What OSHA Really Requires in a Fire Prevention Plan—and How to Build One That Works
When it comes to workplace safety, fire is one of the most catastrophic risks. According to OSHA standard 29 CFR 1910.39, any workplace that is required to have a fire prevention plan must meet a specific set of criteria. While the regulation is brief, compliance—and actual effectiveness—requires deliberate planning, documentation, and ongoing attention.
Here’s what you need to know about the minimum requirements, required documentation, and best practices for building and maintaining your company’s Fire Prevention Plan (FPP).
Minimum Requirements Under OSHA 1910.39
According to OSHA, a Fire Prevention Plan must be in writing, kept in the workplace, and made available to employees for review. If you have 10 or fewer employees, the plan may be communicated orally.
At a minimum, your Fire Prevention Plan must:
List all major fire hazards in the workplace.
Provide proper handling and storage procedures for hazardous materials.
Describe potential ignition sources (e.g., open flames, sparks, electrical equipment) and their control methods.
Outline the type of fire protection equipment available (extinguishers, sprinklers, suppression systems).
Designate personnel responsible for maintaining fire prevention equipment.
Establish procedures for controlling accumulation of flammable or combustible waste materials.
Assign duties for employees who are responsible for fire prevention.
While the regulation seems straightforward, effective implementation requires a deeper dive into your facility’s unique fire risks.
Required Documentation
To comply with OSHA 1910.39, your written plan must include:
A list of fire hazards specific to your facility or operations.
Control measures for each hazard (engineering or administrative).
Preventive maintenance schedules for fire prevention equipment.
Roles and responsibilities clearly assigned to individuals.
Training records to prove employees have been informed about the plan.
Documentation isn’t just about compliance—it’s a tool for training, accountability, and continuous improvement.
How to Create an Effective Fire Prevention Plan
Creating a useful fire prevention plan goes beyond just checking boxes. It should start with a risk assessment, then translate that risk into prevention actions.
Here’s a step-by-step process:
1. Conduct a Fire Hazard Analysis
Identify flammable chemicals, combustibles, hot work areas, electrical systems, and any history of fire-related incidents.
Use tools like a Job Hazard Analysis (JHA) or a Fire Risk Matrix to evaluate severity and likelihood.
2. Review Facility Layout and Utilities
Assess fire compartmentation, egress paths, ventilation, storage rooms, and power sources.
Map out suppression systems and ensure clear access.
3. Establish Controls
Engineering: fire-rated walls, spark arrestors, explosion-proof fixtures.
Administrative: hot work permits, housekeeping procedures, ignition source control.
4. Assign Roles and Responsibilities
Who inspects extinguishers?
Who manages flammable waste?
Who leads annual reviews?
5. Write the Plan
Keep it concise but thorough.
Include emergency contact numbers, training schedules, and inspection logs.
6. Train Employees
All employees must be trained on fire hazards and their role in prevention.
Supervisors must be trained in enforcement and documentation.
Best Practices
While OSHA provides the foundation, here are ways to elevate your FPP:
Integrate with other safety programs. Link fire prevention to your chemical hygiene, electrical safety, and hot work programs.
Use visual controls. Label flammable storage areas and post extinguisher inspection schedules.
Leverage technology. QR codes can link to digital SDSs or inspection forms.
Conduct fire drills. While not required under 1910.39, drills reinforce awareness and readiness.
Maintaining the Plan
A fire prevention plan is not a “set it and forget it” document. It must be:
Reviewed at least annually (or whenever processes or materials change).
Updated after any incident, near miss, or audit finding.
Audited internally, with fire hazards reassessed during routine safety inspections.
Supported with ongoing training, especially during onboarding and job transfers.
Remember, OSHA can cite you not just for not having a fire prevention plan—but also for having one that’s never reviewed, trained on, or followed.
Final Thoughts
Your fire prevention plan isn’t just a compliance tool—it’s a shield against one of the most devastating workplace events. By going beyond the bare minimum of 1910.39 and building a living, functional plan, you protect your workers, your operations, and your business.
Need help developing a compliant and customized Fire Prevention Plan? VanguardEHS offers templates, guidance, and safety support tailored to small businesses.
