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 http://www.osha.gov.

March 6, 1981

Mr. Gerald M. Brown
Sgt., Plant Security
Cadillac Motor - GMC
2860 Clark Street
Detroit, Michigan 48232

Dear Mr. Brown:

This is in response to your recent letter requesting clarification of 29 CFR 1910.160(b)(6) and (b)(10). Your letter addressed to Mr. Michael B. Moore was forwarded to this office for response.

29 CFR 1910.160(b)(6) requires an annual inspection of the fixed extinguishing system. Employers may qualify one of their employees to perform the inspection through instruction and hands-on practice in the operation of the system or may use an outside contractor to perform the inspection.

29 CFR 1910.160(b)(10) requires that employers train and annually review the inspection, maintenance, operation, and repair procedures with employees designated to perform those functions. Employers again may qualify one of their employees to perform the above tasks through instruction and hands-on practice in the operation of the system or may use an outside contractor to perform these functions.

If we may be of further assistance, please feel free to call or write.

Sincerely,



John K. Barto
Chief, Division of
Occupational Safety Programming