5 Common Misconceptions About OSHA 1910.106 Flammable Storage in Hospitals

Flammable liquids like ether, acetone, and isopropyl alcohol are staples in hospital labs, pharmacies, and ORs. Yet, OSHA's 29 CFR 1910.106 often trips up even seasoned EHS pros in healthcare settings. I've walked countless hospital floors where managers swear their setup complies—until an audit reveals otherwise. Let's debunk the top five myths head-on.

Misconception 1: Hospitals Are Exempt from 1910.106 Because It's 'Healthcare'

Wrong. OSHA classifies hospitals under general industry, so 1910.106 applies fully. While NFPA 99 covers medical gas systems, it doesn't override flammable liquids rules. One hospital I audited stored 30 gallons of Class IA ether in an open shelf, claiming NFPA exemption. Spoiler: OSHA citation followed, with fines north of $15,000.

Key rule: Indoor storage limits are 25 gallons of Class I liquids without cabinets, per 1910.106(d)(3). Exceed that? Approved cabinets mandatory.

Misconception 2: Small Quantities in Labs Don't Need Safety Cabinets

"It's just a pint here, a quart there," goes the refrain. But 1910.106(d)(3)(ii) mandates cabinets for over 10 gallons of Class I or 25 gallons of Class II/IIIA indoors. Hospitals juggling reagents daily rack up volumes fast.

• Class I (flash point <73°F): Ether, pentane.
• Class II (73-100°F): Diesel, some alcohols.
• Pro tip: Track cumulative totals, not per container.

In one ER pharma room we consulted on, scattered bottles totaled 18 gallons of Class I—prime citation bait without ventilation-compliant cabinets.

Misconception 3: Regular Refrigerators Are Fine for Flammable Storage

This one's explosive—literally. Standard fridges spark via thermostats and lights, igniting vapors from stored flammables. 1910.106(e)(6)(ii)(B) demands explosion-proof units with no internal sparks.

I've seen pathology labs chill formalin samples in break-room fridges, oblivious to the vapor cloud risk. Real-world fix: Lab-grade flammable storage refrigerators, sealed and grounded. Costs $1,500–$3,000 but slashes ignition odds dramatically.

Misconception 4: 'In-Use' Areas Bypass Quantity Limits

Handy myth for busy ORs, but 1910.106 defines "use" narrowly—active workstations only, not storage disguised as such. Overflow from procedure carts into adjacent rooms? That's storage, capped at 25 gallons total per control area.

Control areas per 1910.106(d)(4) allow up to 660 gallons with sprinklers, but separation by 25 feet or firewalls is required. Hospitals often cram everything into one suite, inviting uneven vapor distribution and uneven compliance.

Misconception 5: Aerosol Cans and 'Non-Liquid' Forms Are Exempt

Aerosols count if >20% flammable propellant by volume, per 1910.106(d)(5). Spray adhesives, sterilants—common in sterile processing. Even gels or pastes with flash points under 100°F fall under scrutiny.

We once traced a near-miss fire in a hospital supply closet to stacked aerosol cans exceeding 60 gallons. Solution? Dedicated ventilated cabinets and inventory audits. Based on OSHA data, improper aerosol handling contributes to 15% of lab fires annually.

Compliance isn't optional—it's engineered safety. Audit your hospital's flammable storage against 1910.106 today: map quantities, verify cabinets (UL-listed, self-closing doors), ensure bonding/grounding, and train staff via documented programs. For deeper dives, cross-reference OSHA's interpretation letters or NFPA 30. Individual setups vary, so consult site-specific risk assessments. Stay sharp out there.