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Previous by Date: Subject: Re: [DCHAS-L] solvent drums Date: Tuesday, April 23, 2019 at 7:37:08 PM Author: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU> |
Next by Date: Subject: Re: [DCHAS-L] solvent drums Date: Tue, 23 Apr 2019 23:23:40 -0400 Author: ILPI Support |
The key Fire Code that determines this is the International Fire Code Chapter 50 Hazardous Materials. This will be what the Fire Marshal will use. As someone noted earlier it is based on whether the material in the drums meet the definition of Hazardous and whether there is a potential for a spill such as the forklift puncture. It notes
5001.3.3.4 Spill mitigation. Spill containment systems
or means to render a spill harmless to people or property
shall be provided where a spill is determined to be
a plausible event and where such an event would
endanger people or property.
Also Chapter 57 Flammable and Combustible Liquids
I did a quick review and saw no requirement for grounding of an unopened drum. Only one that is in use
Eugene Ngai
Chemically Speaking LLC
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Yaritza Brinker
Sent: Tuesday, April 23, 2019 5:19 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] solvent drums
I presume all of that was evaluated when we built this facility 6yrs ago. We hired an EH&S firm for the first 2 (if not 3) years to help us meet all requirements. Grounding of new unopened drums and use of spill containment platforms for storage of said drums were not part of the set-up. Since then, we added grounding. However, the actual requirements for grounding remain unclear. Now we’re looking at the spill platform idea. I think is a good idea, but need to figure out the requirements.
Thank you,
Yaritza Brinker
260.827.5402
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Zack Mansdorf
Sent: Tuesday, April 23, 2019 3:09 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] solvent drums
** External Email **
Yaritza:
This is actually much more complicated than a simple rule. It is multifactorial and highly dependent on a risk assessment.
Is this a lot of drums or just a few?
Do you have floor drains?
Do you have floor containment (sloped to contain any spill with raised sills and no drains)?
Are the solvents compatible with wood or should you be using plastic pallets?
Are the solvents compatible with the flooring?
Are the solvents highly volatile and with low OELs?
Are the solvents highly flammable?
Do you have adequate sprinklers (and the right type) for the storage in case of fire?
Do you have ventilation in the storage area?
Do you have spill response equipment?
I could go on for a long time but will stop here. Get the advice of a good IH or safety person that you respect.
In most locations, the local zoning board or the local fire marshal will approve this type of storage and use. Was that done?
Good luck
Zack
S.Z. Mansdorf, PhD, CIH, CSP, QEP
Consultant in EHS and Sustainability
7184 Via Palomar
Boca Raton, FL 33433
561-212-7288
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Yaritza Brinker
Sent: Tuesday, April 23, 2019 2:15 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] solvent drums
Hello,
Our new unopened drums are stored on a wood palette until they are needed. A colleague recently suggested that new unopened drums should be stored on a spill containment platform instead of the palette. However, I have visited plenty of facilities where new unopened drums are stored directly on the concrete floor. Is there a rule on this? Where can I find it?
Also, there’s some debate as to whether or not new unopened drums need to be grounded while in storage?
Thanks,
Yaritza Brinker
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