Q&A: Storage of flammable liquids

Author: Business and Learning Resources


Do small spray bottles of rubbing alcohol (~32 oz) and paint spray cans (12 oz) that are used in many different areas throughout the facility need to the stored in a flammable liquid cabinet(s)?


According to the federal Occupational Safety and Health Administration’s (OSHA) flammable liquids standard for general industry workplaces, the way that flammable liquids must be stored depends on how flammable a particular liquid is, the quantity of liquid being stored, and how the liquid is being used.

OSHA’s flammable liquids standard can be found at 29 Code of Federal Regulations (CFR) 1910.106 and it includes provisions for “incidental” storage and use of flammable liquids in the workplace (see 1910.106(e)(2)). If the use and handling of rubbing alcohol and spray paint is only incidental to the primary business operations being conducted in an area of the facility and these materials are stored in quantities below certain thresholds, the materials do not need to be stored in a special flammable storage cabinet or inside storage room rated for fire resistance.

Rubbing alcohol is a Category 2 flammable liquid (as defined under 1910.106(a)(19)(ii)). In a building or in any one fire area of a building, you are allowed to store up to 120 gallons of Category 2 liquids outside of a flammable storage cabinet or inside storage room. Flammable aerosol paints are generally considered Category 1 liquids (as defined under 1910.106(a)(19)(i)). In a building or in any one fire area of a building, you may store up to 25 gallons of Category 1 flammable liquids outside of a flammable storage cabinet or inside storage room. Check the safety data sheets (SDSs) for the specific flammable liquids you are storing to confirm their category, which is based on flash point and boiling point. The product manufacturers may also include specific storage recommendations in the SDSs.

Note: In the case of incidental storage and use of any category of flammable liquids in containers, the liquids must be kept in “closed containers,” defined by OSHA as containers that are “sealed by means of a lid or other device that neither liquid nor vapor will escape from it at ordinary temperatures.”

If OSHA’s incidental use and storage provisions do not apply, flammable liquids must be kept in a flammable storage cabinet or inside storage room that complies with 1910.106(d)(3) or 1910.106(d)(4), respectively. In the case of storage cabinets, no more than 60 gallons of Category 1, 2, or 3 flammable liquids, and no more than 120 gallons of Category 4 flammable liquids may be stored in each cabinet.

Finally, OSHA’s flammable liquid container storage requirements, for containers with a maximum capacity of 60 gallons each, do not apply to flammable paints used for painting or maintenance if they are kept on-site for 30 days or fewer.

What is EHS Hotline?

Subscribers of EHS Hero® get access to our team of in-house subject matter experts. EHS Hotline allows subscribers to submit questions and receive timely, thorough, and plain-language answers from our team of experts—complete with resources and references. The purpose of EHS Hotline is to help connect workplace employment, safety, and environment questions to the material provided by BLR on its subscriber websites. While the service is defined as providing advice, it is assistance to help bridge the gap between the BLR compliance resources and our client’s workplace issues. It is not a legal opinion or replacement for seeking legal counsel.