OSHA 1910.106 Compliance Checklist: Flammable Storage in Corrugated Packaging Facilities
OSHA 1910.106 Compliance Checklist: Flammable Storage in Corrugated Packaging Facilities
In corrugated packaging plants, flammable liquids like inks, solvents, and adhesives are everyday essentials. But store them wrong, and you're inviting flash fires or regulatory headaches under OSHA 1910.106. We've walked dozens of facilities through audits—here's the no-nonsense checklist to lock in compliance.
Understand Your Scope Under 1910.106
OSHA 1910.106 governs flammable liquids (flash point below 100°F). Class IA (flash point <73°F, boiling <100°F) demands cabinets; Class IB/IC allow indoor storage with limits. In corrugators, glues and printing solvents often hit Class II (flash point 100-140°F), but verify SDS sheets first. We've seen plants fined $14,000+ for misclassifying inks—don't skip this step.
Site Assessment: Map Your Risks
- Inventory flammables: List all liquids by class, quantity, and location. Corrugated ops often stash solvents near flexo printers—flag hotspots.
- Check container integrity: Use DOT-approved metal/plastic drums or safety cans (max 5 gal for Class I indoors without cabinets).
- Evaluate ventilation: Ensure 1 cfm/sq ft mechanical exhaust in storage areas per 1910.106(b)(2)(ii).
This initial audit? It caught a client storing 60 gallons of solvent in open buckets—prime explosion bait. Pro tip: Use digital tools for real-time tracking; paper logs fade faster than cardboard in rain.
Storage Cabinets and Containers: The Core Requirements
- Max 60 gal Class I/II or 120 gal Class III in one cabinet (FM-approved, self-closing doors).
- Separate oxidizers/flammables by 20 ft or 1-hr fire wall.
- No stacking cabinets more than two high without engineering approval.
- Label boldly: "Flammable—Keep Fire Away."
Picture this: A Bay Area corrugator squeezed three cabinets into a corner—OSHA shut 'em down. Space them 10 ft apart from ignition sources like hot presses or sparks from slitters. We've retrofitted dozens; FM3580 cabinets pay for themselves in avoided citations.
Indoor vs. Outdoor: Location-Specific Rules
Indoors? Limit to 25 gal Class IA outside cabinets, 660 gal with sprinklers. Outdoors, 660 gal Class I/II in racks, drums on noncombustible surfaces. Corrugated plants love warehouse edges for storage—ensure 10 ft from building lines and 3 ft aisles. Diking? Mandatory for >1,100 gal to contain spills (1910.106(b)(4)).
| Location | Max Quantity (No Sprinklers) |
|---|---|
| Inside Cabinets | 60 gal Class I/II |
| Outside Cabinets (Room) | 25 gal Class IA |
| Outdoor Cutoff Rooms | 660 gal |
Handling, Bonding, and Spill Prep
- Bond and ground: Every transfer—static sparks have ignited solvent vapors in corrugator ink rooms.
- Spill kits ready: Absorbents, drains sealed per local codes.
- No smoking/pilots within 20 ft: Post signs; enforce with audits.
- Training logged: Annual refreshers on 1910.106(e) handling (we've trained 500+ operators—knowledge sticks).
One playful aside: Treat flammable cabinets like moody exes—door closed, or drama ensues. Research from NFPA shows 40% of liquid fires stem from poor handling; bond every pour.
Documentation and Audits: Seal the Deal
Maintain SDS files, inspection logs (weekly cabinet checks), and spill reports. Mock OSHA walkthroughs reveal gaps—conduct quarterly. For corrugated specifics, cross-reference NFPA 30 for tank farms if scaling up. Results vary by facility size; a 50,000 sq ft plant might need third-party hazmat audits.
Resources: OSHA 1910.106 Full Text | NFPA 30. Tick this checklist, and your corrugator runs safer, smoother. Compliance isn't optional—it's your edge.
