Fire Extinguisher Training: OSHA 1910.157 Requirements and What Annual Training Must Cover

Your first decision under OSHA 1910.157 isn’t about what extinguishers to buy. It’s about what you expect your employees to do when a fire starts.

OSHA gives you two options. You can expect employees to use extinguishers to fight incipient-stage fires. Or you can require them to evacuate immediately and leave firefighting to professionals. That choice drives everything else, including your training requirements, your written policies, and your inspection program.

Most employers don’t realize they’ve made this choice by default, usually the wrong way. They have extinguishers on the wall, no written policy, and employees who have never touched one. That’s a violation of both options.

The Two Paths Under 1910.157

Under the “evacuate only” path, you need a written policy stating that employees won’t use extinguishers. Your emergency action plan must direct all employees to evacuate when a fire alarm sounds. You still have to train employees on evacuation procedures. But you don’t need to train them on how to use an extinguisher.

The “expected to use” path requires more. If any employee might use an extinguisher, even voluntarily, OSHA treats them as expected to use one. And that triggers the full training requirements under 1910.157(g).

Most general industry workplaces take the “expected to use” path because they want the option available. That means annual training is not optional.

What Annual Training Must Cover

OSHA 1910.157(g)(2) requires annual hands-on training for all employees expected to use extinguishers. A video and a quiz don’t satisfy this requirement. Employees must actually operate an extinguisher.

The training content must cover the general principles of fire extinguisher use and the hazards of incipient-stage firefighting. In practice, that means four topics.

First, fire behavior. Employees need to understand how fire grows and what “incipient stage” means. A fire in the incipient stage is still small, confined to its point of origin, and manageable with a portable extinguisher. Once it spreads beyond that point, it’s no longer an incipient-stage fire and employees should evacuate.

Second, extinguisher classes and how to match them to fire types. Using the wrong extinguisher can make a fire worse. Throwing water on a grease fire is a well-known example. Training must cover which extinguishers work on which materials.

Third, the PASS technique. Pull the safety pin. Aim at the base of the fire, not the flames. Squeeze the handle. Sweep side to side at the base. This is the one skill that practice training actually builds, because the muscle memory of aiming low is different from what most people instinctively do.

Fourth, when to fight and when to leave. The rule is simple: don’t fight a fire unless you have a clear exit path behind you, the fire is small enough that one extinguisher can handle it, and you’ve already activated the alarm and made sure others are evacuating. If any of those conditions aren’t met, evacuate. No extinguisher is worth getting trapped.

Training records must be kept. OSHA doesn’t specify a retention period for fire extinguisher training records under 1910.157, but three years is a reasonable minimum given general inspection practices. Document the date, the trainer, and the employees trained.

For new employees, include fire extinguisher familiarization in your new employee safety orientation before they start working in areas where they might face a fire risk.

Placement and Travel Distance

Under 1910.157(d)(1), extinguisher placement depends on the hazard class.

For Class A hazards (ordinary combustibles like wood, paper, cloth), the maximum travel distance from any point in the protected area to the nearest extinguisher is 75 feet. For Class B hazards (flammable liquids and gases), the limit drops to 50 feet. Class K extinguishers protecting commercial cooking equipment must be within 30 feet of the hazard.

These distances often catch facilities off guard during inspections. The rule isn’t about distance from the nearest wall or exit, it’s about distance from any point in the work area. A large warehouse with extinguishers only at the exits may have significant coverage gaps in the middle.

Extinguishers must be mounted, not stored on the floor. Larger units (above 40 pounds) can be no more than 3.5 feet off the floor. Smaller units should be mounted so the top is no more than 5 feet high.

Signage matters too. If an extinguisher is blocked from view by shelving or equipment, mount a sign above it so workers can find it quickly.

Inspection Requirements

OSHA 1910.157(e)(1) requires monthly visual inspections. These are quick checks, not formal maintenance. The person doing the check confirms the extinguisher is in its designated place, the pressure gauge reads in the operable range (typically the green zone), the pin and tamper seal are intact, and there’s no obvious damage or corrosion.

Monthly inspections need to be documented. Write the date and your initials on the tag attached to the extinguisher. If anything is wrong, pull the unit from service and report it.

Annual maintenance is a different requirement. OSHA 1910.157(e)(2) requires that extinguishers be inspected annually by a qualified person. This is typically a licensed fire protection contractor who performs a thorough internal and external examination and documents the results on the maintenance tag.

NFPA 10 goes further than OSHA in some areas. It requires a 6-year internal inspection of stored-pressure extinguishers and hydrostatic testing on a schedule that varies by extinguisher type. Dry chemical stored-pressure units require hydrostatic testing every 12 years. Co2 units require it every 5 years. NFPA 10 is incorporated by reference in many state fire codes, so check your local requirements.

Extinguisher Types and Fire Classes

Class A extinguishers handle ordinary combustibles: wood, paper, cloth, rubber, and many plastics. The rating number before the A (like 2-A or 4-A) tells you the relative firefighting capacity.

Class B covers flammable and combustible liquids, including gasoline, oil, paint, and solvents, plus flammable gases. The rating number (like 10-B or 20-B) represents the square footage of burning liquid the extinguisher can handle.

Class C means the extinguisher agent is non-conductive and safe to use on energized electrical equipment. There’s no numerical rating for C because it doesn’t describe firefighting capacity, just suitability. Once electricity is removed, the fire is treated as an A or B.

Class D extinguishers handle combustible metals, including magnesium, titanium, potassium, and sodium. These are specialized units found mainly in machining and laboratory environments. Using an ABC extinguisher on a combustible metal fire can make it violently worse.

Class K extinguishers are built for commercial kitchen cooking fires involving cooking oils and fats at high temperatures. They use a wet chemical agent that creates a foam blanket. Most commercial kitchens with deep fryers are required to have K-class units as part of their fire suppression system.

The ABC multipurpose dry chemical extinguisher is the most common choice for general industry. It handles the most typical fire scenarios in one unit.

Common Violations

OSHA 1910.157 violations appear on the Top 10 list regularly. The most frequent issues are missing monthly inspection records, no documentation of annual training, extinguishers that are overdue for annual maintenance, and units that are blocked or mounted too high.

If you operate a facility where hot work happens, review the hot work permit guide alongside your extinguisher program. Hot work permits typically require a dedicated fire watch with an extinguisher on hand, which has specific placement and readiness requirements.

PPE for fire response is another overlooked area. If employees are expected to approach a fire to use an extinguisher, they need appropriate eye and face protection. Review your PPE guide to confirm your PPE hazard assessment covers fire response scenarios.

The one mistake that creates real liability is training employees on extinguisher use without training them on when not to use one. A worker who stays to fight a fire that’s already past the incipient stage, because they were trained to use an extinguisher but not told to read the fire, is a preventable fatality.