From:Gary Jones(firstname.lastname@example.org )
Date:: Mon, 15 Jan 2001 11:30:04 EST
Doreen: I am not aware that EPA has any regulations that limit the amount of material that can be stored at press-side. There are regulations that limit the amount of hazardous waste that can be stored in a satellite storage area, which is 55 gallons. Perhaps you may be thinking about OSHA. OSHA does have a set of regulations that govern the storage and handling of flammable and combustible materials. OSHA's regulations on this fall under 29 CFR 1910.106. 1910.106 generally mirrors NFPA 30, but unlike NFPA 30 has not been updated in many years. In examining 1910.106, there are several provisions that could apply to the use of solvent at press-side and it depends upon how the operation would be classified under OSHA''s regulations as to whether the use of solvent was incidental to the operation or not. However, OSHA issued an important interpretation that seems to be almost right on point to the question. According a 1986 letter of interpretation, OSHA found that "Containers of flammable ink and adhesive at the Paramount Packaging Corporation which are necessary for a day's operation are not considered to be stored flammables. Such in-use flammables are not a citable violation of the standards at 29 CFR 1910.106 (d) or (e). The current NFPA 30 Code clarifies this circumstance as follows: "The quantity of liquid that may be located outside of an inside storage room or storage cabinet or in any one fire area of a building, shall not exceed...A supply for one day." Violations of 29 CFR 1910.106 (e)(2)(ii)(b) are de minimis violations if no more that a one day supply of flammable liquid is located in the production area. The handling of flammable liquids at the point of final use need to be in compliance with 1910.106 (e)(2)(iv)." Scott Schuler gave you quick summary of the regulations that pertain to 29 CFR 1910.106 (d), Container and portable tank storage. Based on OSHA's 1986 letter of interpretation, this section would not be applicable to those solvents used at press side. These regulations could apply to the same solvent stored or utilized in another manner elsewhere in the facility. Likewise, the limits at 29 CFR 1910.106 (e) relating to the amount of flammable and combustible liquids that can be stored outside of an solvent storage room or cabinet would also be situational.