In our latest installment of Ask the Expert, brought to you by the team of industry experts at EHS Hero®, we look at a recent question from a subscriber asking about the U.S. regulations for how much alcohol-based hand sanitizer can be stored in retail stores and depots. See what the experts had to say.
Q: Can you direct me to any regulations in the U.S. which define/restrict/regulate the allowed amount of alcohol-based hand sanitizer that can be stored in retail stores and depots in Massachusetts?
Alcohol-based hand sanitizer (ABHS or alcohol-based hand rub) which typically contains 60% or more ethyl alcohol, is considered under U.S. OSHA to be a Category 1 flammable liquid. Although it can easily evaporate at room temperature into an ignitable vapor, ABHS rarely causes a fire. Regardless, several sets of regulations and Fire Codes dictate both the quantity of ABHS that can be stored as well as the conditions under which it can be stored. Relevant to all states are OHSA flammable liquid storage rules at 29 CFR 1910.106(d), state and local fire codes, and at least two codes and standards from the National Fire Protection Association (NFPA). (Note that most fire codes refer to flammable liquids such as ABHS as a “Class 1” rather than “Category 1” flammable liquid.)
OHSA regulation 29 CFR 1910.126(d) applies to the storage of flammable liquids in drums or other containers not exceeding 60 gallons individual capacity. The design, rating and capacity, and construction of storage cabinets, inside storage rooms and warehouses are addressed in this regulation.
Most state fire regulations reference the state’s adoption of the “NFPA 30: Flammable and Combustible Liquids Code” as the standards that apply to the storage of ABHS. Massachusetts regulations require compliance with NFPA 30.
Although I have not had access to NFPA 30, it is my understanding that this NFPA code allows 263 gallons of Class 1 flammable liquid to be stored in one location provided certain conditions are met including:
• The maximum height of the pile (i.e. pallets) is 5 feet
• The storage of the liquids cannot obstruct access to egress in the room. A fire in the liquid storage cannot prevent egress from the room.
• Storage cannot be in a basement
• An inside storage room with a total floor area less than 150 square feet is required to be protected with fire-resistant construction of 1-hour (walls, ceiling floors)
• An inside storage room with a total floor area more than 150 square feet but less than 500 square feet must be protected with fire-resistant construction of 2-hours (walls, ceiling, floors)
• Inside storage rooms with a total floor area of 500 square feet or more are not allowed.
• Containment or drainage protection is required.
The Massachusetts Board of Fire Prevention regulations at 527 Code of Massachusetts Regulations (CMR) 1.00 (“Comprehensive Fire Safety Code”) adopt and incorporate the provisions of “NFPA 1:Fire Code, 2015 edition” as modified on a chapter by chapter basis by 527 CMR 1.05. This “modifying” state regulation at 527 CMR 1.05 states that you must comply with NFPA 30 in addition to complying with the flammable and combustible liquids standards of Chapter 60.1 to 60.4 and Chapter 66 of NFPA 1.
Other sections of 527 CMR 1.05 relevant to storage of ABHS include Section 1.12.8 concerning permits issued by the authority having jurisdiction (AHJ) such as your local fire department. According to Table 1.12.8.40 of Section 1.12.8, Massachusetts requires a permit to store more than 10 gallons of “alcohol-based hand rub preparations”. Storing above the 10-gallon threshold would require an extensive process of reviewing your building’s construction, fire alarm systems, sprinklers, defined fire control areas, and the current inventory of hazardous materials stored and used in your building. If you already have a flammable storage permit, you may be able to add ABHS to this existing permit.
In sum, a review of the OSHA flammable liquids regulation, applicable NFPA Codes, state regulations, and local fire code rules will determine the quantity of ABHS that can be stored and the conditions under which it must be stored which could necessitate a permit or license, depending on the jurisdiction in which the storage takes place.
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