What hydro test interval do you use for ABC and BC dry chemical stored-pressure fire extinguishers with mild steel shells on RR vehicles (locos, passenger cars, MOW equipment)?

The reason I'm asking:

NFPA 10 is the de facto national standard. But California Code of Regulations 19 CCR § 592.3 requires a much shorter hydrostatic test interval for FEs on vehicles:
NFPA 10, Table 8.3.1: Hydrostatic test interval = 12 years
19 CCR § 592.3 Vehicles Hydrostatic test interval = 5 years

I couldn't find anything in 49 CFR 229 Railroad Locomotive Safety Standards and 49 CFR 238 Passenger Equipment Safety Standards about fire extinguisher hydro test intervals. Do you know of any FRA or other Federal regulation that specifies hydro test interval for these FEs?

Thanks!
- Doug Debs
Hazmat Mgr, Niles Canyon Railway
Sunol, CA 94586
cell 650-704-1487

I haven't found any certification intervals in the FRA CFRs. I don't know how CA works these days, I haven't lived there for a long time. We have our local Orrville, OH fire department inspect, certify and tag ours for the next due date. I don't exactly recall - I don't have one handy - but I think it's five years. We just gather them up when the tags are up, haul them over and get them back or get replacements when required.

There are no specification or regulations by FRA regarding specifications on fire extinguishers. Check OSHA 1910.157 - Portable fire extinguishers.

MDR

Hi Doug,
What a rabbitt hole you fell into! (I got pushed into the PFE hole a few years ago)

As far as I know most fed regs follow NFPA 10 including OSHA for general industry and construction. MSHA too, however MSHA wants an internal inspection annually not every 6 years. No different frequency for hydro.
Could not find anything either in the avaition regs for hydro.
Nothing for hydro of PFE's on over the road vehicles in the fed regs (just talks about got to have one, size, maintained, & inspected).

A couple of other notes, Avaition doesn't want ABC extinguishers in or around aircraft
seems the ABC chemical is very fine, gets into structural joints or sheet metal to structural members, and when absorbs moisture becomes corrosive to aluminum.

As far as state fire martials go, here in Nevada, as we are a mining state, Nevada wants an internal examination every year (following MSHA). Hydro frequency is NFPA 10.

I think you are in a good place for the on rail equip, as I recall NCRY is reg by FRA.
You might reach out to a CA commercial motor vehicle inspector and ask their opinion for CMV's if they get sucked into the SFMO's regs.

Good luck!

C W

Regardless of any regulation, your extinguisher will fail if it is past the manufacture expiration date. The smaller ones that really don't get recharged have one stamped on the shell. These are the ones typically in fleet commercial vehicles-the kind Amazon or AT&T or whoever installs to meet federal regulations.

I would have to agree with CW. Follow NFPA 10 including OSHA for general industry. That is what railroads (FRA regulated or not) would fall under.

MDR

FYI: Niles Canyon Railway standard fire extinguisher plan:

Diesel Locomotives
Cab: BC or ABC, 10# or 20#
Diesel engine & electrical generator hood: BC, one 20# on each side
(BC to prevent corrosion damage to electrical generator, high-voltage relays, etc)

Steam Locomotives
Cab: ABC, 10# or 20#

Passenger Cars
ABC, 5# or 10#

MOW Equipment
ABC, 5# or 10#
or in a few cases
Water, stored-pressure, 2.5 gallon

- Doug Debs

The NCRy team looked further into California Code of Regulations Title 19, and found:

https://regulations.justia.com/states/california/title-19/division-1/chapter-3/article-2/section-557-22/
19 CCR § 557.22. “V” Definitions
(c) Vehicle. For the purposes of this Chapter, as defined in Vehicle Code Section 670 and includes vessels as defined in Harbors and Navigation Code Section 651, and aircraft as defined in Public Utilities Code Section 21012.

https://law.justia.com/codes/california/code-veh/division-1/section-670/
California Vehicle Code § 670 (2025),
670. A “vehicle” is a device by which any person or property may be propelled, moved, or drawn upon a highway, excepting a device moved exclusively by human power or used exclusively upon stationary rails or tracks.

Conclusions:
19 CCR § 592.3 Vehicles does not apply to railroad equipment that only be operated on railroad track.

- Doug Debs