January 14, 1999
| MEMORANDUM FOR: |
RUTH MCCULLY
Regional Administrator
|
| FROM: |
Richard E. Fairfax
Director
Directorate of Compliance Programs
|
| SUBJECT: |
Citation Policy Regarding Automatic Sprinkler Systems. |
This is in response to your memorandum of October 15, regarding OSHA's citation
policy for maintaining sprinkler systems. Specifically, you requested a
clarification as to whether it would be an employer's obligation to maintain an
automatic sprinkler system, in situations where the sprinkler system at issue
is not actually required by a particular OSHA standard.
Please note that the lack of maintenance on a sprinkler system which is not
required by an OSHA standard would not constitute a violation, except if the
system poses a new hazard.
With regard to your specific example regarding §1910.252(a)(2)(vi)(B), this
standard prohibits the performance of welding and cutting in an area equipped
with an inoperable sprinkler system. Therefore, the standard implies that
welding and cutting should be performed in areas with properly functioning
sprinkler systems. The lack of an operable sprinkler system, in this case,
would constitute a violation. On the other hand, if an operation did not
require the presence of a properly functioning sprinkler system according to
a particular standard, the existence of an impaired sprinkler system would not
constitute a violation.
Thank you for your inquiry. If you need further assistance, please contact
Alcmene Haloftis of my staff at 202-693-1850.
|
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