Safe Use and Storage of
Flammable Liquids
Strategies for Protecting Workers and Your Facility
OSHA 1910.106, 1450 / 1926.152 Related Standards: 1910.1200, 1201
Flammable Liquid Landmines
• Common Errors Leading To BOOM! • Using an unmarked container. • Using an old anti-freeze or windshield wash jug. • Carrying containers on back of the truck, unsecured,rough
handling, rag in spout. • Carrying containers in passenger compartment. • Using or carrying containers missing proper closure (caps). • Filling containers on bed of truck. This can create static
electricity, esp. in low humidity.
“Pumping Gas”
NEVER leave the pump running unattended Do NOT rely on the auto shut-off – especially at off-market locations Keep nozzle in contact with tank fill pipe or container. This is grounding
discharge to dissipate static. Shut off engine. Avoid using a cell phone while pumping gas When exiting the vehicle, make sure to ‘touch metal’ to discharge static
electricity between you and the vehicle Be alert for any ignition hazards in the area – i.e. smokers Bonus Tip: carry a disposable glove or heavy grade tissue to handle the
icky pump nozzle Gas weighs 6.3 lbs. per gallon. 5 Gal. can = 34 lbs. Less than water, but
still hefty.
General ‘Best Practices’ For Flammable Handling
Check your storage and use areas for ignition sources. For example, a bare lightbulb in a tool shed with gas cans is probably
not a good idea. Electrical hardware must be approved for the location, i.e. vapor tight
fittings. Make sure housekeeping is good- no trip hazards, spill control gear
handy, lighting adequate, sufficient clearances, not blocking aisles, no excess combustibles, etc. How far to nearest extinguisher?
Check floor drains. Keep drain covers handy. Usually runs to a separator.
Explain ‘primary’ and secondary containment. Make sure your extinguishers are suited to the materials, properly sized,
etc. Train, instruct, teach, demonstrate, show & tell, translated, etc. to be
sure employees understand the characteristics of the material, how to use extinguishers, explain HazCom, etc.
Definitions of Key Terms
• Flash point: the minimum temperature at which a liquid gives off vapor in sufficient concentration to form an ignitable mixture with air near the surface of the liquid. The flash point is normally an indication of susceptibility to ignition.
• Combustible liquid: any liquid having a flash point at or above 100ºF.
OSHA- New Classes Of FL’s Class I Flammable Liquid: has a flash point below
100ºF Divided into three classes: Class IA: liquids having flash points below 73ºF and a
boiling point below 100ºF Class IB: liquids having flash points below 73ºF and a
boiling point at or above 100ºF Class IC: liquids having flash points at or above 73ºF
and below 100ºF
Examples of Flammable Liquids • Class IA • Ether (starting fluid)
• Class IB • Gasoline * Acetone • Ethanol • Alcohol
• Class IC • Mineral spirits • Turpentine
Combustible Liquids • Combustible liquid: any liquid having a flash point at or above 100ºF
Combustible liquids are divided into two classes as follows:
• Class II liquids: Flash points at or above 100ºF and below 140ºF • Class III liquids shall include those with flash points at or above 140ºF • Class III liquids are subdivided into two subclasses:
– Class IIIA liquids: Flash points at or above 140ºF and below 200ºF
– Class IIIB liquids - flash points at or above 200ºF
Examples of Combustible Liquids
• Class II ‐ Diesel Fuel, Paint Thinner • Class IIIA ‐ Home Heating Oil , Some
House Paint, Stains • Class IIIB ‐ Cooking Oils, Lubricating Oils,
Motor Oil , Plain Old House Paint
FLAMMABLE (EXPLOSIVE) LIMITS
• When vapors of a flammable or combustible liquid are mixed with air in the proper proportions in the presence of a source of ignition, rapid combustion or an explosion can occur.
• The proper proportion is called the flammable range or the explosive range. This range includes all concentrations of flammable vapor or gas in air, in which a flash will occur or a flame will travel if the mixture is ignited.
• There is a minimum concentration of vapor or gas in air below which propagation of flame does not occur on contact with a source of ignition. There is also a maximum proportion of vapor in air above which propagation of flame does not occur.
