Question: Is there any OSHA or NFPA guidance on where flammable storage cabinets can be located? I have seen one in a corridor near an exit door, which doesn’t seem right.
Answer: This is a great question, and one that we find many facility managers and EHS professionals have trouble with.
Because this cabinet you saw is located near an exit door, let’s first look at OSHA’s general requirements for exit routes, emergency action plans and fire prevention plans [20 CFR 1910.37-39].
Fire exit routes cannot be obstructed [29 CFR 1910.37(a)(3)] and they cannot become more narrow at any point. Depending upon where the cabinet is placed in the corridor, if someone is walking near the wall of that corridor and has to step around the cabinet to continue walking, that would make the exit route narrower where the cabinet is located and the cabinet would need to be removed. This is true of any item that someone may want to place in an exit route, not just a flammable storage cabinet.
Exit routes are also required to be free of hazards. It could also reasonably be argued that putting a flammable cabinet in a corridor constitutes a hazard to anyone exiting. This can be subjective since the point of a flammable storage cabinet is to safeguard its contents, but it could still be argued that the flammables in the cabinet present a hazard and therefore would not be permitted in an exit route [29 CFR 1910.37(a)(2)].
Next, let’s look specifically at OSHA’s flammable liquids regulations. Flammable storage cabinets cannot “limit the use of exits, stairways or other areas normally used for the safe egress of people” [29 CFR 1910.106(d)(5)(i)]. This citation echoes the formerly mentioned requirements for fire exit routes not to be unobstructed.
Moving on to consensus standards, NFPA 1 Fire Code and NFPA 101 Life Safety Code both use identical verbiage that addresses this topic: “no furnishings, decorations, or other objects shall obstruct exits or their access thereto, egress therefrom, or visibility thereof” [NFPA 101: 188.8.131.52.1 and NFPA 1: 184.108.40.206].
If any of these conditions apply to the flammable storage cabinet in your exit corridor, it needs to be relocated to another area that is not along an exit route. When it doubt, your local fire marshal is a great resource for situations like this when you may not be quite sure if a regulation or standard applies.
Do you have questions about the location of your facility’s flammable cabinets? Leave a comment below or email me at firstname.lastname@example.org!