Blog · Flammable liquids · 29 CFR 1910.106
Meet the OSHA 1910.106(d)(3) Requirements for a Flammable Storage Cabinet
OSHA 29 CFR 1910.106(d)(3) sets four things for a flammable liquid storage cabinet: how much it may hold, how it must perform in a fire, how it must be labeled, and what construction is deemed to comply. Check a cabinet against each one before you compare flammable storage cabinets on price.
Keep each cabinet under the capacity limit
Paragraph (d)(3)(i) sets these limits for a single cabinet:
- 60 gallons of Category 1, 2, or 3 flammable liquids, or
- 120 gallons of Category 4 flammable liquids.
OSHA classifies flammable liquids by flash point in 1910.106(a)(19), in Categories 1 through 4. Category 1 is the most volatile. Category 1 and 2 liquids have flash points below 73.4°F, which includes common liquids such as gasoline and acetone, so the 60-gallon limit governs most cabinets in a maintenance area. Total the containers you plan to store, by category, before you choose a size.
Confirm the cabinet passes the fire test.
Paragraph (d)(3)(ii) requires the cabinet to limit its internal temperature to not more than 325°F when exposed to a 10-minute fire test using the standard time-temperature curve in NFPA 251-1969. All joints and seams must stay tight, and the door must stay securely closed during the test.
A manufacturer that states FM approval has submitted the cabinet to FM Approvals’ fire test standard. OSHA does not approve cabinets.
Label the cabinet in conspicuous lettering.
The same paragraph requires the cabinet to be labeled, in conspicuous lettering, “Flammable—Keep Fire Away.” Replace a label that has faded or peeled.
Recognize the construction OSHA deems compliant.
OSHA describes two constructions that are deemed to meet the fire test requirement.
| Element | Metal cabinet, (ii)(a) | Wooden cabinet, (ii)(b) |
|---|---|---|
| Walls, top, bottom, door | At least No. 18 gage sheet iron, double walled with a 1½ inch air space | Approved grade of plywood at least 1 inch thick that will not break down or delaminate in a fire |
| Joints | Riveted, welded, or made tight by an equally effective means | Rabbetted and fastened in two directions with flathead woodscrews |
| Door | Three-point lock; sill raised at least 2 inches above the cabinet bottom | Where more than one door is used, a rabbetted overlap of at least 1 inch |
| Hinges | Not specified beyond the fire test | Mounted so they keep their holding capacity if the screws loosen or fail in a fire |
A cabinet built another way can still comply if it passes the fire test. The three cabinets in the cabinet comparison list 18-gauge double-wall steel construction, and two of them list FM approval.
Check the rules OSHA does not set
- Self-closing doors. 1910.106(d)(3) does not require them. Many fire codes and insurers do. Ask your fire marshal.
- Venting. The OSHA paragraph does not require venting. Cabinets ship with vent openings plugged, and manufacturers advise venting only where the authority having jurisdiction requires it.
- Number of cabinets per area. NFPA 30 and local fire codes limit how many cabinets may be grouped in one fire area.
Install the cabinet where the liquid is used
- Total the flammable liquids at the work area by category.
- Choose a cabinet that holds that volume and stays under 60 gallons of Category 1, 2, or 3 liquids.
- Confirm the construction or FM approval, the label, and the door type your jurisdiction requires.
- Place it on a level floor, away from exits and ignition sources.
The flammable storage cabinet guide compares a 12-, 22-, and 30-gallon cabinet on construction, door type, and dated Amazon price.