OSHA clarifies Flammable Liquid Cabinet storage limitations (1910.106(d)(3)(i)
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 may be stored in a storage cabinet." This language is an adaptation of similar language in section 4210 of the 1969 edition of the National Fire Protection Association's (NFPA) Standard 30, Flammable and Combustible Liquids (source standard for 29 CFR 1910.106), which states: "Not more than 60 gallons of flammable or 120 gallons of combustible liquids may be stored in a storage cabinet." The requestor correctly pointed out that using "or" and "nor" above is ambiguous and that users might interpret these requirements differently. They listed multiple possible interpretations in their letter, including, but not limited to: |
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