Have you ever seen several full tanker trailers parked without their mode of transport under them or a railcar with the Class 3 Flammable placard hooked up to the process and being used as a storage tank? Although OSHA’s 1910.106 makes no specific prohibition against this practice, I would like to point out that the International Fire Code (IFC) of which many states in the USA have adopted as their state fire code does make a SPECIFIC PROHIBITION of using railcars or tank trucks as “storage tanks”.
5704.2.2 Use of tank vehicles and tank cars as storage tanks.
Tank cars and tank vehicles shall not be used as storage tanks.
There are a lot of reasons why the IFC prohibits the use of transportation containers in lieu of properly constructed and installed fixed storage tanks, but the primary reason is the design of the transport containers is not intended for longterm. They behave differently when exposed to a fire. They most often are not provided proper secondary containment and all too often we find them “sited” in the darndest places!
Bottom line… a RR Car or Tanker Truck is NOT to be used as a fixed flammable liquid storage tank… per the IFC.