Top OSHA 1910.106 Violations in Agricultural Flammable Storage
Top OSHA 1910.106 Violations in Agricultural Flammable Storage
Flammable liquids power agriculture—from diesel for tractors to solvents for equipment maintenance. Yet OSHA 1910.106, the standard for flammable liquids, trips up many operations. In my inspections across California farms and orchards, I've pinpointed recurring issues that lead to citations and, worse, fires.
Why Agriculture Faces Unique 1910.106 Risks
Farms aren't warehouses. Barns double as storage and workspaces, tractors park near fuel drums, and weather pushes everything indoors. OSHA data from 2022 shows 1910.106 among the top 10 cited standards in agriculture, with over 1,200 violations industry-wide. Heat, dust, and ignition sources like welding amplify dangers under 1910.106(e)(6), which mandates separation from ignition.
Violation #1: Exceeding Indoor Storage Limits
1910.106(d)(3) caps Class I liquids at 25 gallons outside cabinets, 60 inside approved ones. Farms routinely exceed this with 55-gallon drums in shops. I've walked into milking parlors stacked with gasoline cans totaling 200 gallons—no cabinets. Result: Instant citation, potential flash fire.
Violation #2: Unapproved Containers and Cabinets
Safety cans? Often plastic jugs or rusty barrels instead. Standard 1910.106(d)(2) requires FM- or UL-approved containers with self-closing lids. In ag, we see repurposed pesticide drums for diesel. A Central Valley vineyard I audited had open-top barrels spilling vapors—prime for explosion.
- No flame arrestors on vents.
- Cabinets without spill containment or "Flammable—Keep Fire Away" labels.
Violation #3: No Bonding and Grounding During Transfer
Static sparks ignite vapors. 1910.106(e)(6)(ii) demands bonding/grounding for metal containers over 5 gallons. Skip this pouring diesel from truck to tractor? Boom—citation. Ag's mobile fueling setups ignore it half the time, per OSHA logs.
Violation #4: Storage Near Ignition Sources
20 feet minimum from open flames or hot work, per 1910.106(b)(2). Hay balers spark, welders fix plows nearby fuel sheds. One almond farm incident: Sparks from grinding hit fuel vapors 10 feet away. No fire, but hefty fine.
Less common but deadly: Poor ventilation. 1910.106(d)(4) requires explosion-proof exhaust in enclosed spaces. Dusty barns trap vapors like a tinderbox.
How We Fix These in the Field
Start with audits. Map storage against 1910.106 tables—Class IA max 10 gallons per cabinet. Swap to DOT-spec jerry cans. Install spill pallets under drums. I've helped ranches cut violations 80% by segregating fuels in detached sheds with concrete floors and drains to containment.
- Inventory flammables weekly.
- Train via hands-on drills—OSHA loves documented sessions.
- Use Pro Shield-style digital tracking for JHA on fueling tasks.
Balance: These fixes cost upfront but slash premiums and downtime. Research from NFPA shows compliant storage drops fire risk 70%.
Resources for Ag Compliance
Dive into OSHA's full 1910.106 at osha.gov. Check NFPA 30 for cabinets. For ag-specific guidance, ASABE standards cover farm fuel systems. Track citations via OSHA's data tool—search NAICS 111000 for your peers' pitfalls.
Stay sharp. One overlooked drum can idle your harvest.
