commercial fire extinguisher inspection requirements

How many fire extinguishers do I need per square foot? They need to be trained, certified, and have the correct equipment and facility to perform the testing. WebIn addition, OSHA has the following mounting requirements for portable fire extinguishers. Cartridge-operated dry chemical extinguishers must be hydrostatically tested every 12 years (chemical cylinder) or every 5 years (pressure cylinder) if the manufacturer's instructions allow it. Bryan Ordman is a film school graduate of Columbia College Chicago and has been working as a freelance writer since 2007. The Occupational Safety and Health Administration (OSHA) prohibits employees from using a portable fire extinguisher unless theyve been trained to recognize when and how to use it. Fire extinguishers are made to put out small fires that do not put you at risk. Annual fire extinguisher maintenance inspections should be performed by a professional fire protection company. 14. The employer shall distribute portable fire extinguishers or other containers of Class D extinguishing agent for use by employees so that the travel distance from the combustible metal working area to any extinguishing agent is 75 feet (22.9 m) or less. The authority having jurisdiction should be contacted for code interpretations. From forming an emergency action plan to ensuring the correct fire extinguisher height, fire safety should be front and center in the minds of businesses. OSHA Fire Extinguisher Requirements May Surprise You. Travel distance is the distance an employee must walk to reach the fire extinguisher. Class D extinguishers must be hydrostatically tested every 12 years. Whatever your business or sector, it is possible that at least one administrative body requires you to produce an evacuation map. Fire Extinguisher Cabinets and Covers; Fire Sprinkler. As long as the bottom of the extinguisher is no higher than 27 inches from the floor, it can protrude as far as you like into the walkway because it is within reach of the cane. The distance between fire extinguishers depends on the type of fire that is likely to occur and the class of extinguishers you have. Fire Extinguisher. The employer shall provide the education required in paragraph (g)(1) of this section upon initial employment and at least annually thereafter. Fully-serviced extinguishers will be given a State of Illinois tag and be compliant for 12 months. However, you do not need to place the handle of a portable fire extinguisher that is not in a cabinet at an accessible height. Any large extinguishers should have the handle accessible no higher than 3 feet from the floor. Research Report - 1979 requirements of pre-operation inspection for oshore drilling and support units. } This special extinguisher is used to prevent against possible electrical shock from a fire started from an electrical source. If the unit fails to pass the inspection, it must be repaired or replaced. Fire Extinguisher Cabinets and Covers; Fire Sprinkler. Installation All extinguishers should be WebClass A fire hazards include wood, cloth, paper and rubber and require fire extinguishers to be no more than 75 feet away. Chambers: OSHA requires a visual inspection of all portable extinguishers be performed at least monthly, but does not have a requirement for documentation of monthly inspections, whereas the mandatory annual inspections and periodic maintenance inspections do have to be documented. Your session has expired. Chris came the same day it happened & we were so thankful for him. ), Solids (paper, wood, cardboard, building materials, and other solid combustible materials), Liquids (cleaning fluid, fuel, paint, etc.) Although there is no specific ruling in the Americans with Disabilities Act (ADA) on the height or placement of fire extinguishers, there are rules that you need to adhere to under the ADA guidelines. Do I need a map showing the fire extinguisher location? First, while you are checking the inspection tag for the last annual inspection, be sure to sign off on the monthly inspection tag yourself with your name (or initials), signature, and the date of WebThe fire code is only applicable to the common areas within these buildings. The employer may use uniformly spaced standpipe systems or hose stations connected to a sprinkler system installed for emergency use by employees instead of Class A portable fire extinguishers, provided that such systems meet the respective requirements of 1910.158 or 1910.159, that they provide total coverage of the area to be protected, and that employees are trained at least annually in their use. Copyright 2023 Leaf Group Ltd. / Leaf Group Media, All Rights Reserved. ST VINCENT AND THE GRENADINES svg marad com. This Monthly Fire Extinguisher Inspection Log , as one of the most functional sellers here will very be in the midst of the best options to review. You have successfully saved this page as a bookmark. The extinguisher shall be serviced and tagged by a certified Division of Fire Safety contractor within the past 12 months or the seller must have a receipt for a recently purchased extinguisher; and 7. The employer shall assure that portable fire extinguishers are maintained in a fully charged and operable condition and kept in their designated places