When Flammable Cabinets Regulations Fall Short in Corrugated Packaging

Let's dive into the nitty-gritty of OSHA's 1910.106 regulations and see where they might not fully cover your corrugated packaging operations.

Understanding the Regulations

OSHA's 1910.106(e)(2)(ii)[b] and 1910.106(d)(3)(ii) set the standards for the safe storage of flammable liquids in industrial settings. These regulations are crucial for ensuring that flammable materials are stored in a way that minimizes risk. But, when it comes to the unique environment of corrugated packaging facilities, there are scenarios where these rules might not be enough.

Where the Regulations Fall Short

High-Volume Storage: In corrugated packaging, you often deal with large volumes of flammable liquids used in adhesives or inks. The standard cabinet sizes and capacities might not be sufficient for these operations. We've seen cases where facilities had to resort to multiple cabinets, which can complicate compliance and safety management.

Custom Storage Solutions: The nature of corrugated packaging might require custom storage solutions that don't fit neatly into the standard cabinet design. For instance, I once worked with a facility that needed to store drums of adhesive in a way that wasn't covered by the typical cabinet dimensions. This is where the regulations can fall short, leaving you to figure out how to stay compliant while meeting your operational needs.

Integration with Production Lines: In many corrugated packaging plants, flammable liquids are directly integrated into the production lines. The regulations don't specifically address how to manage safety when these liquids are in use, rather than just stored. This gap can lead to confusion and potential safety hazards if not addressed properly.

Best Practices for Compliance

Risk Assessment: Conduct a thorough risk assessment specific to your corrugated packaging operations. Identify where the standard regulations might not fully apply and develop strategies to mitigate those risks.

Custom Solutions: Work with safety consultants to design custom storage solutions that meet both the regulatory requirements and your operational needs. These solutions should be scalable and adaptable to changes in your production processes.

Continuous Training: Ensure that all employees are regularly trained on the safe handling and storage of flammable liquids. This training should be tailored to the specific risks and procedures in your corrugated packaging facility.

Documentation and Audits: Keep detailed records of your compliance efforts and conduct regular audits to ensure that your custom solutions are still meeting safety standards. This documentation can be crucial in demonstrating compliance during OSHA inspections.

While OSHA's 1910.106 regulations provide a strong foundation for safety, corrugated packaging operations often require a more nuanced approach. By understanding where these regulations might fall short and implementing best practices, you can maintain a safe and compliant workplace. For further reading, consider the resources provided by the National Fire Protection Association (NFPA) on the safe storage of flammable liquids in industrial settings.