Flammable Liquids: What Can You Do With Them?
Too much material with too many vapors and too little ventilation will no doubt create too much of a "boom" that you do not want.
- By Randy DeVaul
- Dec 01, 2006
COMPLIANCE requirements for using and storing flammable liquids in the workplace are quite
detailed and specific. Unfortunately, the requirements are spread over a number
of agencies and multiple documents.
Occupational Safety & Health Administration provides the regulatory
requirement for the workplace in 29 CFR 1910.106. But the agency also adopts
and references other standards from other organizations (NFPA, NIOSH), in
addition to its multiple standards within 29 CFR related to storage and use.
Then, there are "secondary" standards requiring emergency plans,
evacuation maps, fire protection, and others because of having flammable liquids
in quantity on the premises. And don't forget the whole 29 CFR 1910.120
(HAZWOPER) requirements. For some facilities, there are also the local fire
marshal and/or fire protection plans to address, as well.
is no wonder that, despite all of the articles already written on flammable
liquids, people are still confused or, at best, in a quagmire about what to do
with the compliance requirements for this category of material. Attempting to
obtain all of the compliance requirements can be difficult. Once you purchase
the volumes of OSHA standards, you then have to purchase the NFPA standards.
Then you have to find time (and interpretation skills) to read all of the
volumes of material, including your ability to locate all of the applicable
standards scattered throughout those volumes. An online search can create
challenges if you don't use the right terminology in your search, so after
hours of either reading or searching, you just give up.
doubt there needs to be a simplified way to address this topic. Of course, we
don't want the government's version of "simplification." (Look at
what happens to tax laws when they are reviewed and overhauled.) Until
something all-inclusive comes along, we are left to our own defenses and
thoughts, hoping we are at least favorably looked upon for good-faith efforts
in the event of an unforeseen incident that attracts regulatory inspectors and
article is intended to provide you with some practical, real-world practices
while reviewing some of the more "elusive" regulatory requirements to
help you establish or review potential hazards from your employees'
perspective. A regulatory standard does not carry much meaning for an employee
who can't see the logic or the sense behind following it, but making the
message personal and understanding the hazards based on practices and
procedures will help the employee make smart choices that will also comply with
the standards--99 percent of the time.
let's start with the employee. When using a flammable liquid, what does an
employee need to know to protect his own personal safety and health? I'll start
with a flammable liquid's hazardous properties.
material is identified as "flammable" based on the material's ability
to create vapor and flash or ignite at certain temperatures, known as its
flashpoint. The flashpoint is defined as the minimum temperature at which a
material produces enough vapor that, when introduced to an ignition source,
will flash/burn. It will not necessarily sustain a flame, but it will ignite
and flash. It is the temperature that critically separates a material from
being extremely flammable, flammable, or combustible.
table shows the temperatures and examples that determine these categories:
= 200º F
Fuel (104-110º F)
employee using a flammable or extremely flammable liquid in the work process
must recognize and consider the product's flashpoint if using it in a high heat
or in an area in which there are ignition sources (welding, cutting, kilns,
of the low flashpoints, these materials also produce airborne vapors due to
relatively low boiling points. Vapors create a couple of hazards. It is the
vapor--not the liquid--that burns, so an increase in vapor increases the risk
of fire; and many of the vapors create health risks, such as inhaled
respiratory disorders, various cancers, and eye irritation, depending on the
material in use. In addition to the fire hazard from the flashpoint, an
employee can be exposed to double hazards during the use of these products that
may require respirators, direct ventilation, or other protection levels such as
the correct selection of hand protection.
using a flammable liquid, employees should keep the cover or lid on the material
when it is not in use. This helps to keep the vapors in check, the evaporation
of product down, and the health hazards minimized. Where the product will be
used also is a factor. Depending on the vapors and the location where flammable
vapor-air mixtures may exist, special electrical wiring requirements under
Subpart S of the OSHA standards must be addressed to prevent an explosion or
flame resulting from arcing or heat.
a Class 1 (such as gasoline) flammable liquid from one container to another
requires grounding the primary container and bonding the primary container with
the secondary container with a conductive wire to prevent or dissipate the
build-up of static electricity during the flow of the liquid.
of flammable liquids has been a point of discussion and confusion because so
much of the discussion centers more on opinion, "best practices," or
misinterpretation of the standards rather than the facts. For example, I
remember an outside consultant who came to our facility to help with a mock
OSHA audit and stated that all of our flammable storage cabinets were required
to be vented to the outside. To this day I do not know what his intention was
with that demand, but it certainly was not correct. Had we followed his
recommendation to vent the cabinets, we would have created a far greater hazard
with vapor exposures in high-heat, high-spark environments.