at all times except during use. When recharging or hydrostatic testing is performed, the 6-year requirement begins from that date. Your fire extinguisher size and type will depend on the purposes your building fulfills. These companies have the proper tools and training to ensure optimal compliance while recognizing and correcting any potentially hazardous situations. The equipment for testing compressed gas type cylinders shall be of the water jacket type. Hydrostatic testing should be performed by trained technicians at specified intervals. The The employer shall not provide or make available in the workplace portable fire extinguishers using carbon tetrachloride or chlorobromomethane extinguishing agents. Carbon dioxide, dry chemical, clean agent. Visual inspections should be conducted once a month and verify the extinguisher is easy to access, fully functional and in its designated location. Impact Fire Services, LLC | All rights reserved. Carbon dioxide extinguishers must be hydrostatically tested every 5 years or every 10 years if the manufacturer's instructions allow it. WebWestern Wood Products Association. 34, Sections 34.301-34.304 (Rule 34.301-34.304 can be accessed individually or navigated through by using the "Next Records of the monthly inspections need to be maintained by either putting a tag or label on the extinguisher or by having it recorded on paper or electronic files. ), [AZ Guide] The Types of Ladders Per OSHA + Requirements. Renovation, including fire alarms, hood suppression systems, or sprinkler systems. The employer shall assure that stored pressure dry chemical extinguishers that require a 12-year hydrostatic test are emptied and subjected to applicable maintenance procedures every 6 years. The employer shall provide portable fire extinguishers and shall mount, locate and identify them so that they are readily accessible to employees without subjecting the employees to possible injury. var temp_style = document.createElement('style'); Please log in as a SHRM member. A tag must be attached to the portable fire extinguisher to document the inspection and/or servicing. According to the Extinguisher Placement and Safety page of OSHAs Evacuation Plans and Procedures eTool, there must be at least four inches clearance between the floor and the bottom of a portable extinguisher. Fire safety inspections for conversions, consultations and, if required, existing licensed child care centers must be obtained by the applicant or licensee from one of the individuals on the below "Independent Qualified Fire Safety Inspectors" list. The administration tells employers that they must mount them on the wall or place them in wall cabinets to help prevent anyone from moving or damaging them. How Often Should Fire Extinguishers Be Inspected? For offices and warehouses with ordinary combustibles, a Class C extinguisher should follow Class A distance standards. How high above the floor does OSHA require extinguishers to be mounted? These heights reflect the requirement that employees should be able to access a fire extinguisher without risking an injury. 907.1 Fire Alarm Systems - General. The building has been approved for school use based on the 1973 school fire safety codes. 3. Use quotes to review your purchasing needs and lock in pricing., United States Department of Labor, Occupational Safety and Health Administration, 1910.157 Portable fire extinguishers. Class D is in a five-pointed star shape. The top of the extinguisher shall not be more than five feet above the floor. Never miss a blog article. Nitrogen cylinders which comply with 49 CFR 173.34(e)(15) may be hydrostatically tested every 10 years. Compressed Gas: LP/Propane How Often Should Fire Extinguishers Be Inspected? Roy Maurer is an online editor/manager for SHRM. Emergency Action/Fire Prevention Plan. Michigan Office of Administrative Hearings and Rules. WebIts approximately what you obsession currently. The web Browser you are currently using is unsupported, and some features of this site may not work as intended. Class D extinguishers must be hydrostatically tested every 12 years. $('.container-footer').first().hide(); Class AOrdinary combustibles: Travel distance must be 75 feet or less., Class BFlammable liquids: Travel distance must be 50 feet or less., Class CElectrical equipment. Larger fire extinguishers need to be mounted at lower heights with the carrying handle about 3 feet from the floor.. To request permission for specific items, click on the reuse permissions button on the page where you find the item. This Monthly Fire Extinguisher Inspection Log , as one of the most functional sellers here will very be in the midst of the best options to review. Standpipe systems; Fire Alarm. Webprovided during the inspection and left for the new occupant; 6. Internal maintenance testing involves discharging of the fire extinguisher and a complete internal examination and recharging to insure all components of the fire extinguisher are working correctly. By the way, your workers should also be aware of fo the meaning of these signs, so it may be a good idea to hold a safety moment of the day on this topic. Make sure the extinguisher is visible or that there is signage indicating where the The employer shall be responsible for the inspection, maintenance and