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.

June 26, 1981

Mr. Thomas A. Duym
Safety Administrator
Special Products Division
Nabisco, Inc.
East Hanover, New Jersey 07936

Dear Mr. Duym:

This is in response to your recent inquiry regarding supervised manual fire alarm systems and 29 CFR 1910.165. The requirement of 1910.165(a)(1), that employers have an alarm system, applies only to those employers who choose to have employee emergency plans as indicated in 1910.38.

There is presently no requirement to install manual fire alarm systems; however, if they are installed and are capable of being supervised, the requirements of 1910.165(d) would apply.

The public address, bell paging, fire gong, bull horn and/or personal communicators must comply with 1910.165(b)(1)-(b)(5) if the employer has an employee emergency plan.

Fire alarm systems for grain elevators must also comply with the appropriate requirements of 29 CFR 1910 Occupational Safety and Health Standards - Fire Protection, [Exit Routes], and Hazardous Materials only if the employer has an emergency action plan.

We hope this information will be of assistance to you.


John K. Barto Chief,
Division of Occupational Safety Programming

[Corrected 2/4/2004]