Does Your Clinic Need a Fire Prevention Plan? An OSHA Guide (29 CFR § 1910.39)

OSHA’s Fire Prevention Plan (FPP) standard, found in 29 CFR § 1910.39, requires healthcare practices to establish a written plan that minimizes the risk of workplace fires and prepares staff to respond effectively. For small clinics, this regulation is especially important since even minor fires can endanger patients, damage medical equipment, and cause costly disruptions. Compliance with this rule ensures that clinics have proactive measures in place to identify fire hazards, maintain safe practices, and assign clear responsibilities to staff. Developing and maintaining a fire prevention plan not only protects lives but also shields small practices from OSHA penalties and reputational harm.

Healthcare environments are uniquely vulnerable to fire hazards due to the presence of oxygen tanks, cleaning chemicals, electrical equipment, and patient care activities. While small clinics may assume that fire emergencies are rare, OSHA’s Fire Prevention Plan standard (29 CFR § 1910.39) makes it clear that every employer must take structured steps to minimize fire risks. Compliance with this rule is not optional, it is a safeguard against potential disasters. For small practices, an effective Fire Prevention Plan can mean the difference between a controlled incident and a devastating shutdown.

Understanding Fire Prevention Plans Under 29 CFR § 1910.39

OSHA requires employers to maintain a written Fire Prevention Plan that is accessible to all employees. The regulation outlines mandatory elements, including:

• Identification of major fire hazards such as oxygen tanks, flammable chemicals, or electrical systems.

• Proper handling and storage procedures for flammable materials.

• Maintenance of safeguards installed on heat-producing equipment.

• Names or job titles of employees responsible for fire safety programs.

• Procedures for controlling fuel source hazards that may ignite fires.

The regulation allows employers with 10 or fewer employees to communicate the plan orally, but written documentation is strongly advised for small healthcare facilities where patient care complicates emergency response. Understanding these requirements ensures clinics avoid legal penalties while building a safer workplace.

While OSHA enforces workplace safety regulations, the Department of Health and Human Services Office for Civil Rights (OCR) may also evaluate fire safety planning under healthcare-related compliance reviews. If a clinic fails to account for patients with mobility issues during fire prevention planning, OCR could investigate potential violations of civil rights protections under Section 504 of the Rehabilitation Act or the Americans with Disabilities Act (ADA). Triggers for reviews may include:

• Complaints from patients or staff after unsafe fire conditions.

• Self-reports of fire-related incidents.

• Broader compliance investigations where fire safety is reviewed alongside HIPAA and patient safety.

This dual oversight highlights that fire prevention planning protects both employee safety and patient rights.

Developing a compliant Fire Prevention Plan can be done efficiently when following OSHA’s framework.

1. Identify Major Fire Hazards: List sources such as oxygen tanks, medical gases, and cleaning chemicals. Document safe handling and storage procedures.

2. Assign Fire Prevention Roles: Designate staff responsible for inspections, maintenance, and training. Include names and job titles in the plan.

3. Maintain Heat-Producing Equipment: Establish a maintenance schedule for sterilizers, space heaters, or other equipment that could cause ignition.

4. Control Fuel Sources: Document procedures for controlling waste, combustible materials, and flammable liquids.

5. Write and Share the Plan: Ensure all employees review the Fire Prevention Plan during onboarding and refresher sessions.

6. Train and Drill: Conduct periodic fire safety training and document participation to demonstrate compliance.

These steps help small clinics build a fire prevention system that satisfies regulatory requirements while protecting patients and staff.

Case Study

A small dermatology clinic was cited by OSHA after a preventable fire safety lapse exposed both staff and patients to unnecessary risks. Inspectors found that multiple oxygen tanks, considered highly combustible materials, were being stored in an unsecured closet located next to heat-producing equipment. The clinic also lacked a written Fire Prevention Plan (FPP) as required under 29 CFR 1910.39, and staff had never received formal training on fire safety procedures or evacuation protocols.