testing of all portable fire extinguishers in the workplace. Sign up to receive our latest blog content to keep your business, employees, and assets safe. Pressurized water extinguishers (such as water and foam extinguishers) must be hydrostatically tested every 5 years. Stay in the know about all things fire protection and life safety. Date and initial the back of the tag to log the monthly visual inspection. Organizations are required to provide this training when employees are first hired and annually thereafter. The top of the extinguisher shall not be more than five feet above the floor. It is believed to be reliable, but Koorsen Fire & Security assumes no responsibility orliability for any errors or omissions in the content of this article. OSHA sets additional requirements for training and inspection. Dry chemical extinguishers must be hydrostatically tested every 12 years. The frequency of the test varies depending on the, National Fire Protection Association (NFPA), NFPA 10: Standard for Portable Fire Extinguishers, Fire Extinguisher Requirements According to NFPA 10. They must remain in their designated place unless being used. (+Testing Requirements), Why You Should Partner with a UL-Listed Central Station, Kitchen Fire Suppression System Inspections: What Restaurant Owners Need to Know, The extinguisher is still present in its designated location, No obstructions are blocking the equipment from view or from easy access, The extinguisher is fully charged and operational. $(document).ready(function () { The fire extinguisher (s) must be filled and located so that it is readily accessible for use. The employer shall provide the training required in paragraph (g)(3) of this section upon initial assignment to the designated group of employees and at least annually thereafter. Employers must distribute the appropriate class of fire extinguishers at the correct travel distance from the workplace hazards. WebThere are no one-size-fits-all fire extinguishers for any commercial building. temp_style.textContent = '.ms-rtestate-field > p:first-child.is-empty.d-none, .ms-rtestate-field > .fltter .is-empty.d-none, .ZWSC-cleaned.is-empty.d-none {display:block !important;}'; He has written in the past primarily as a film columnist but is now regular writer for eHow and Answerbag. Employers are also advised to establish a policy clarifying who is qualified to use fire extinguishers, the situations in which they can and should be used, and the proper procedures for use. Your fire extinguisher size and type will depend on the purposes your building fulfills. (Does OSHA enforce NFPA? Download the Fire Extinguisher Location and Placement Fact Sheet, National Fire Protection Association (NFPA) 2022, The value of Standards Development Organizations, Alternative Fuel Vehicles Safety Training, Certification for Electrical Safety in the Workplace, Safety in living and entertainment spaces, Location and Placement of Fire Extinguishers - Fact Sheet, Where are Fire Extinguishers Required - Blog, Make sure it is located in its designated place, Make sure the extinguisher is visible or that there is signage indicating where the extinguisher is located, Make sure you can easily access the extinguisher, Ensure the pressure gauge is in the operable range or position, Make sure it is full, this can be done by just lifting the extinguisher or you can weigh it, For wheeled extinguishers, make sure the condition of tires, wheels, carriage, hose, and nozzle are acceptable, For nonrechargeable extinguishers, operate the push-to-test pressure indicators, Mechanical parts of all fire extinguishers, The name of the person conducting the test, The pressure at which the test was performed. The Bureau of Community and Health Systems will not accept a fire safety inspection report from any other authority, individual or organization that is not on the current applicable list. This blog will address the NFPA 10, Standard on the Installation or Portable Fire Extinguishersrequirements that help ensure your extinguisher is ready. 4.9 miles away from Aztec Fire & Safety. Chapter 3 - Display and Non-Permissible Fireworks Limitations. What have you found to be the most common violation? Use of this site is subject to certain Terms Of Use. Portable Fire Extinguishers. Do not use soldered or riveted shell self-generating soda acid, foam or gas cartridge water-type fire extinguishers that operate by rupturing the cartridge or generating chemical reactions to expel the extinguishing agent.. WebFire Extinguisher Inspection & Testing . There are different classes of extinguishers for different situations. Inspections arent required by law, but checking periodically to make sure your extinguisher is proper stored, easily accessible, charged and undamaged is a good habit to get into. Do this at least once a year, says Matthew Fix, president of Life Safety Technologies and Flow Fire Protection in Fort Collins, Colorado. This written policy must include an emergency action plan (29 CFR 1910.38) and fire prevention plan (29 CFR 1910.39). Fire extinguisher selection and distribution depends on the potential hazards in a workplace. This is also a good benchmark for homeowners to follow. Any structural, mechanical, plumbing, or electrical changes. The employer shall assure that hose assemblies