• These boundary-line mixtures of vapor with air are known as the lower and upper flammable limits (LFL or UFL) respectively, and they are expressed as their percentage by volume of vapor in air.
Basic Chemistry of Fire
• Simple tri-lateral equation.
• All three components must be present to create combustion.
What are LFL- UFL
• L = LOWER Flammable Limit (Not enough FUEL to ignite)
• U = UPPER Flammable Limit ( TOO MUCH fuel to support ignition)
• With gasoline for example, it does not take much vapor to reach the flammable range.
Define Your Purpose and Intended Use
• Incidental use – i.e. landscaping, mower and tool, equipment refueling
• Production Process – i.e. paint spray booth, Body Shop
• Bulk Storage – Tank Farms - Process Industries – Pipelines, etc.
• Limit your on hand inventory as much as practicable.
Quantity is Your Determining Factor • 60 gallons or more in one vessel is a storage TANK
• Common small daily use containers are usually in the 1 to 5 gallon range
• Larger quantities, i.e, 55 gallon drums will need special hardware – grounding lines, venting caps, self closing nozzles, etc.
• Flammable liquid storage rooms need special engineering – Warning labels; protection class rated, berms on floor and at entrance, exhaust ventilation at floor and ceiling levels, FR doors and materials, unpainted walls, explosion resistant electrics, non-sparking hardware, alarms and sprinklers, among other controls
Limited Quantity Storage Cabinets • 25 gal. or less does not need cabinet; i.e. spray
cans, incidentals • Cabinets should be properly grounded • Double walled, with air space, self extinguishing • Vented, depending on contents, with fire baffle • Self closing doors with latch engagement • Internal door sill to prevent spillage • Properly labeled – Pictorial Warning – “No Flame –
No Smoking” – Other Specific
OSHA 1926- Construction Standard • Not more than 60 gallons of Category 1, 2 and/or 3
flammable liquids or 120 gallons of Category 4 flammable liquids can be stored in one cabinet.
• Not more than three cabinets may be located in a single storage area.
• Quantities in excess of this must be stored in an inside flammable liquid storage room.
If You Use FL’s as a PROCESS, You Need A PROGRAM • Train & Equip employees for the correct handling & exposures. Have a wri?en
protocol in your safety manual describing all aspect of your use of flammables: Purchasing Receiving Transport Storage Handling Dispensing Recovery of spent liquids Disposal or recycling Disposal of empty containers Health monitoring for employees-‐ industrial hygiene VenElaEon systems for indoor spray applicaEons Monitoring for concentraEons of vapor Emergency Response & Fire – i.e. Industrial Fire Brigade formaEon
5 TONS of Flammable Product
• 10,000 lbs. of any flammable liquid places you into the Highly Hazardous Chemical Standard
• This triggers Process Safety Management Standard (PSM) compliance.
• Your Occupancy Permit will trigger numerous levels of inspection – OSHA, State & Local, Insurance, Customer and others.
OSHA Process Safety Management Standard
(PSM)
• PSM is required reading for anyone using 10,000 lbs. of flammable liquids in a process environment.
• The PSM Standard is a good tool to apply to any safety situation. It WORKS!
Process Safety Management Standard OSHA 1910.119
This is a very important standard, possibly one of the most far reaching in all of OSHA’s library. We can learn a lot from it, not only for HHC’s and flammables but for Safety Program Management generally. Among the more salient secEons: • Employee ParEcipaEon in your enEre chemical process • IniEal Process Hazard EvaluaEon, Pre-‐Start procedures • SOP’s, wriVen pracEces, specificaEons, i.e. Hot Work Permits • ‘Management of Change’ descripEon, responsibiliEes, funcEonal roles • Contractor Safety Management • ReporEng of Near Miss Events, anomalies, incident invesEgaEons • Regular review & update of the safety plan • hVps://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9760
Gasoline CANS vs. Plastic Jugs
• The DOT regulates what can be carried on a vehicle. They do not look kindly on plastic jugs.
• OSHA allows practically anything as long as it is compatible with the liquid.
• Don’t be surprised if you get pulled over on a DOT roadside inspection and get cited for carrying a plastic gas jug, even though the OSHA guy didn’t write it up.
• All containers MUST be clearly labeled with contents.
