The Definition of Fire Prevention Plan

Definition of Fire Prevention Plan

A fire prevention plan (FPP) is a workplace document that identifies the fire hazards on site and sets out who controls them and how, so that fires do not start in the first place. It focuses on fuel, ignition sources and the people responsible for keeping the two apart.

In the US, the federal requirement is OSHA 29 CFR 1910.39. The rule is short, but it carries weight because other standards point to it. An FPP is not the same as an evacuation plan. It deals with prevention before a fire, while the emergency action plan deals with what people do once a fire or other emergency is underway. Many sites combine the two into one document, which is fine as long as each set of required elements is still there.

When OSHA Requires a Fire Prevention Plan

Section 1910.39(a) says an employer must have a fire prevention plan when an OSHA standard in Part 1910 requires one. That wording surprises people: 1910.39 sets the content, but other standards create the duty. The standards that call for an FPP include:

• 1910.1047, ethylene oxide. Where EtO is used and an emergency could occur.
• 1910.1050, methylenedianiline. Covers workplaces handling MDA.
• 1910.1051, 1,3-butadiene. Applies to facilities producing or using butadiene.
• 1910.157, portable fire extinguishers. Employers who choose a total-evacuation policy instead of letting employees fight fires may be exempt from most extinguisher requirements, but only if they have an emergency action plan and a fire prevention plan that meet the rules.

Even where no standard strictly triggers the plan, a written FPP is good practice and often expected by insurers, fire officials and corporate audit programs. Construction has its own route: 29 CFR 1926.150 makes the employer responsible for a fire protection program through all phases of a project, and 1926.24 addresses fire protection and prevention more broadly.

Required Elements Under 1910.39

Written or oral

The plan must be in writing, kept in the workplace and made available to employees for review. An employer with 10 or fewer employees may communicate the plan orally instead.

Minimum content

Section 1910.39(c) lists five elements:

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 needed 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 accidental ignition of combustible materials.
4. The name or job title of employees responsible for maintaining equipment that prevents or controls sources of ignition or fires.
5. The name or job title of employees responsible for the control of fuel source hazards.

Employee information

Under 1910.39(d), the employer must inform employees of the fire hazards they are exposed to on initial assignment, and review with each employee the parts of the plan needed for their own protection.

Building a Plan People Actually Use

Start from a hazard walk, not a template

The weakest plans list generic hazards copied from elsewhere. Walk the site with maintenance and operations, room by room. Note flammable storage, combustible dust deposits, battery charging, kitchens, heaters, dryers, compressors, smoking areas and waste points. Check safety data sheets for flash points and incompatibilities, and record where each material is stored and in what quantity.

Housekeeping

Waste control is the element most often missed in practice. Set frequencies for emptying bins, cleaning lint and dust from equipment, and removing oily rags into self-closing metal cans. Say who does it and on which shift. Pallets stacked against the building and cardboard piled in electrical rooms are classic findings.

Ignition source control

Cover hot work permits, smoking rules, electrical equipment rating in hazardous areas, static control during transfer of flammable liquids, and portable heater rules. Hot work should link straight to the site's permit system and its fire watch procedure.

Maintenance of heat-producing equipment

Ovens, furnaces, boilers, dryers, fryers and heat-treating lines need scheduled checks of their safeguards: thermostats, high-limit switches, flame safeguards, exhaust systems and clearances to combustibles. Tie these to the preventive maintenance schedule so they are not kept in a separate binder nobody opens.

Names, not departments

"Maintenance" is not a responsible person. Name job titles, with backups for nights and weekends.

Fire Prevention Plan vs. Emergency Action Plan

The two plans sit next to each other in 29 CFR 1910 Subpart E and are often confused.

• Fire prevention plan (1910.39): hazards, storage, waste control, ignition control, equipment maintenance and responsible people. Its goal is to stop fires from starting.
• Emergency action plan (1910.38): how to report emergencies, evacuation procedures and evacuation routes, procedures for employees who stay to operate critical plant operations, accounting for employees after evacuation, and rescue or medical duties. Its goal is to get people out safely when something has gone wrong.

Both have the same 10-employee oral option. A combined fire and emergency document works well when sections are clearly labeled and each list of elements is complete.

Example of a Fire Prevention Plan

A building materials manufacturer that makes engineered wood panels had an FPP written years earlier by a consultant. It listed "wood dust" as a hazard and "housekeeping" as the control, with the maintenance department responsible. After a small fire started in a dust collector duct, the site rewrote the plan from a fresh walk-through.

The new version mapped dust accumulation points on each line, set cleaning frequencies by area, and banned compressed air blow-down except under a specific procedure. It named the shift maintenance lead as responsible for spark detection and the dryer high-limit checks, and the production supervisor for nightly dust cleanup. Dryer safeguard tests were moved into the maintenance work order system. Supervisors walked each line with their crews to review the relevant section, and the site added fire prevention checks to its monthly safety audits so drift would show up.

Frequently Asked Questions: Fire Prevention Plan

How often should a fire prevention plan be updated?

OSHA does not set a fixed review cycle. Update the plan whenever processes, materials, layouts or responsible people change, and after any fire or near miss. Many employers also review it annually. A plan that still names a supervisor who left two years ago, or lists a line that has been removed, signals to an inspector that nobody is using it.

Does a small office need a fire prevention plan?

Only if an OSHA standard requires one, which is uncommon for an office. The most likely trigger is choosing total evacuation instead of training staff to use extinguishers under 1910.157. Even then, an office with 10 or fewer employees can communicate the plan orally. Local fire codes and landlords may still have their own requirements.

Who is responsible for writing the plan?

The employer is responsible. In practice, an EHS manager or facilities lead usually drafts it with input from maintenance, operations and whoever handles purchasing of hazardous materials. Contractors working on site should be briefed on the parts that affect them, and their own hot work or storage practices should fit inside the host employer's plan.

How is fire prevention handled outside the US?

In the UK, the Regulatory Reform (Fire Safety) Order 2005 requires the responsible person to carry out a fire risk assessment, recorded in writing where five or more people are employed. In Canada, provincial occupational health and safety rules and the National Fire Code apply. Australian workplaces manage fire under WHS duties and state fire safety laws.