1910.165(d): Employee Alarm Maintenance and Testing
Employers must keep employee alarm systems in operating condition except during repairs, test non-supervised systems every two months using a different actuation device each time, keep power supplies fully operational, and provide backup alarm means like runners or telephones when systems are out of service. Supervised circuitry installed after January 1, 1981 must be supervised and tested at least annually, and service must be done by trained persons.
Key takeaways
- 1910.165(d) is part of OSHA's general industry standards (29 CFR Part 1910, Subpart L).
- OSHA cited it 35 times in the last 3 years, in 33 inspections, with $189,341 in current penalties.
- 1 death is linked to inspections that cited this rule.
- Most citations: CA (11), CO (4), NY (3).
- Related part: 1910.165(d)(1) (28 citations).
- Free 5-minute toolbox talk for your crew below.
In this article
What this rule covers
29 CFR 1910.165(d) ("Maintenance and testing") is one requirement inside 1910.165 Employee alarm systems, an OSHA general industry standard (Part 1910, Subpart L). It includes 5 sub-paragraphs. The official text below is copied word for word from the Electronic Code of Federal Regulations (eCFR). The numbers, injury cases and training on this page show how OSHA enforces it on real job sites.
Official text
(d) Maintenance and testing. 35 citations
(1) The employer shall assure that all employee alarm systems are maintained in operating condition except when undergoing repairs or maintenance. Open (d)(1) 28 citations
(2) The employer shall assure that a test of the reliability and adequacy of non-supervised employee alarm systems is made every two months. A different actuation device shall be used in each test of a multi-actuation device system so that no individual device is used for two consecutive tests. 3 citations
(3) The employer shall maintain or replace power supplies as often as is necessary to assure a fully operational condition. Back-up means of alarm, such as employee runners or telephones, shall be provided when systems are out of service. Open (d)(3) 3 citations
(4) The employer shall assure that employee alarm circuitry installed after January 1, 1981, which is capable of being supervised is supervised and that it will provide positive notification to assigned personnel whenever a deficiency exists in the system. The employer shall assure that all supervised employee alarm systems are tested at least annually for reliability and adequacy. 1 citations
(5) The employer shall assure that the servicing, maintenance and testing of employee alarms are done by persons trained in the designed operation and functions necessary for reliable and safe operation of the system.
Source: eCFR, text current as of 2026-10-15. Read all of 1910.165.
Injuries linked to this rule
1 death is linked to inspections where OSHA cited 1910.165(d).
At 2:40 p.m. on May 17, 2024, Employee #1 was working in the Mud Recovery Tank (MRT) area, monitoring the shakers and the volumes of other tanks as materials were transferred from the truck off-load area. A co-worker was nearby in the washout bay, unhooking…
Where and how often it was cited
| Year | Citations |
|---|---|
| 2023 | 3 |
| 2024 | 13 |
| 2025 | 11 |
| 2026 | 8 |
Top states: CA (11), CO (4), NY (3), VA (3), IA (3)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| KRAFT HEINZ | MUSCATINE, IA | $110,000 |
| ROCKY MOUNTAIN METAL CONTAINER | GOLDEN, CO | $30,000 |
| THATCHER COMPANY, INC. | SALT LAKE CITY, UT | $14,000 |
| VALENCE SURFACE TECHNOLOGIES. LLC | GROVE, OK | $7,000 |
| PMX INDUSTRIES, INC. | CEDAR RAPIDS, IA | $6,500 |
Free toolbox talk
A 5-minute crew talk on 1910.165(d), plus alerts when this rule changes. Free.
OSHA interpretation letters
- Employee emergency alarm systems. (1991-01-23)
- Supervised manual fire alarm systems. (1981-06-26)
Related parts of this rule
- 1910.165(d)(1) 28 citations
- 1910.165(d)(3) 3 citations
Get your crew competent
Trainers on Black Belt Safety: Marc Harvey, Dana Reyes
Trainers and suppliers: feature your business on this rule for $25/month.
Frequently asked questions
How often must non-supervised alarm systems be tested?
Every two months, using a different actuation device in each test of a multi-actuation system.
What if the alarm is out of service?
Back-up means of alarm, such as employee runners or telephones, shall be provided.
How often must supervised alarm systems be tested?
At least annually for reliability and adequacy.
About this page
Sources
- 29 CFR 1910.165 (eCFR), text current as of 2026-10-15
- U.S. Department of Labor enforcement data: OSHA inspections, citations and accident records, copied nightly; data as of 2026-10-22
3-year window. Federal OSHA only; state-plan rules are not counted. Plain-language text is a summary, not legal advice; the official text controls. Black Belt Safety is not part of OSHA or the Department of Labor.