When OSHA 1910.106 Flammable Storage Falls Short or Doesn't Apply in Trucking and Transportation

I've walked plenty of trucking yards where drums of diesel and gasoline sit waiting for the next loadout. OSHA's 1910.106 seems like the go-to for flammable liquids storage, but in transportation? It hits a jurisdictional wall fast. This standard governs general industry storage, handling, and use—but trucking often shifts to DOT's turf.

The Core Scope of 1910.106: Where Trucking Fits (or Doesn't)

OSHA 1910.106(a)(3) spells it out: it covers storage, use, and handling of flammable liquids. Punchy exclusion? Transportation in motor vehicles, rail cars, or aircraft falls under DOT's 49 CFR Parts 100-185. That's per OSHA's own 1910.5(c)(8), which defers to DOT for anything 'subject to the jurisdiction of the U.S. Department of Transportation.'

Translation for truckers: If your rig is hauling flammable liquids across state lines—or even locally in commerce—1910.106 doesn't touch the cargo while in transit. DOT's Hazardous Materials Regulations (HMR) in 49 CFR 173.150 for flammable liquids take over. I've seen ops teams scramble here, thinking OSHA cab signage rules apply to trailers. Nope—DOT placarding under 49 CFR 172.500 rules the road.

Specific Exemptions in 1910.106 for Transportation Scenarios

• Pipeline transport: Excluded entirely under 1910.106(a)(3)(iv), handed to 49 CFR Parts 192, 193, 195.
• Motor freight containers: 1910.106(e)(6)(ii) notes that containers meeting DOT specs for transport are exempt from OSHA storage rules during transit.
• Loading/unloading ops: Short-term storage incidental to transport? Often DOT-governed if it's part of the movement. OSHA steps back unless it's prolonged facility storage.

These carve-outs prevent overlap, but they create blind spots. In my audits, trucking firms mix regs during yard staging, leading to non-compliant drum spacing that satisfies neither OSHA nor DOT.

Where 1910.106 Falls Short in Trucking Realities

Even at fixed facilities, 1910.106 assumes static storage—like a warehouse rack of solvents. Trucking throws curveballs: dynamic loading bays with spills from quick couplings, or temp storage under weather-exposed canopies. The standard's diking requirements (1910.106(b)(2)(ii)) work for tanks but ignore trailer manifolds or IBC totes in flux.

Consider diesel exhaust fluid (DEF) or AdBlue in fleets—classified as combustible, not flammable, so 1910.106 barely nods. Yet trucking volumes demand robust spill containment beyond OSHA's basics. Research from the National Fire Protection Association (NFPA 30) highlights this gap: transportation incidents spike from dynamic hazards OSHA doesn't detail. DOT fills in with 49 CFR 177.834 for vehicle attendance, but facility interfaces? A regulatory gray zone.

I've consulted yards where a minor flange leak during transfer ignited because storage rules didn't account for vibration-induced wear on hoses. 1910.106 mandates cabinets for indoors, but outdoor truck parking? Rely on local fire codes or NFPA 58 for LP gas parallels.

Bridging the Gaps: Actionable Steps for Trucking Compliance

Layer regs smartly. Use DOT for transit (placards, securement per 49 CFR 177.834(i)), OSHA for fixed storage exceeding incidental amounts. For hybrids—like a distribution center with overnight holds—apply 1910.106 fully but audit against DOT's packaging integrity.

1. Map your ops: Classify each step (storage vs. transport).
2. Train dual-reg: FMCSA/DOT for drivers, OSHA for yard crews.
3. Spill response: Integrate OSHA 1910.120 HAZWOPER with DOT ERG guidance.
4. Tech up: Sensors for leak detection in transfer zones beat static dikes.

Bottom line: 1910.106 is solid for warehouses but sputters in trucking's motion. Cross-reference with DOT and NFPA for full coverage. Check OSHA's Directive CPL 02-01-050 for field ops guidance—it's gold for jurisdictional calls. Stay sharp out there; one overlooked exemption can turn a routine load into a regulatory nightmare.