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Are there any regulations that require the storage of flammable/hazardous chemicals in a locked cabinet?

Ask The Expert, March 10, 2004

 

The applicable standards governing storage of flammable chemicals are NFPA 30 Flammable and Combustible Liquids Code (2003 Edition) and the OSHA standards under 29 CFR 1910.106.

Interestingly enough, relative to storage cabinets, the language in NFPA 30 and 29 CFR 1910.106 (section (d), part (3) for the specifics) is very similar. It is almost identical with one small, but important exception, at least in terms of your question. NFPA 30 requires flammable storage cabinets to have the following:

(a)   The bottom, top, door, and sides of the cabinet shall be at least No. 18 gauge sheet steel and shall be double-walled, with 38 mm (1.5 in) air space.

(b)   Joints shall be riveted, welded, or made tight by some equally effective means.

(c)   The door shall be provided with a three-point latch arrangement, and the door sill shall be raised at least 50 mm (2 in) above the bottom of the cabinet to retain spilled liquid within the cabinet.

In addition, 29 CFR 1910.106(d)(3)(a) states:

Metal cabinets constructed in the following manner shall be deemed to be in compliance. The bottom, top, door, and sides of cabinet shall be at least No. 18 gage sheet iron and double walled with 1.5-inch air space. Joints shall be riveted, welded or made tight by some equally effective means. The door shall be provided with a three-point lock, and the door sill shall be raised at least 2 inches above the bottom of the cabinet.

Very similar, don't you think? But look at the last proviso-where NFPA 30 looks for a three-point latch arrangement, 29 CFR 1910.106 calls for a three-point lock. I don't believe that I've ever run into a flammables cabinet that could not be locked, and my usual rule of thumb is if it has a lock on it, the intention is for it to be locked, but there seems to be contemplation of a risk assessment process. 

In looking through the rest of 29 CFR 1910.106 for references to security concerns, there is a limited palate to review. For storage inside buildings (d) (5), there are no specific security requirements. Only when the topic turns to outside container storage is there a specific security reference: "Security. The storage area shall be protected against tampering or trespassers where necessary and shall be kept free of weeds, debris and other combustible material not necessary to the storage."

If your lab is reasonably secure (and I certainly hope that it is) and following a risk assessment, you can assure that you are not engaging in a practice that unduly elevates the risk associated with that practice, then you should be on solid ground. If you are still unsure, you might consult either your local OSHA office and/or your local authority having jurisdiction (AHJ)--generally, your local fire department's prevention/safety officer-for their opinions. Ultimately, it's your AHJ who has the final say in matters of fire safety, so involving the AHJ in the front end of the process might well be your best bet.

Ask the Expert features advice from Steven MacArthur, a safety consultant with The Greeley Company in Marblehead, MA. If you have additional questions or require further information, please feel free to contact him at smacarthur@greeley.com