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Subject: Re: Laboratory use of oily rag containers?
Date: Wed, 12 Oct 2011 11:04:03 -0700
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Subject: Re: Welding Fumes
Date: Wed, 12 Oct 2011 14:28:09 -0500
Author: "Duke, Roderick L"


Date: Wed, 12 Oct 2011 15:25:12 -0400
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Subject: Re: Laboratory use of oily rag containers?
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On Oct 12, 2011, at 12:01 PM, Bethicia Prasek wrote:

Does anyone know where I can find the regulations related to storage of oily rags in laboratories? We have a service take the rags and return them clean, but aren=92t sure how to store them in the meantime. Do the containers need to be made of metal? Do they need to be red? Thank you.

Let me start with a discussion of the history of some of the pertinent OSHA regs.  Apparently: 

29 CFR 1910.108 is now apparently deprecated.   It did call for "OSHA 29 CFR 1910.108 (f)(2):, (2) Waste Cans. When waste or rags are used in connection with dipping operations,  approved metal waste cans shall be provided and all impregnated rags or waste deposited therein immediately after use. The contents of waste cans shall be properly disposed of at least once daily at the end of each shift."  However, that rule disappeared some years back when the dipping and coating standards were rewritten: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=PREAMBLES&p_id=862   Part of that went into 29 CFR 1910.125(e) http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9775&p_table=STANDARDS which states at paragraph (e)(4)(2) which states "Rags and other material contaminated with liquids from dipping or coating operations are placed in approved waste cans immediately after use"; in earlier versions the word "metal" was included after the word "approved".  It is gone now. 

29 CFR 1910.106 Flammable and Combustible Liquids, http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9752  addresses the issue at paragraph (h)(8)(iii):

1910.106(h)(8)(iii)"Waste and residues." Combustible waste material and residues in a building or operating area shall be kept to a minimum, stored in closed metal waste cans, and disposed of daily.

However, OSHA STD 1-5.13 (which is presumably still in effect)  http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1777 indicates:


1. Purpose

The purpose of this directive is to give guidance on citing for the use of approved nonmetallic waste cans, where the OSHA standard requires a metal waste can.

2. Documentation Affected

None

3. Background

a. There are several OSHA standards that require approved metal waste cans or metal waste cans. Presently, there are approved nonmetallic waste cans on the market.
b. It is not the intent of OSHA to discriminate or restrict employers from using new materials or products providing the products are approved or listed by nationally recognized testing laboratories for the particular use or exposure at the worksite.

4. Action

Where the employer is found using an approved nonmetallic waste can that is approved for its particular use or exposure at the worksite by a nationally recognized testing laboratory; and, the nonmetallic waste can is in violation of an OSHA standard requiring a metal waste can, the violation shall be considered "de minimus."
In short, some it appears that OSHA has been phasing out the metal requirement. And if you read the Action line above carefully, using a plastic (or any other material) can approved by a national testing lab is not a violation..

My company distributes Eagle Manufacturing products.   A few years back they (and some other manufacturers) discontinued selling metal oily waste cans and went entirely to polyethylene.  These cans are FM-approved and meet OSHA 30 requirements for *temporary* storage of oily waste materials.  See, for example http://www.safetyemporium.com/?02133-A (disclaimer: that's my company web site) and http://www.eagle-mfg.com/pdf/Eagle_Oily_Waste_Can_Flyer.pdf

Polyethylene has many advantages over galvanized steel - they are harder to dent/deform/destroy, less are expensive, they can handle corrosive materials, they don't rust or need painting, self-closing mechanism is less likely to fail etc.   Either type of container will exclude oxygen to snuff an incipient fire and can do the job just fine.  Plastic would be my personal preference, but metal cans are still available from Justrite and other manufacturers if you have a hankering for it.

Rob Toreki

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