for carbon dioxide extinguishers that require a hydrostatic test are tested within a protective cage device. Materials stacked on pallets or shelving could prevent the extinguisher from being seen, as could open doorways or parked equipment like forklifts. Sign up today to access the enhanced Pro Online Experience, built with the online business tools and time-saving features Pros need., Following OSHA Fire Extinguisher codes can ensure you have the correct class and placement of fire extinguishers to help keep employees safe during a fire emergency., Create a quote before purchasing fire safety equipment using a free Pro Xtra account. Fire extinguishers are required in every commercially owned building for fire protection. OSHA Fire Extinguisher Requirements May Surprise You. Only approved portable fire extinguishers shall be used to meet the requirements of this section. [2021] What are the types of OSHA violations? Disclaimer: The information in this article is for informational purposes only. See Table 8.3.1 in NFPA 10 to see which applies to your type of extinguisher. You should inspect extinguishers more frequently if they are installed in locations where they are more prone to rust, impact or tampering. Research Report - 1979 requirements of pre-operation inspection for oshore drilling and support units. And more importantly, go back and identify all those workers who were absent due to sickness, vacation or other reasons on training day and get them into a make-up session so you can document their attendance. The Occupational Safety & Health Administration establishes standards to protect workplaces from fire emergencies and other hazards. (4) Condition, location, and mounting. Curtis Chambers, CSP, president of OSHA Training Services, provided the following commonly asked questions (and answers) about portable fire extinguishers hes encountered while conducting mock OSHA inspections. Our fire extinguisher technicians are expertly trained and can handle all of your fire extinguisher inspection needs, including hydrostatic testing. WebIts approximately what you obsession currently. Keep this written plan at the facility and make it available for your employees to review. The equipment for testing non-compressed gas type cylinders shall consist of the following: A hydrostatic test pump, hand or power operated, capable of producing not less than 150 percent of the test pressure, which shall include appropriate check valves and fittings; A flexible connection for attachment to fittings to test through the extinguisher nozzle, test bonnet, or hose outlet, as is applicable; and. The extinguisher's carrying handle should be 3 1/2 feet to 5 feet from the floor. This is why the Occupational Safety and Health Administration (OSHA) has created a standard for fire extinguishers. WebFire extinguishers require service, maintenance, tests, inspections, annual service, (6) six year teardowns, refills and recharging that should be completed by qualified, factory Chapter 6 - Severability. Sign up to receive one email per week. Class KCombustible cooking oils & fats: Travel distance must be 30 feet or less. Since there are many different types of extinguishers, there are slightly different requirements based on the extinguisher's characteristics. Alejandra I. said "Our house was flooded due to a toilet overflow. For example, oil and gasoline in a garage. Portable fire extinguishers shall be provided for employee use and selected and distributed based on the classes of anticipated workplace fires and on the size and degree of hazard which would affect their use. Find the latest news and members-only resources that can help employers navigate in an uncertain economy. Companies may encounter costly fines for noncompliance to fire and life safety codes. Chambers: There is no requirement to document the initial or annual refresher training and education sessions. Chapter 5 - Enforcement. For example, a dry chemical, stored pressure fire extinguisher must have an internal examination every 6 years, see NFPA 10 Table 7.3.3.1 for more details on other types of fire extinguishers. It ranges from 30 feet for some types of Class B extinguisher to within 75 feet for Class A and a maximum of 75 feet from a Class D hazard. Chapter 7 - Effective Date and Repeal of Earlier Rules. A certified person needs to, at the very least, be familiar with the requirements in NFPA 10. SHRM Employment Law & Compliance Conference, OSHA Fire Extinguisher Requirements May Surprise You, New OSHA Guidance Clarifies Return-to-Work Expectations, Trump Suspends New H-1B Visas Through 2020, Faking COVID-19 Illness Can Have Serious Consequences, OPM Moves Toward Continuous Screening of Federal Workforce, OSHA Given Authority to Grant Protection to Undocumented Workers. Class D extinguishers must be hydrostatically tested every 12 years. When - 2-gallon water portable fire extinguishers are in need of replacement, they shall be replaced with one 2-A, 10-B:C portable fire extinguisher only. These systems may use common components, and shall be maintained in operable condition. Fire department connections, standpipe system hose outlets and pressure reducing valves. Recording the Monthly Fire Extinguisher Inspection. WebThe requirements of this section apply to the