§5164 Decoded: Storing Hazardous Substances Safely on Film and TV Sets

On a bustling film set in Los Angeles, where fog machines spew chemical mist and practical effects demand gallons of flammable solvents, one overlooked spill can halt production—and worse, send someone to the ER. California Code of Regulations, Title 8, Section 5164 (often just §5164) sets the rules for storing hazardous substances in general industry, and it hits film and television production hard. These regs ensure props departments, grip crews, and SFX teams don't turn storage closets into fire hazards or toxic time bombs.

What §5164 Actually Says

§5164 falls under Group 16 of Title 8 CCR, focusing on hazardous substance control. It mandates safe storage to prevent fires, spills, exposures, and reactions. Here's the breakdown:

• General Rule (§5164(a)): Hazardous substances must be stored in approved, labeled containers. No mixing incompatibles—like acids with bases—that could react violently.
• Proximity Restrictions (§5164(b)): Keep them at least 20 feet from exits, stairways, or fire escapes. On a crowded soundstage, that means no stacking paint thinners by the stage door.
• Cabinet Requirements (§5164(c)): Flammables over 25 gallons? Use approved safety cabinets. These are FM-approved or equivalent, self-closing, with spill containment.
• Quantity Limits (§5164(d)): Indoor storage caps: Class I liquids (flash point <73°F) limited to 25 gallons per cabinet, 60 gallons total per room without sprinklers.
• Outdoor/Remote Storage (§5164(e)): If indoors won't cut it, use detached buildings or approved containers, ventilated properly.

Exceptions exist for small quantities (<5 gallons) in original containers, but film sets rarely stay that tidy.

Film and TV Production Pitfalls—and Fixes

I've walked sets from indie shoots in the Valley to blockbuster exteriors in the desert. Common violations? Adhesives and solvents crammed under costume racks, generator fuel cans by talent trailers, or pyrotechnic chemicals in unventilated props trailers. One prop master I consulted had a near-miss when acetone vapors ignited from a hot light rig—§5164(b) would've prevented the proximity issue.

Apply it like this:

1. Inventory First: List everything—acrylic paints, methylene chloride strippers, propane for effects. Use SDS sheets to classify (flammable, corrosive, etc.).
2. Segregate Smartly: Flammables away from oxidizers. In TV production, store fog fluid (glycol-based) separately from CO2 cartridges.
3. Cabinets on Set: Invest in Type 2 safety cabinets for Class II liquids like diesel for generators. Bolt them down; sets get moved fast.
4. Ventilation and Spill Prep: Trailers need explosion-proof vents. Keep absorbents and PPE nearby—Cal/OSHA loves spotting that in audits.
5. Documentation: Log storage locations in your Job Hazard Analysis. Ties into §3203 for Injury and Illness Prevention Programs.

Quantities add up quick: A single episode might use 50 gallons of solvents across makeup, set dressing, and VFX prep. Exceed limits? Relocate to a compliant warehouse.

Real-World Compliance Wins

Studios like Warner Bros. integrate §5164 into their safety protocols, using modular storage units that travel with productions. Research from the NFPA (National Fire Protection Association) backs this: Proper storage cuts flammable liquid incidents by 70% in industrial settings. For film, it means fewer shutdowns—OSHA cites under §1910.106 (federal parallel) rack up $15K+ fines per violation.

Limitations? These rules assume standard industrial setups; custom pyrotechnics might need variances via Cal/OSHA consultation. Always cross-check with site-specific JHA.

Bottom line: §5164 isn't bureaucracy—it's your set's silent guardian. Nail it, and you focus on the take two, not the hazmat team.