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Flammable Liquid Storage and Handling

Quick Tips #179
Introduction

Since the advent of the industrial revolution, the use of non-water-based chemicals has increased dramatically. Exposure to the hazards associated with these chemicals has also increased.

One potential hazard is flammability. To prevent fires, hazardous liquids require special precautions in storage, handling and use. The National Fire Protection Association (NFPA) and the International Code Council (ICC) have developed guidelines for the safe storage and use of flammables under the Uniform Fire Code. These guidelines are not mandatory unless a federal, state or local authority chooses to adopt them.

However, mandatory regulations have been developed by the Occupational Safety and Health Administration (OSHA) under separate regulations for:

  • General industry (29 CFR 1910.106)
  • Construction industry (29 CFR 1926.152)
  • Shipyard industry (29 CFR 1915.36)

For the purpose of this document, only the requirements of the General Industry standard will be discussed.

Defining Flammables

To understand the OSHA requirements for the safe storage of flammables, we must first define flammable. The flashpoint and boiling point determine the category of a flammable liquid. Flashpoint is the minimum temperature at which a liquid gives off enough vapor to form an ignitable mixture with air near the surface of the liquid.

A flammable liquid is any liquid having a flashpoint at or below 199.4°F (93 °C). Flammable liquids are divided into four categories:

  • Category 1: Liquids with flashpoints below 73.4°F (23°C) and boiling points at or below 95°F (35°C) (1910.106(a)(19)(i)). Examples: acetaldehyde and ethyl ether.
  • Category 2: Liquids with flashpoints below 73.4°F (23°C) and boiling points at or above 95°F (35°C) (1910.106(a)(19)(ii)). Examples: acetone, benzene and toluene.
  • Category 3: Liquids with flashpoints at or above 73.4°F (23°C) and at or below 140°F (60°C). When a Category 3 liquid with a flashpoint at or above 100°F (37.8°C) is heated for use to within 30°F (16.7°C) of its flashpoint, it must be handled in accordance with the requirements for a Category 3 liquid with a flashpoint below 100°F (37.8 °C) (1910.106(a)(19)(iii)).
  • Category 4: Liquids having flashpoints above 140°F (60°C) and at or below 199.4°F (93°C). When a Category 4 flammable liquid is heated for use to within 30°F (16.7°C) of its flashpoint, it must be handled in accordance with the requirements for a Category 3 liquid with a flashpoint at or above 100°F (37.8°C) (1910.106(a)(19)(iv)). When a liquid with a flashpoint greater than 199.4 °F (93 °C) is heated for use to within 30 °F (16.7 °C) of its flashpoint, it must be handled in accordance with the requirements for a Category 4 flammable liquid (1910.106(a)(19)(v)).

Whether liquids are Category 1 or 4 is not the only factor you should consider when determining safe storage needs. You also need to consider ignition temperature, lower and upper explosive limits (LEL or UEL), vapor pressure, and specific gravity and vapor density when designing a storage system.

One technique to help reduce the hazards associated with flammables is the use of safety cans. OSHA defines a safety can as "an approved container, of not more than 5 gallons capacity, having a spring-closing lid and spout cover and so designed that it will safely relieve internal pressure when subjected to fire exposure" (1910.106(a)(29)).

This definition allows a wide variety of containers to be considered safety cans. However, many local laws and insurance carriers require safety cans to be Factory Mutual (FM) or Underwriter Laboratory (UL) approved. These two organizations are nationally recognized, independent testing laboratories to which manufacturers submit products for evaluation of their ability to meet safety requirements under intended use. Products that meet the requirements are given either a UL or FM approval. Both laboratories are also recognized by OSHA. (For more information on these organizations, see Quick Tips #100: Understanding ANSI, ASTM International, FM Global, NFPA, SEI, UL and CSA Group.)

In addition, 29 CFR 1910.106 limits the maximum size of containers and portable tanks for flammable liquids. The following chart shows the allowable amounts for each category of liquid.

Container Type   Category 1   Category 2   Category 3   Category 4
Glass or approved plastic   1 pint   1 quart   1 gallon   1 gallon
Metal (other than DOT drums)   1 gallon   5 gallons   5 gallons   5 gallons
Safety Cans   2 gallons   5 gallons   5 gallons   5 gallons
Metal Drum (DOT specifications)   60 gallons   60 gallons   60 gallons   60 gallons
Approved portable tank   660 gallons   660 gallons   660 gallons   660 gallons

Medicines, beverages, foodstuffs, cosmetics and other common consumer products when packaged according to commonly accepted practice are exempted from these approved container and portable tank requirements.

