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.

November 16, 1982

Mr. Paul R. Kaveler
Fire Protection Engineer
Union Electric Company
1901 Gratiot Street
P.O. Box 149 - Mail Code 560
St. Louis, Missouri 63166

Dear Mr. Kaveler:

This is in response to your letter of October 26, 1982, requesting a clarification of several items in Subpart L of the General Industry Safety and Health Standards. My response to your three questions follows:

1. The manufacturer's acceptance test conducted at the factory does satisfy 29 CFR 1910.158(e)(ii), providing the test of the hose is conducted with the couplings attached.

2. Subpart L does not require any periodic hydrostatic testing of fire hose, but we do require that the hose be inspected annually and maintained in serviceable condition.

3. It was not the intent of 29 CFR 1910.158(e)(ii) to specifically cross-reference with NFPA Standards 1962 - 1979.

If I may be of further assistance, please feel free to contact me.

Sincerely,



John K. Barto
Chief, Division of Occupational
Safety Programming