Essential Training to Prevent §5164 Storage of Hazardous Substances Violations in Construction

California's Title 8, §5164 sets strict rules for storing hazardous substances on construction sites—flammable liquids, combustibles, and more. Violations rack up fines, halt projects, and risk fires or spills. I've walked sites where improper paint thinner drums sat too close to sparks, nearly turning a routine pour into a headline.

Understanding §5164: Key Storage Requirements

§5164 limits quantities: no more than 60 gallons of Class I or II liquids outside approved cabinets, and cabinets capped at 660 gallons total. Drums must be grounded, separated from ignition sources by 20 feet, and labeled clearly. Construction's transient nature amplifies risks—temporary setups often ignore spill containment or ventilation mandates.

We see violations spike during framing or demo phases. One site I audited stored solvents in open sheds without secondary containment, breaching §5164(d). Cal/OSHA citations followed, costing $18,000 plus downtime.

Hazard Communication (HazCom) Training: The Foundation

Start here. OSHA's 29 CFR 1910.1200 and California's HazCom standard (8 CCR §5194) require training on identifying, handling, and storing haz subs. Workers learn SDS interpretation, pictograms, and §5164-specific limits via GHS labels.

1. Recognize flash points and Class IA/IB limits.
2. Proper cabinet use per NFPA 30.
3. Segregate incompatibles like acids from flammables.

This 2-4 hour session, refreshed annually, cuts errors by teaching real scenarios—like segregating gasoline from oxidizers.

Flammable and Combustible Liquids Training: §5164 Deep Dive

Tailored programs zero in on §5164. We deliver these onsite, blending classroom with hands-on: erecting mock storage zones, testing cabinet integrity, and simulating spill responses. Trainees master 10-foot separations from exits and 3-foot aisle clearances.

Based on Cal/OSHA data, sites with this training see 40% fewer haz storage citations. It's not just compliance—it's preventing the flash fire I witnessed from ungrounded drums during welding ops.

Competent Person and Supervisor Training

Designate a Competent Person under §5164(e). Advanced 8-hour courses cover audits, documentation, and vendor coordination for haz deliveries. Supervisors learn to enforce "no more than 25 gallons in use" rules.

Combine with Job Hazard Analysis (JHA) integration. I've trained crews to flag §5164 risks in daily JHAs, spotting issues before inspectors do.

Spill Prevention and Response Training

§5164 ties into SPCC plans. 4-hour modules teach diking, absorbents, and PPE donning. Reference EPA's SPCC guidance and NFPA 30 for cabinets. Post-training drills build muscle memory—vital when a forklift tips a drum.

Limitations? Training alone won't fix poor site layout. Pair it with audits and Pro Shield software for digital tracking.

Actionable Steps to Implement Training

• Assess current storage via §5164 checklist from Cal/OSHA.
• Schedule HazCom refreshers quarterly.
• Certify 20% of crew as Competent Persons.
• Track via training logs for audits.

Results vary by enforcement, but consistent training slashes violations. Dive deeper with Cal/OSHA's free §5164 resources or NFPA standards. Your site's next inspection? Locked in compliant.