tester's signature and the serial number or other identifier (1910.157(f)(16)).

Licensed shops in Florida and Texas also have to follow state tag rules. Florida rule 69A-21.241 requires a new tag "each time a service is performed," with the month and year shown "by means of perforation," the serial number, the technician's full name ("Initials are not acceptable") and permit number. Texas rule 28 TAC 34.520 requires a new tag each time service is performed, the month and year "to be punched," and the licensee's signature ("a stamped signature is prohibited").