Safety ‘Cans’ – Some are High Dollar • Depending on your use, you may need
some expensive hardware. • General Rule: The more volaEle the
liquid, the more complex and expensive the handling & hardware.
• For example: stainless steel cans, self closing, baffled, arrestor spout, raised rim, vented can easily cost over $100. You want to be sure this can does not get banged around carelessly
• Shop cloth & towel disposal cans • Parts washers should have self closing lid
on a fire link, although most solvents have been changed over to a citrus based aqueous fluid.
Container Pictorial - GHS
• Unmistakable • Universal • Non-Verbal • Easy to Recognize • Required By OSHA & DOT • Exxon SDS for Gasoline: • www.msds.exxonmobil.com/IntApps/psims/SearchResults.aspx
Use of Burn Blankets
• Cool the burn quickly by removing heat from tissue
• Avoid contamination of broken skin, bacteriostatic
• Long shelf life • Minimal inspection requirement • Also can be used as an extinguishing
agent in some cases
How to Safely Dispense A Hazardous Liquid
• First, use ‘Engineering Methods’ to make the transfer as contained and safe as possible. Look for ways to eliminate need for pouring.
• Position the containers and your body where you have good control over the pouring. Examples are trying to fill a chain saw on the ground. Use smallest container available.
• Use a funnel or other hardware to be sure the liquid goes where you want it. Do not stand directly over the pour. Blowback.
• Pour slowly. Avoid choking the funnel or spout, avoid backsplash, avoid vapor lock. Use vented containers for air pocket relief.
• Wear eye protection, face shield, proper gloves, i.e. high grip, impervious. Keep a rag or towel handy for clean up.
• Have an eye wash/shower in the area. Make sure it is functional. • If you handle the liquids frequently, look for ways to improve,
minimize exposure
Extinguishers For Liquid Fires
• Dry Chemical A-B- C is most popular • Water not recommended • CO2 not recommended • Aqueous foam will work, requires large
system • Re- ignition is hazard
OSHA Lab Safety Standard 1910.1450
• Train employees, plan the work, minimize materials
• Know how to react for clothing fire, small bench-top fire, when to call 911
• https://www.osha.gov/Publications/laboratory/OSHA3404laboratory-safety-guidance.pdf
What To Look For On INSPECTIONS • Fire ExEnguisher, mounted, with sign, charged, tagged, dated
• Look for signs of liquid leakage or spills. Strong odor of liquid – its usually smelly stuff
• Sloppy housekeeping, tools or other materials impeding access • Unlabeled containers, mongrel containers, incompaEble, home
made, etc. • Improper storage, i.e. cans stacked on one another, foreign objects
that could cause issues • DefecEve or open electrical boxes, exposed wiring, unprotected
bulbs, etc. • Open floor drains; eye wash or shower; burn blanket; first aid kit;
spill clean up kit; PPE handy and clean; SDS’s accessible; other specialty hardware such as non-‐sparking tools; handing equipment; dedicated pipelines are marked; locaEon of shut off valves are marked; venElaEon is operable and ductwork is clean;
Know the CharacterisEcs of the Liquid Not all flammables are created ‘equal’
Some large compressed gas boVles for example, may vent to atmosphere at a certain pressure.
Oxygen and fuel gasses on torch rigs are subject to have a separator panel on the cart.
Fuel gas boVles must be stored separately from Oxygen boVles Compressed gas cylinders must be capped and stabilized upright Liquid Propane is COLD, need to use insulated glove to avoid cold
‘burn’. Always do a pressure check on a oxy-‐fuel gas torch rig. Check the
TIP – if it is damaged or clogged, it could cause an explosion in the torch body mixing chamber. Good pracEce is to always use a new Ep or carry a clean spare and change them out. A bad Ep not only wastes gas but gives a poor cut. It could also cause a blockage and lead to an explosion.
John J. Meola, CSP, ARM Pillar, Inc. Safety Director
Richmond, VA
Mr. Meola has many years experience with construcEon and industrial safety program management. He is a published author and contribuEng writer for several trade
industry magazines and the World Sweeping AssociaEon. His consulEng with Pillar Inc. includes transportaEon, construcEon and industrial safety program management.
He can be reached at: 804.283.0038
[email protected] www.pillarens.com