Common Compliance Failures

Real and representative examples of the deficiencies fire marshals, AHJs, and CMS surveyors actually flag. Each entry lists the citation, the severity, and the practical fix. Use this with the Compliance Walk-Through for a pre-inspection sweep.

10 of 10 findings

MAJOR

Portable extinguishers

Fire extinguisher blocked by storage

Pallets / boxes / racks stacked in front of the wall-mounted extinguisher, preventing access in an emergency.

CITATION

NFPA 10 §6.1.3 + 29 CFR 1910.157(c)(1) — extinguishers must be visible and accessible; OSHA expects 'no obstruction' to access.

FIX

Mark the floor with red tape at a clear 36-inch radius around each extinguisher and brief supervisors. Inspect monthly per §7.2.

Fire Extinguishers (NFPA 10) →

MAJOR

Portable extinguishers

Expired or missing annual maintenance tag

Annual external maintenance tag is older than 12 months from inspection date — or missing entirely. Most-cited NFPA 10 finding in CMS, TJC, and AHJ inspections.

CITATION

NFPA 10 §7.3.1 (annual external maintenance) + §7.3.2 (record requirements). Tag must show date, technician, license, and next-due date.

FIX

Schedule annual service with a Georgia-licensed FSP firm; verify tag at delivery; add the date to your monthly inspection checklist.

GA recharge vendors + inspection rules →

CRITICAL

Electrical safety

Storage blocking 36-inch electrical panel clearance

Storage drifts in front of the panel over time. NFPA 70E + NEC 110.26 require 36 inches of clear depth in front of any panel rated 600V or less to allow safe operation and emergency response.

CITATION

NFPA 70 (NEC) §110.26(A)(1) + NFPA 70E §130 + OSHA 29 CFR 1910.303(g)(1)(i).

FIX

Mark the 36-inch zone on the floor with red tape; declare it a no-storage zone enforced by daily walks. The supervisors will fight it; do it anyway.

NFPA 70E — Electrical Safe Work →

CRITICAL

Passive fire protection

Fire door propped open with a wedge

Wedge / chock / chair holding a self-closing fire door open defeats the entire purpose of the rated assembly. The door cannot close on smoke or fire; the rated wall is functionally a regular wall.

CITATION

NFPA 80 §6.1.1.4 (self-closing requirement) + NFPA 101 §7.2.1.8 (no impediment to self-closing). CMS K-Tag K-372 / K-211.

FIX

Replace wedges with magnetic hold-open devices tied into the FACP, OR remove the wedges and let the door close. Brief staff that wedging a fire door is never permitted.

Fire Doors (NFPA 80) →

MAJOR

Sprinkler systems

Storage within 18 inches of sprinkler heads

The 18-inch clear space below sprinklers (commonly called the '18-inch rule') exists so the discharge pattern can develop without being blocked by storage. Pallet racks creep up over time.

CITATION

NFPA 13 §10.2.6.3 (general 18-inch rule) — note: storage occupancies have specific clearance tables in NFPA 13 Ch 25.

FIX

Mark a high-line on the rack uprights at 18 inches below sprinkler deflector. Inspect quarterly; rotate stock down when the rack creeps up.

Sprinkler Heads + 18-inch rule →

CRITICAL

Egress & life safety

Egress path blocked by storage or carts

Required corridor width reduced below code minimum by carts, equipment, or stored supplies. In healthcare, both K-Tags and CMS surveys cite this aggressively; in retail and assembly, IFC §1031 applies.

CITATION

NFPA 101 §7.1.10 (means of egress unobstructed) + CMS K-Tag K-211 / K-225. IFC §1031 for non-healthcare.

FIX

Mark corridor floors with permanent tape showing the required clear width. Brief staff that ANY cart or equipment outside the marked zone is non-compliant. Repeat the message until it sticks.

Healthcare occupancy egress →

MAJOR

Sprinkler systems

Missing spare sprinkler cabinet

NFPA 13 + NFPA 25 require a spare sprinkler cabinet stocked with 6 / 12 / 24 spares (depending on system size) plus a wrench. Frequently missing on older buildings or after a renovation.

CITATION

NFPA 13 §16.2.7 (installation requirement) + NFPA 25 §5.2.1.1.1 (must be present at ITM).

FIX

Order a stocked cabinet from your sprinkler contractor; mount near the system riser; verify spare types and temperatures match what's installed.

Spare Sprinkler Cabinet →

MAJOR

HazCom

Spray bottle / secondary container with no GHS label

Spray bottle filled from a bulk supply with no GHS label. OSHA's #2 cited general-industry standard; the secondary-container gap is the most consistently missed labeling item.

CITATION

29 CFR 1910.1200(f)(6) — secondary container labeling. Allowed: full GHS label OR sufficient information identifying contents + hazard.

FIX

Establish a labeling protocol: every secondary container gets either the manufacturer's label OR a Samektra-style internal label with product name + GHS pictogram + signal word.

HazCom (29 CFR 1910.1200) →

MAJOR

Egress & life safety

Handrail damaged, missing, or below required height

Handrails on stairways must be continuous, between 34" and 38" above the nosing, and capable of withstanding a 200-lb load. Damaged or missing handrails are a fall-protection violation in any occupancy.

CITATION

NFPA 101 §7.2.2.4 (handrails) + IBC §1014 + 29 CFR 1910.29(f) (general industry).

FIX

Repair or replace damaged sections; verify height with a tape; verify return-to-wall at top and bottom; document in the inspection log.

Fall Protection Guide →

MAJOR

Sprinkler systems

Fire pump weekly run-test not documented

NFPA 25 requires weekly run-tests of electric fire pumps and weekly visual inspections of diesels. Tests get done but the log gets lost; the missing log IS the violation.

CITATION

NFPA 25 §8.3.2 (electric pumps weekly) + §8.3.3 (diesel pumps weekly) + §8.3.5 (annual flow test).

FIX

Print the weekly test log and mount it in the pump room. The log itself is the deliverable; the AHJ checks the log, not the pump's memory.

Fire Pump →

Have a deficiency photo to add? Email it to stanley.samek@proton.me with the citation, severity, and what was wrong. The library grows from real field examples.