Flammable Liquids

At 3:11 p.m. on August 26, 2015, Employee #1, who had worked with the company for three months as a forklift operator/ repacking, was working alone in the repacking area making a transfer of flammable liquid acetone from an elevated 793-gallon stainless steel intermediate bulk container (tote) to a 350-gallon stainless steel tote on the…...

The transfer of Class IA liquids from polyethylene drums and containers may be safety accomplished and is deemed to comply with the intent of the standards at 29 CFR 1910.106(e)(6)(ii) and (h)(7)(i)(b) when: A polyethylene drum is equipped with an approved metallic suction pump and draw tube for taking liquid through the top of the…...

OSHA does not have any provisions that require the emergency relief devices on PORTABLE TANKS to discharge to the outside of buildings. However, if portable tanks are part of a PSM-covered process, at a minimum, the employer would be required to IDENTIFY, EVALUATE, AND CONTROL [§1910.119(e)(1)] the hazard of discharging flammable and combustible materials through…...

OSHA bases their position on which section of 1910.106 would be applicable; if the plant is an industrial (covered under 1910.106 (e)) or a processing plant (covered under 1910.106(h)).  If the operation is an incidental activity covered by §1910.106(e)(2), paragraph §1910.106(e)(2)(iv)(d) allows transfer of flammable or combustible liquids into vessels, containers, and portable tanks within…...

OSHA’s says No; 1910.106(e)(2)(iii) does NOT require the exclusive use of fresh air for ventilation purposes.  OSHA states that 1910.106(e)(2)(iii) is a performance requirement and does NOT explicitly require the introduction of fresh air to meet the performance requirements of the OSHA standard. OSHA, under §1910.106(e)(2)(iii), expects employers to provide adequate ventilation to maintain concentrations…...

One of the top questions we get when working with clients whose primary business is storing, handling, and processing flammable liquids is… How many flammable storage cabinets can we have in the same area? This answer used to be easy, but these days – not so much.  Back in the day, NFPA 30 (2000 Edition)…...

In 2011 someone wrote to OSHA and specifically asked for clarification on the use of the words “or” and “nor” in the paragraph Design, Construction, and Capacity of Storage Cabinets-Maximum Capacity, 1910.106(d)(3)(i), which states: “Not more than 60 gallons of Class I or Class II liquids, nor more than 120 gallons of Class III liquids…...

An investigation into an explosion last year at a fertilizer plant has been completed by the State Fire Marshal’s Office and the report reads like a classic flammable liquid explosion – one small problem, Triclopyr 3 is not a flammable liquid! Triclopyr 3 has a flash point of 141°F and in today’s GHS world that…...

A major hazard involved with the transfer of non-conductive flammable liquids is the build-up of static electricity with the potential for discharge resulting in fire and subsequent loss of primary containment, an LOPC event. Certain non-polar liquids can be charged (e.g., while flowing through pipes and hoses). Detectable and hazardous charges must be expected if…...

It appears OSHA is getting serious about 1910.106(e)(2)(ii)(b)… 1910.106(e)(2)(ii) “Containers.” flammable liquids shall be stored in tanks or closed containers. 1910.106(e)(2)(ii)(a) Except as provided in subdivisions (b) and (c) of this subdivision, all storage shall comply with paragraph (d) (3) or (4) of this section. 1910.106(e)(2)(ii)(b) The quantity of liquid that may be located outside of an inside storage…...

Back on March 4, 2016 a contractor/truck driver was transferring “diesel fuel” of some type from a storage tank to his truck when there was a flash fire.  He received 2nd and 3rd degree burns over 50% of his body and has since passed away from his injuries.  When I saw this incident in my…...