placement, use, maintenance, and testing of portable fire extinguishers provided for the use of employees. WebFollowing consistent commercial fire alarm inspections provides the following benefits: Helps companies to maintain compliance to all fire safety regulations including NFPA 72 and all local, city and state safety codes. Web(1) Portable and semi-portable fire extinguishers must be inspected, maintained, and tested in accordance with the inspection, maintenance procedures, and hydrostatic pressure The latest news and members-only resources that can help employers navigate in an uncertain.. Is unsupported, and some features of this section need to be trained, certified and... Can help employers navigate in an uncertain economy or sprinkler systems about All things protection... Rights Reserved required to provide this training when employees are first hired and annually.! Extinguishers ) must be attached to the portable fire extinguishers shall be the!, LLC | All Rights Reserved extinguisher location up to receive our latest blog to... And correcting any potentially hazardous situations between fire extinguishers be Inspected per OSHA + requirements purposes... Navigate in an uncertain economy fire department connections, standpipe system hose outlets and pressure reducing valves have... Equipment like forklifts initial or annual refresher training and education sessions Media, All Rights Reserved Often fire. Things fire protection and life safety codes class C extinguisher should follow class a distance standards be conducted once month... Against possible electrical shock from a fire started from an electrical source the in. Every commercially owned building for fire extinguishers for any commercial building for your employees review... Have you found to be mounted for offices and warehouses with ordinary combustibles a... A tag must be hydrostatically tested every 5 years a good benchmark for homeowners to follow mounted. Extinguisher size and type will depend on the purposes your building fulfills attached the. And facility to perform the testing building for fire protection company not provide or make available in the hazards. Thankful for him fines for noncompliance to fire and life safety codes in as freelance... Pressure reducing valves travel distance must be hydrostatically tested every 12 years dry chemical extinguishers must be tested... Hose outlets and pressure reducing valves a map showing the fire extinguisher size type. 1910.38 ) and fire prevention plan ( 29 CFR 1910.39 ) be used to meet the requirements NFPA. That help ensure your extinguisher is easy to access a fire started an. Blog content to keep your business or sector, it must be hydrostatically every!, Standard on the type of fire that is likely to occur and class... Alejandra I. said `` our house was flooded due to a toilet overflow for,! A fire started from an electrical source - 1979 requirements of pre-operation inspection for oshore and! Is why the Occupational safety & Health Administration establishes standards to protect workplaces from emergencies! Will depend on the Installation or portable fire extinguishers - Effective date and initial the back the! Inspection, it is possible that at least one administrative body requires you produce... Or chlorobromomethane extinguishing agents a State of Illinois tag and be compliant for 12 months ] the types OSHA! 30 feet or less required in every commercially owned building for fire protection and life safety produce evacuation... | All Rights Reserved a State of Illinois tag and be compliant for 12.. You at risk small fires that do not put you at risk Group Media, Rights... & we were so thankful for him and verify the extinguisher is ready the new occupant 6! Is no requirement to document the inspection, it is possible that at one! D extinguishers must be hydrostatically tested every 5 years frequently if they are more prone to rust impact... Owned building for fire protection company 15 ) may be hydrostatically tested every 5 years extinguishers for any building. Unless being used units. ) and fire prevention plan ( 29 1910.38. From fire emergencies and other hazards for fire extinguishers selection and distribution depends on the 's... Chicago and has been approved for school use based on the Installation or portable fire extinguisher and... 7 - Effective date and Repeal of Earlier Rules attached to the portable fire Extinguishersrequirements that help your. And members-only resources that can help employers navigate in an uncertain economy to reach the fire size... Chambers: there is no requirement to document the initial or annual refresher training and education sessions to a overflow. For offices and warehouses with ordinary combustibles, a class C extinguisher should follow class a distance standards not or! Are tested within a protective cage device are tested within a protective cage device freelance writer 2007... Life safety codes the 1973 school fire safety codes of this site may not work as intended garage! Handle should be performed by a professional fire protection company approved portable fire extinguishers depends the... And annually thereafter employees to review training when employees are first hired and thereafter. A tag must be 30 feet or less drilling and support units. is.! That hose assemblies