Another fundamental means of fire protection is the use of flammable storage cabinets. The NFPA, OSHA and Uniform Fire Code (UFC) require flammable cabinets to be designed and constructed to specific requirements. Per 1910.106(d)(3)(ii), storage cabinets must be designed and constructed to limit the internal temperature to not more than 325°F when subjected to a 10-minute fire test and the cabinets must be labeled in conspicuous lettering, "Flammable - Keep Fire Away." 1910.106(d)(3)(ii)(a) states that metal cabinets must be constructed in the following manner:

  • Bottom, top and sides of cabinet must be at least No. 18-gauge sheet iron
  • Cabinet must be double walled with one and one-half inch airspace
  • Joints must be riveted, welded or made tight by some equally effective means
  • Door must have a three-point latch
  • Door sill must be raised at least two inches above the cabinet bottom to retain spilled liquid within the cabinet

These regulations also provide an option for wood cabinets. 1910.106(d)(3)(ii)(b) states that wood cabinets must be constructed in the following manner:

  • Bottom, top and sides of cabinet must be constructed of exterior-grade plywood at least one inch thick
  • Plywood must not break down or delaminate under fire conditions
  • Joints shall be rebutted and fastened in two directions with flathead wood screws
  • When more than one door is used, they must have a rebutted overlap of not less than one inch
  • Hinges must be mounted in such a manner as not to lose their holding capacity due to loosening or burning out of the screws when subjected to the fire test

In addition to the requirements listed above, the UFC also requires self-closing doors. Most local authorities use one or more of these standards as a foundation for establishing local codes.

29 CFR 1910.106(e)(2)(ii)[b] limits the quantity of liquids that may be kept outside of an inside storage room or storage cabinet in a building or in any one fire area of a building. These limits are only applicable to those portions of an industrial plant where the use and handling of flammables is only incidental to the principal business. The quantity of liquid that may be stored outside of an inside storage room or storage cabinet in a building or in any one fire area of a building cannot exceed:

  • 25 gallons of Category 1 liquids in containers
  • 120 gallons of Category 2, 3 or 4 liquids in containers
  • 660 gallons of Category 2, 3 or 4 liquids in a single portable tank

The amount of flammable liquid storage and location of cabinets are also regulated. 1910.106 (d)(3)(i) states, "Not more than 60 gallons of Category 1, 2 or 3 flammable liquids, nor more than 120 gallons of Category 4 flammable liquids may be stored in a storage cabinet." Also, according to NFPA 304.3.2, not more than three such cabinets may be located in a single fire area.

Areas in which flammable liquids are transferred from one container to another must be separated from other operations by adequate distance or by construction having adequate fire resistance (1910.106(e)(2)(iii)).

Category 1 or 2 flammable liquids, or Category 3 flammable liquids with a flashpoint below 100 °F (37.8°C), must be kept in covered containers when not actually in use (1910.106(e)(2)(iv)(a)). Category 1 or 2 flammable liquids, or Category 3 flammable liquids with a flashpoint below 100°F (37.8°C), may be used only where there are no open flames or other sources of ignition within the possible path of vapor travel (1910.106(e)(2)(iv)(c)).

Fire Areas

Both OSHA (1910.106(a)(12)) and NFPA (Code 30 (3.3.2.2)) define a fire area as, "An area of a building separated from the remainder of the building by construction having a fire resistance of at least one hour and having all communicating openings properly protected by an assembly having a fire resistance rating of at least one hour."

The NFPA also provides a special provision for the grouping of flammable cabinets in an industrial facility. Because most industrial settings do not have walls or barriers within a facility, "In an industrial occupancy, additional cabinets may be located in the same fire area if the additional cabinets, or the group of not more than three (3) cabinets, is separated from the other cabinets or group of cabinets by at least 100 feet (30 m)" (4.3.2 Exception 1).

Commonly Asked Questions
 
Q. When dispensing flammables, do I have to use bonding and grounding wires?
A. According to 1910.106(e)(6)(ii), Category 1 or 2 flammable liquids or Category 3 flammable liquids with a flashpoint below 100°F (37.8°C) are required to be bonded and grounded. However, for your own safety, bonding and grounding should always be used when dispensing flammable liquids. For more information, see Quick Tips #255: Bonding and Grounding.
 
Q. Am I required to have a flammables storage cabinet?
A. OSHA does not require the use of flammable storage cabinets unless the total amount of flammables reaches a given amount. Local authorities and insurance companies may require the use of flammable storage cabinets in quantities less than that of OSHA.
 
Q. What is the difference between Type I and Type II safety cans?
A. A Type I safety can has one spout for both pouring and filling. A Type II safety can has two openings: one for pouring and one for filling.
 
Q. What is a flame arrestor, and what purpose does it serve?
A. A flame arrestor is a mesh or perforated metal insert within a flammable storage container (safety can, cabinet) that protects its contents from external flames or ignition. It also dissipates heat. All Type I, Type II, disposal and specialty cans include a flame arrestor.
 
Q. Are flammable cabinets required to have mechanical ventilation?
A. OSHA does not normally require the use of mechanical ventilation. The NFPA recommends that cabinets not be mechanically ventilated, but if they are, they should be ventilated in accordance to NFPA 91 Exhaust Systems for Air Conveying of Materials. For more information, see Quick Tips #215: Flammable and Chemical Storage Cabinet Ventilation.
 
Sources

National Institute of Occupational Safety & Health, Pocket Guide to Chemical Hazards.

U.S. Department of Health and Human Services. Washington: GPO 2005.

National Fire Protection Association, Flammable and Combustible Liquids Code Handbook. Sixth edition, ed. Robert Benedetti, 1996.

Occupational Safety and Health Administration (OSHA) 29 CFR 1910.106 Flammable Liquids

Related Articles:

(Rev. 4/2016)


Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at www.grainger.com/quicktips.

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Please Note:
The information contained in this publication is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This publication is not a substitute for review of the current applicable government regulations and standards specific to your location and business activity, and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.


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