Hazardous Material Storage Buildings - When Are They Required?
Properly storing hazardous materials is an essential step in protecting workers, the workplace, and the environment.
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Hazardous materials are solids, liquids, and gases that have physical and chemical properties that make them flammable, explosive, reactive, corrosive, radioactive, oxidizing, asphyxiating, biohazardous, pathogenic, allergenic, or toxic.
Clearly, they're not to be treated lightly.
Not only can these materials harm people, but they can also harm other organisms, the environment, and property.
It's essential, then, to store them safely and securely. Failing to do so could lead to exposure, harmful interaction, and uncontained spills (see 7 Things to Know About Storing Hazardous Materials to learn more).
In some cases, proper storage will mean housing in a hazardous material storage building. In this article, I'll explain when that's the case and go over the regulations you need to be familiar with if you're storing hazardous materials on your worksite.
When Is a Hazardous Material Storage Building Required?
In many cases, it's perfectly safe and compliant to store hazardous materials in your primary facility. When you exceed certain quantities of these, however, you will need to store them in specially designed indoor and outdoor storage buildings.
For starters, you need a HAZMAT building when you're storing hazardous substances in quantities that wouldn't fit in a hazardous material storage cabinet. Barrels, totes, and bulk bags should be stored in a compliant indoor or outdoor storage building, while a bottle, can, or box can usually be stored in a cabinet.
One notable exception are explosives, which must always be stored in explosive magazines, regardless of quantity. There are also some smaller quantities of flammable, combustible, or otherwise hazardous materials that, although they can be stored in buildings that have a general designation, must be separated from the rest of the buildings by firewalls, have adequate ventilation, and must be stored in rooms away from stairs and exits.
To take the guesswork out of this, several organizations have developed a regulatory framework that outlines the need and standards for hazardous material storage buildings.
Key Storage Regulations You Need to Know
Flammable and combustible substances that can ignite and set fire to your facility are of concern and should be stored in designated storage buildings.
According to OSHA's 1910.106 standard, containers stored in the building must be placed on pallets or similarly stable surfaces and have aisles at least three feet wide to allow fire equipment to get through.
Containers can be stacked, preferably on racks, but should be kept at least three feet away from beams or sprinklers (due to their size, this rule does not apply to storage lockers).
Drums and racks containing flammable substances have to be grounded. The building itself has to be grounded as well.
Flammable and combustible substances should not be housed in a storage building that also contains compressed gas cylinders (Compressed Gas Association Pamphlets C-6, C-8 and P-1). Gas cylinders should, instead, be secured with a chain, strap, or stand and stored in outside storage lockers. Full and empty cylinders should be segregated.
When substances are volatile and can result in explosive concentrations of vapor, the storage building must be vented and equipped with fire suppression or sprinklers and explosion relief panels. Transferring flammable and combustible fluids should only be done in storage facilities that are separated from the rest of the building,
The National Fire Prevention Association has several codes dealing with the storage of hazardous materials. The most relevant is NFPA 30, which specifies that combustible and flammable liquids (as defined by the code) must be stored in a non-combustible or fire rated building.
Uniform Fire Code
The International Code Council (ICC), International Building Code (IBC), and International Fire Code (IFC), together with the NFPA, have developed guidelines for storing flammable and combustible materials under the Uniform Fire Code.
These guidelines, however, are not mandatory and have no legal power unless federal, state, or local authority decides to enforce them.
The Environmental Protection Agency is, naturally, concerned with the environmental effects of spilling corrosive or acidic substances, pesticides, and poisons.
The EPA's 40 CFR 264.175 Code requires storage buildings and cabinets to be equipped with a secondary containment sump capable of storing either 10% of all stored hazardous substances or 100% of the largest recipient, whichever is greater. Containers that do not contain liquid are not included in the calculation.
Though not regulated, polyethylene is the most common material for a corrosives/acids storage building. For these substances, venting through a fume hood or other system is strongly recommended.
Pesticides, herbicides, rodenticides, and other poisons should have secondary containment and be locked.
Most jurisdictions simply follow OSHA regulations. However, because they are more explicit and stringent and save them the headache of developing their own standards, local authorities often adopt the NFPA and ICC guidelines.
Buildings are classified by their fire rating:
- Non-Fire Rated: Stored materials are neither flammable nor combustible – building can be made of regular construction materials or polyethylene
- Non-Combustible: Constructed exclusively of non-combustible materials, such as concrete and steel, and is suitable for storing combustible and flammable materials
- Fire Rated: Constructed of non-combustible materials with fire-resistant insulation in the walls
The required fire rating for a storage building depends not only on the materials it contains but also how distant it is from the main facility. Storage buildings located within 10 feet of the main building should have a 4-hour fire rating, while those located between 10 and 30 feet from the building only require a 2-hour fire rating. Storage buildings located further than 30 feet from the main facility do not require fire unless local codes stipulate otherwise.
Hazardous material storage buildings are generally designed to address specific packaging or scopes. Though not exhaustive, here is a list of the most common applications:
- Pallet and Totes – Usually equipped with racks sized to accommodate the containers of the stored material, they provide easy access for forklifts. Depending on the stored materials, they can be fire-rated or non-fire-rated and might not have secondary containment (if the stored material is not a liquid).
- Drums - The main feature of this storage is spill containment. Smaller buildings are usually set for one level storage and drums might be handled with a cart. Larger, multi-leveled storage buildings are set for forklifts.
- Multi-Compartment – These are versatile buildings that allow you to store different types of hazardous materials. Usually, each compartment is customized to respond to the hazards of the stored material and have their own venting and fire suppression, as well as individual sump containment to avoid mixing chemicals that might leak.
- Mixing and Dispensing – These buildings feature some type of ventilation to minimize worker exposure to harmful vapors and the build-up of potentially explosive vapors. For mixing flammable and combustible materials, explosion panels should be installed.
- Climate Controlled – Designed to maintain hazardous substances at an optimal temperature in order to improve their shelf life and minimize fire and explosion hazards. These units can be cooled (to prevent auto-ignition) or heated.
Keeping large quantities of dangerous substances scales up the health, safety, and environmental risks posed by these materials. Knowing where and how to store them is an essential part of protecting your workplace, your employees, and even the surrounding natural environment.