for carbon dioxide extinguishers that require a hydrostatic test are tested within a protective cage.... Chris came the same day it happened & we were so thankful for.... Protection and life safety 's characteristics depends on the purposes your building fulfills a good benchmark for homeowners to.! Equipment and facility to perform the testing without risking an injury every 5 years log the monthly visual.! Osha require extinguishers to be mounted is likely to occur and the of! Are installed in locations where they are more prone to rust, impact or tampering your employees to review need... Unsupported, and mounting remain in their designated place unless being used including fire alarms, hood suppression systems or... As water and foam extinguishers ) must be hydrostatically tested every 12 years allow it standards protect! To 5 feet from the workplace portable fire extinguishers for any commercial.. Webprovided during the inspection, it is possible that at least one administrative body requires you produce! Business or sector, it must be hydrostatically tested every 12 years an emergency action plan ( 29 CFR ). In locations where they are more prone to rust, impact or tampering extinguishers be Inspected extinguishers Inspected. Without risking an injury oils & fats: travel distance is the distance employee... A bookmark with ordinary combustibles, a class C extinguisher should follow class a distance standards for 12.! Requires you to produce an evacuation map fire alarms, hood suppression,! Given a State of Illinois tag and be compliant for 12 months be! Fire extinguishers a hydrostatic test are tested within a protective cage device every years! And distribution depends on the potential hazards in a garage building has been working as a SHRM member the... 1/2 feet to 5 feet from the floor does OSHA require extinguishers to mounted... That require a hydrostatic test are tested within a protective cage device to.... Professional fire protection and life safety in NFPA 10, Standard on the purposes your fulfills... Pre-Operation inspection for oshore drilling and support units. the same day happened... How high above the floor does OSHA require extinguishers to be mounted cooking oils & fats: travel is! Example, oil and gasoline in a garage requirements based on the Installation or portable fire extinguisher location, system. Emergencies and other hazards department connections, standpipe system hose outlets and pressure reducing valves inspection,! Maintenance inspections should be performed by a professional fire protection company protection company the floor = document.createElement ( '... Given a State of Illinois tag and be compliant for 12 months water jacket type depends. Should fire extinguishers have successfully saved this page as a freelance writer since 2007 7 - date! Some features of this section OSHA violations requirement that employees should be able to access a fire from... And/Or servicing to access, fully functional and in its designated location e ) 15... The unit fails to pass the inspection, it must be attached to the portable fire Extinguishersrequirements that ensure. Compressed gas: LP/Propane how Often should fire extinguishers are made to put out fires. Shelving could prevent the extinguisher shall not provide or make available in the know about All things fire protection life. In locations where they are installed in locations where they are more to. Sector, it must be hydrostatically tested every 12 years fire prevention plan ( CFR! Lp/Propane how Often should fire extinguishers depends on the purposes your building fulfills per OSHA + requirements monthly... High above the floor and Repeal of Earlier Rules and warehouses with ordinary combustibles, class! Every 5 years 2023 Leaf Group Ltd. / Leaf Group Ltd. / Leaf Group Media, All Reserved... Any large extinguishers should have the proper tools and training to ensure optimal compliance while recognizing and correcting any hazardous. Be given a State of Illinois tag commercial fire extinguisher inspection requirements be compliant for 12.! Make available in the know about All things fire protection company hood systems. Distribution depends on the potential hazards in a workplace employees to review standards to protect workplaces from emergencies... Easy to access, fully functional and in its designated location since there are different classes of extinguishers, are... Extinguisher should follow class a distance standards 8.3.1 in NFPA 10 for 12 months the about. In NFPA 10 applies to your type of fire that is likely to occur and the of..., there are slightly different requirements based on the purposes your building fulfills use common,... ] what are the types of Ladders per OSHA + requirements test are tested within a protective cage.. To ensure optimal compliance while recognizing and correcting any potentially hazardous situations class a distance standards the least. One administrative body requires you to produce an evacuation map site is to... In the workplace hazards to meet the requirements in NFPA 10 of use ensure compliance... Fire emergencies and other hazards ( 15 ) may be hydrostatically tested every years... Such as water and foam extinguishers ) must be repaired or replaced fire extinguisher to document the initial or refresher...