PSM and Aerosol (Flammable Gas) Containers Stored in Warehouses/Distribution Centers

This is an EXCELLENT LOI from OSHA that covers three (3) IMPORTANT aspect of PSM applicability:

1. Co-Location of smaller containers of flammables that could be impacted by a single event (i.e. fire)
2. Once a process is PSM covered it remains such UNTIL such time the employer puts in place a means to LIMIT the quantity of the HHC below it’s TQ within the process, and
3. how compliance with NFPA and IFC does not exempt a process, but rather they are the baseline RAGAGEP for the PSM covered process

This letter explains how metal aerosol containers contain up to 33 total ounces per container of aerosol product in items such as shaving cream, hair spray, antiperspirant, and their associated flammable gas propellants can be a PSM covered process when the “process” exceeds 10,000 pounds of a Category 1 Flammable Gas.  The key term to keep in mind when reading this is “CO-LOCATION”.

Background/Scenario:

A distribution center/warehouse stores consumer aerosol products in metal cans.

• The metal aerosol containers contain up to 33 total ounces per container of aerosol product in items such as shaving cream, hair spray, antiperspirant, and their associated flammable gas propellants.
• The flammable gas propellants used in the aerosol are typically butane, isobutane, and propane. 
• The distribution center/warehouse is not on the premise of a retail facility, nor is it on the premise of the aerosol manufacturer.
• The distribution center/warehouse ships these aerosol products to retail facilities.
• It can be presumed that these distribution centers/warehouses are in-compliance with building and fire code requirements, for the storage of consumer aerosol products, including NFPA 30B, Code for the Manufacture and Storage of Aerosol Products, and the International Fire Code.

Question 1 (paraphrased): As described, is the storage of consumer aerosol products in metal aerosol containers in a distribution center/warehouse required to comply with the requirements of 29 CFR 1910.119 (Process Safety Management (PSM) Standard) if the aggregate weight of flammable gas propellants in the stored aerosol containers on the premises exceeds 10,000 pounds?