Is the question how large a bottle in which a flammable may be stored? Stored meaning that it is in a flammable storage cabinet, not in the laboratory space or is the question how much flammable liquid may be in the laboratory space?
The latter question is answered by NFPA 45 Standard on Fire Protection for Laboratories Using Chemicals, without looking it up I would just be making up the numbers, but it is based on total volume of flammable material in total room volume.
The former question would be answered by the manufacturer of the flammable storage cabinet and the OSHA Regulation that you are referencing, any exceptions to the OSHA rules are in the regulation itself. The loophole out of the OSHA regulation is to have 10 or fewer employees or to be a state or tribal government facility in which the state or tribe has not said that their facilities will follow OSHA or state OSHA requirements.
A best practice is to follow NFPA guidelines on flammable liquid storage.
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of David Roberts
Sent: Friday, November 10, 2017 9:47 AM
Subject: Re: [DCHAS-L] container size regulations for flammable liquids
So my interpretation of that rule is that you can store in glass up to 1 gallon (I don‰??t fully understand 4 L, since that‰??s a little over, but I guess that works) if your process dictates that you can‰??t use metal or that you will use more than 1 qt at a single time. So I would assume that something like HPLC grade ethanol could be in a 4L glass bottle due to impurities that may happen when placed in a metal can. There are probably other situation where you could make that argument.
I don‰??t know if a plastic carboy can be considered as a safety can - since everything I buy come in 5 gallon plastic containers with spigots (all of my acetone, ethyl acetate, ethanol, methanol come that way). I‰??d guess that about 10 years ago most vendors switched from sending 5 gallon metal pails to 5 gallon plastic pails for most of my organic solvents (except halogenated things, hexane, acetonitrile, etc‰?|). So I don‰??t know exactly what allowed them to do that, but I feel that, in the solvents shipped that way, storage in plastic containers is acceptable.
But that rule does say that you can store category 2 things in 1 qt glass, 5 gallon metal pails, 5 gallon safety cans, 60 gallon metal drums, or 660 gallon portable tanks.
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> On Nov 10, 2017, at 9:59 AM, Sandoval, Mariah W
> A common question our EHS department receives from professors is what size containers they can use to store flammable liquids in the lab, ethanol being the primary one. According to OSHA 29 CFR 1910.106(d)(2)(iii), the size of a glass container for a Category 2 flammable liquid is 1 qt. How then can laboratory researchers order and store 4 L glass bottles of ethanol from chemical suppliers? Is there a loophole I am missing? Are research labs allowed to store flammable liquids in larger size containers (say a 2 gallon carboy) if they use it on a day-to-day basis?
> Mariah Woodroof, PhD
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