OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

December 15, l980

Mr. Dennis K. Shira
Safety Coordinator
State Farm Insurance Companies
One State Farm Plaza, SBI-W
Bloomington, Illinois 61701

Dear Mr. Shira:

This is in response to your inquiry concerning the revised fire protection standards of the Occupational Safety and Health Administration (OSHA) with respect to the use of Halon 1211 fire extinguishers for class A hazards.

At the time OSHA was preparing the final rule for its fire protection standards, Halon 1211 fire extinguishers had not yet received a class A rating from UL. Since that time however, and as you correctly noted, some Halon 1211 fire extinguishers have recently received a class A rating from UL. The OSHA fire protection standards permit the use of any fire extinguisher for use on class A hazards if the extinguisher has received a class A rating from UL. Therefore, those Halon 1211 fire extinguishers with a UL class A rating are permitted to be used on class A hazards.

We hope this has answered your question. Please contact us if you need further assistance.


Glen E. Gardner
Senior Safety Specialist
Office of Fire Protection
Engineering and Systems Safety Standards