The weaknesses in the clinic’s safety program became clear when a minor electrical short in nearby equipment sparked a small fire. Instead of responding in an orderly manner, staff panicked. No one knew who was responsible for evacuating patients or for securing oxygen tanks, and as a result, the fire spread long enough to cause damage to several pieces of expensive medical equipment. Although no injuries occurred, the delayed evacuation created unnecessary risks, and the failure to prepare placed both employees and patients in danger. Following its inspection, OSHA cited the clinic, issuing fines of $6,000 and mandating a corrective action plan. The plan required the clinic to draft a written Fire Prevention Plan, train all staff on fire response, and implement safe oxygen storage practices with clear documentation.

In contrast, another dermatology clinic in the same region had proactively developed a comprehensive Fire Prevention Plan. Leadership designated fire wardens responsible for guiding patients and staff during emergencies, secured oxygen storage in a separate, ventilated area away from ignition sources, and performed monthly inspections of electrical systems. Staff were trained annually on fire safety protocols, including how to identify hazards, use extinguishers, and assist patients with limited mobility.

When a similar electrical short occurred at this second clinic, the fire was quickly detected and contained before it spread. Patients were evacuated calmly under the direction of trained fire wardens, equipment was safeguarded, and the facility resumed operations with minimal disruption. OSHA inspectors later reviewed the incident and found the clinic in full compliance, resulting in no penalties.

This comparison highlights how failing to implement even basic fire safety measures can lead to costly fines, reputational harm, and avoidable risks. Conversely, clinics that invest in proactive fire prevention not only avoid citations but also protect lives, property, and trust within their communities.

Common Pitfalls to Avoid Under 29 CFR § 1910.39

• No Written Plan: Relying solely on verbal instructions creates liability and violates OSHA requirements.

• Improper Storage of Flammables: Storing oxygen tanks or chemicals in unventilated areas increases fire risks.

• Unassigned Responsibilities: Without designated roles, staff may fail to act quickly during a fire.

• Neglecting Equipment Maintenance: Ignoring sterilizer or HVAC servicing can create ignition hazards.

• Lack of Training: Staff unfamiliar with fire prevention procedures are unable to act effectively in emergencies.

Avoiding these pitfalls strengthens compliance and reduces the likelihood of citations and accidents.

• Use OSHA’s Fire Prevention Plan templates to simplify documentation.

• Conduct monthly safety walks to identify and correct hazards.

• Partner with local fire departments for staff training and safety inspections.

• Keep fire extinguishers, alarms, and emergency lighting regularly inspected and maintained.

• Store all fire safety records in both digital and physical formats for quick retrieval.

Adopting these best practices ensures that small clinics meet OSHA standards while promoting a culture of safety.

Fire safety cannot be a one-time exercise, it must be integrated into everyday operations. Clinics can foster compliance by:

• Including fire prevention duties in job descriptions.

• Holding quarterly fire drills with staff and patients.

• Providing refresher training during staff meetings.

• Encouraging staff to report unsafe conditions immediately.

• Recognizing compliance champions to build team accountability.

Embedding fire safety into the organizational culture ensures that clinics remain prepared year-round.

OSHA’s Fire Prevention Plan requirement under 29 CFR § 1910.39 is critical for small clinics to protect patients, staff, and property from fire hazards. Compliance is straightforward when clinics document hazards, assign responsibilities, and provide staff training.

Advisers: Small practices can benefit from affordable compliance software that tracks fire inspections, training sessions, and plan updates. Free resources from OSHA, HHS, and OCR also provide practical tools and templates to help clinics implement compliant Fire Prevention Plans without high costs. Leveraging these resources ensures that even small facilities can maintain full compliance while safeguarding their operations.

• 29 CFR 1910.39, Fire Prevention Plans (eCFR)

• OSHA Fire Safety, Overview

• HHS Office for Civil Rights, Emergency Preparedness Guidance