How many flammable storage cabinets are permitted in a facility?

OSHA expects that all flammable liquids, as defined in 1910.106(a)(19), be kept in a flammable storage cabinet, inside storage room, or flammable storage warehouse per 1910.106(d)(3), (d)(4), and (d)(5), respectively. If you opt for a storage cabinet(s), 1910.106(d)(3) specifies that 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. Section 1910.106 does not specify a maximum number of storage cabinets, but that does not mean an employer is permitted to use any number of storage cabinets.

OSHA explains that it may cite an employer under the General Duty Clause (Section 5(a)(1) of the OSH Act) for not adhering to the maximum number of storage cabinets allowed by NFPA 30, Flammable and Combustible Liquids Code. The NFPA standard offers a table of “maximum allowable quantities” or MAQs that may be kept in a given “control area.”

At the same time, OSHA offers a loophole to the 1910.106(d)(3) storage cabinet storage limitations in paragraph 1910.106(e)(2)(ii), the provisions for industrial plants where the use of flammable liquids are incidental to the principal business. Generally storage even in these industrial plants must follow 1910.106(d)(3) and (d)(4), but under 1910.106(e)(2)(ii), for incidental storage, OSHA allows employers to store up to 25 gallons of Category 1 and 120 gallons of Categories 2, 3, and 4 in containers in any one “fire area” of the facility outside a flammable storage cabinet or storage room.

In addition, local or state fire codes may dictate storage requirements; therefore, employers should contact their local fire authorities as they generally know what OSHA requires as well as the requirements found within local and state fire codes, and these authorities will be the best source of information regarding flammable liquid storage. Moreover, an employer’s liability insurance carrier may require or restrict the storage of flammable liquids, which may affect insurance rates.