clarify that point, then, unless there is a local ordinance that requires
venting of flammable storage cabinets, there is no requirement. As a matter of
fact, the NFPA stated in a formal position letter that "The vents for
flammable liquids storage cabinets are not required or even recommended by our
Flammable and Combustible Liquids Code, NFPA 30. . . . "
of stored flammable liquids are regulated according to a number of factors:
inside vs. outside a storage cabinet, the classification of the flammable
liquid(s) being stored, and the amount(s) of each. For example:
Quantities Outside a Flammable Storage Cabinet or Inside Storage Room
and Container Type
Class IA Liquids in Containers
IB, IC, II or III Liquids in Containers
IB, IC, II or III Liquids in a Single Portable Tank
Quantities Inside a Flammable Storage Cabinet or Inside Storage Room
I or II
with the fire protection standards, there are also limits on the quantity of
cabinets you can store together within a facility. In a non-sprinkler-protected
area, there cannot be more than three flammable storage cabinets within a fire
area. Cabinets that can be separated by at least 100 feet of distance can be
stored in groups of three for each 100 feet of separation. In an automatic
sprinkler-protected area, six cabinets can be stored within a fire area.
case you are not familiar with a "fire area," it is defined as an
area of a building separated from the remainder of the building by special
construction. This area has a fire resistance of at least one hour and has all
communicating openings properly protected by an assembly that also has a fire
resistance rating of at least one hour.
a flammable storage cabinet must meet certain requirements. You cannot simply "designate"
a cabinet for storage of these materials. It must be designed and constructed
to meet the NFPA 30 requirements, including the ability to limit the internal
temperature to no more than 325° F from the center of the cabinet to within 1
inch of the top of the cabinet when subjected to a 10-minute fire test. Many of
the commercially constructed cabinets have self-closing doors in the event of a
fire to reduce its spread.
requirements may be a little deep for what I intended in this article, but
these are the areas where I have seen and heard confusion about what is and isn't
necessary for setting up a storage area or the type of equipment needed. Although
these requirements are based on compliance, certainly you can understand the
need for ensuring you don't create a bulk storage facility of flammable liquid
unless that is exactly your business. Too much material with too many vapors
and too little ventilation will no doubt create too much of a "boom"
that you do not want.
leads to portable containers that have flammable liquids. In a commercial or
industrial setting, you are not allowed to store flammable liquids in
plastic gas cans. A red plastic gas can with gas or another flammable liquid
stored in it that is seen by an inspector will guarantee you a citation. In
addition to the regulatory requirement, storing such material in this type of
container exposes your employees and your facility or equipment to a real fire
you ever seen your plastic gas can at home become heated and expand or bloat?
Have you ever lost the cap or cover to your plastic gas can at home and found
that all the gas evaporated into the air? If you have a gas water heater or
other spark producers nearby, this is not a good mix.
a commercial or industrial setting, such materials must be stored in safety
cans that meet certain design requirements: spring-loaded closure, mesh flash
guard, and pressure-relief mechanism in the event of elevated heat or fire.
These cans are intended for portable, temporary storage of flammable liquids
and are not designed to hold more than five gallons. One point of confusion
that I have seen is that this requirement is for flammable liquid, not
combustible liquid. Going back again to the flashpoints and categories of the
materials, this is an important distinction. Kerosene, diesel fuel, mineral
spirits, and other combustible liquids do not require the use of safety cans.
summarize, flammable liquids present real and potentially serious hazards in
both safety and health to employees. There are quantity limits based on how
flammable a material may be and requirements on how to store those quantities.
forget employee training. Training is a required and important element in keeping
employees safe in the use of these materials. From new-hire training to
specific task and refresher training, employees need to be reminded of the
hazards that are present with these materials and what they can and should do
or not do when handling or storing these materials. Training includes fire
drills, evacuation drills, reading Material Safety Data Sheets, use of fire
extinguishers, selection and use of personal protective equipment when
appropriate, and proper task performance.
are already legally responsible and accountable for ensuring your employees are
protected and that your work environment is free of recognized hazards. You as
an employer need to encourage your employees to actively participate in
locating and identifying workplace hazards so they can be properly and promptly
corrected. This includes employee practices through observation and monitoring,
as much as it does looking at processes and conditions.
job as a manager is to help your people be successful. Set your bar of expectations
high so your people have something to attain. They will follow if they know you
are sincere in your desire to have and maintain a safe working environment.
Remember, your minimum expectation will always be your employees' maximum
expectation. So give them a good target and help them hit the bull's-eye.
employees are your most valuable asset, and they have much more control in the
outcome of their own safety than they may think. Energize them to take that
control. As a result of their participation, you create a win-win environment
that guides your employees into working safely with flammable liquids.
This article appeared in the December 2006 issue of Occupational Health & Safety.
This article originally appeared in the December 2006 issue of Occupational Health & Safety.