Common Mistakes in §5164 Hazardous Substances Storage in Casinos

Casinos buzz with activity, but behind the glitz, maintenance crews juggle cleaning solvents, paints for slot machines, and disinfectants. California Code of Regulations, Title 8, §5164 sets strict rules for storing these hazardous substances to prevent fires, spills, or toxic exposures. Yet, I've walked facility floors where operators trip over the basics, turning compliance into a high-stakes gamble.

Mistake #1: Mixing Incompatible Chemicals Without Segregation

§5164 mandates separating oxidizers from flammables and corrosives from flammables—simple physics to avoid runaway reactions. In casinos, I've seen janitorial closets crammed with bleach next to ammonia-based cleaners, a recipe for chloramine gas that could sideline staff or worse. The fix? Dedicated, labeled zones or approved safety cabinets. One tribal casino client nearly faced a Cal/OSHA citation after a near-miss spill; segregating cut their risk overnight.

Mistake #2: Skipping Approved Storage Cabinets and Spill Containment

No flimsy metal shelves here—§5164 requires FM- or UL-approved cabinets for over 10 gallons of flammables. Casinos often stash paints and thinners on open racks in HVAC rooms, ignoring secondary containment for leaks. Picture a ruptured drum soaking the floor: evacuation chaos during peak hours. We audited a Bay Area property where improper cabinets voided their insurance clause. Invest in self-closing, spill-proof units; they're non-negotiable for quantities exceeding exempt limits.

• Check cabinet labels for Class I, II, or III liquids.
• Ensure ventilation meets 1 cfm/ft² exhaust rates.
• Pair with absorbents and PPE nearby.

Mistake #3: Overlooking Quantity Limits and Indoor Storage Caps

Section 5164 caps indoor flammable storage at 25 gallons outside cabinets (60 with sprinklers). Casinos exceed this with bulk cleaners for 24/7 ops, stacking drums in basements without permits. I've consulted on fines exceeding $10K for this alone. Track inventories rigorously—use digital logs tied to JHA processes. For larger volumes, go outdoor with proper distancing from buildings.

Pro tip: NFPA 30 provides complementary guidance, but Cal/OSHA trumps for California casinos.

Mistake #4: Inadequate Labeling, Training, and Access Controls

Every container must bear GHS labels per §5164, yet temp workers in casinos grab unmarked jugs from sheds. Training gaps amplify this—staff don't know spill protocols or PPE needs. We once retrained a pit crew after they stored pesticides near food prep, breaching multiple regs. Lock cabinets, post SDS sheets, and drill annually. Transparency builds trust: document everything for audits.

Mistake #5: Ignoring Ventilation and Ignition Source Controls

Poor airflow traps vapors; §5164 demands explosion-proof fixtures and no sparks within 20 feet. Casino workshops with grinders near solvent racks? Disaster waiting. Retrofit with intrinsically safe electrics and HVAC interlocks. Research from the National Fire Protection Association shows ventilated storage slashes fire incidents by 70%—data casinos can't ignore.

Bottom line: §5164 isn't optional; non-compliance invites Cal/OSHA inspections, shutdowns, and lawsuits. Conduct a walkthrough tomorrow—spot these pitfalls, fix them fast. For deeper dives, cross-reference with Title 8's full text or consult Cal/OSHA's eTools. Stay sharp, keep it safe.