Recently, one of our subscribers asked the following question:
We have a lacquer thinner solution, a Category 2 flammable liquid, and plan to dispense it from an ordinary quart-sized spray bottle. The solution will be used as a cleaning solution; spray on and wipe off. Will this be a violation of any sort, NFPA or OSHA?
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This was our answer:
Only approved containers may be used for regulated flammable liquids. “Approved” is defined in OSHA as “approved or listed by a nationally recognized testing laboratory” 29CFR1910.106(a)(35). Metal, plastic, or glass containers meeting the requirements of the U.S. Department of Transportation are acceptable under 29CFR1910.106(d)(2)(i).
29 CFR 1910.106(d)(2)(iii) and Table H-12 specify the maximum container size depending upon the category of flammable liquid and the type of material from which the container is made.
| Table H-12: Maximum Allowable Size of Containers and Portable Tanks for Flammable Liquids | ||||
| Container Type | Category 1 | Category 2 | Category 3 | Category 4 |
| Glass or approved plastic | 1 pt | 1 qt | 1 gal | 1 gal |
| Metal (other than DOT drums) | 1 gal | 5 gal | 5 gal | 5 gal |
| Safety Cans | 2 gal | 5 gal | 5 gal | 5 gal |
| Metal drums (DOT specifications) | 60 gal | 60 gal | 60 gal | 60 gal |
| Approved portable tanks | 660 gal | 660 gal | 660 gal | 660 gal |
OSHA consistently sees flammable liquids in plastic and glass containers that are larger than allowed by the standard.
Also, under the Hazard Communication Standard, all workplace containers—not being used immediately—must be labeled with at least the following information:
- Identity of the chemical and
- All potential hazards associated with the chemical
Spray on, wipe off? Has the client tried finding a less hazardous, or at least less flammable, substitute? Many of the new cleaners might surprise you with their effectiveness.
You forgot to actually answer the question.
Thank you