Aerosol Can Storage

Q: Our nursing home just completed a state survey and while we were not cited we were “warned” that all aerosols are to be put into fireproof cabinet. The metal cabinets and toolboxes we have them in currently are not adequate. We use metal toolboxes on housekeeping carts to store one can of each cleaning product we use. The surveyor said these would have be logged in and out daily from fireproof cabinet. Is this an actual NFPA requirement?

A: This is not a Life Safety Code requirement. I’m always suspicious when I hear a surveyor ‘warns’ a facility about an alleged issue rather than actually cite them. In this day and age of the CMS dominant mantra of “If you see it, cite it” mentally, I have to question why didn’t the surveyor actually cite it. One reason could be that it is not a violation of any code or regulation, but it is a surveyor preference. Perhaps the surveyor is using his/her authority to cajole the facility into doing something that is actually not required. Would the facility be safer if all aerosols are stored in a fire-rated cabinet? Perhaps, but if it is not a requirement then the ends have to justify the means.

You didn’t say what was in the aerosol cans; are the contents flammable? According to NFPA 30-2012 flammable liquids are permitted to be stored in their original containers up to 1-gallon in size, and you do not need special containment (i.e. fire-rated cabinet) until the aggregate total of the stored product (per smoke compartment) reaches 5 gallons. To me, aerosol cans placed on a housekeeper’s cart would not be considered in storage – they would be considered in use. However, there are other aspects to consider: Are the cans of aerosol products on the housekeeper’s cart safe from unauthorized individuals (i.e. children, dementia patients)? If not, then that may be a valid reason to place them inside a storage container.

I’m not telling you to NOT follow the surveyor’s advice, but I am saying the warning is not based on Life Safety Code or other NFPA requirements. Perhaps it is based on state or local regulations. If you haven’t already done so, ask him/her to cite the code or standard that requires the storage requirements. If there is an actual code or standard that requires it, then we learned something. But if there is not an actual code or standard that requires it, then the surveyor will back down and admit it is a recommendation or preference.

Storage of Flammable Liquids

Q: It is my understanding that you are only allowed to have 10 gallons of flammable chemicals in a smoke compartment without having a fire cabinet. Does this amount change if it’s a one hour fire rated, fully sprinkled room?

A: According to section 9.4.3 of NFPA 30 Flammable and Combustible Liquids Code, 2012 edition, the storage of Class IB flammable liquids (which is the typical flammable liquids you would find in a hospital, such as ethyl-alcohol) is limited to 5.3 gallons (20 L) per container made of metal, approved plastic, and safety cans.

According to section 9.5.1 of NFPA 30, to total volume of Class I, Class II, and Class IIIA liquids stored in an individual storage cabinet cannot exceed 120 gallons (460 L). The description of an approved storage cabinet is listed in section 9.5.3 (2) which is the type that used to be referred to as “fire-rated” storage cabinets, or “NFPA 30” cabinets. They basically stopped calling these cabinets “fire-rated” and refer to them now by their construction. Incidentally, section 9.5.4 does not require storage cabinets to be ventilated, even though ventilation openings are usually provided.

The maximum allowable quantity of flammable liquids (outside of storage areas) per control area is 10 gallons (38 L) for healthcare occupancies. A control area is defined by NFPA 30 as an area protected with fire-rated barriers. So, technically, smoke compartment barriers in a healthcare occupancy would typically not comply with the NFPA 30 definition of a control area, because smoke compartment barriers doors typically do not comply with the requirements for fire-rated doors. However, CMS and the accreditation organizations have overlooked this detail and allow smoke compartment barriers to serve as control areas for the purpose of storing Alcohol Based Hand-Rub (ABHR) product, which contains ethyl-alcohol.

According to 9.3.6 of NFPA 30, Class I flammable liquids are not permitted to be stored in floors below the level of exit discharge (basements).

Fire resistive rating for rooms for the storage of flammable liquids is dependent on the area of the room. According to Table 9.9.1, a storage room no more than 150 square feet must have a fire resistive rating of 1-hour. A storage room greater than 150 square feet but no more than 500 square feet must have a fire resistive rating of 2-hours. Storage rooms greater than 500 square feet are not permitted, unless you meet the more extreme requirements of a flammable liquid warehouse.

So, you can store up to 120 gallons of Class IB flammable liquids in a storage cabinet that meets the requirements of section 9.5.1 of NFPA 30, but the total quantity does not change if the flammable liquid is stored in a properly fire-rated storage room based on the total area of the room. Be advised that NFPA 30 does not differentiate whether the storage room is sprinklered or not.

However, I disagree with your opening statement that you are allowed to have 10 gallons of flammable chemicals in a smoke compartment without having a fire cabinet. NFPA 30 section 9.4.3 limits the maximum volume to 5.3 gallons of stored flammable liquids without have a fire cabinet.

Compressed Flammable Gas

Q: Can we store compressed butane gas cylinders used for food-warming and heating in the kitchen or do they require special storage?

 A: NFPA 30 requires all flammable gases and liquids exceeding 1 gallon (aggregate total) must be stored in a proper fire rated cabinet, or in a hazardous room with 1-hour fire rated barriers. You are not allowed to store mixed substances, such as combustibles with flammable liquids and gasses. For quantities less than 1 gallon, they must be stored in their original container, or in a special safety can. Joint Commission does have a standard (EC.02.01.01) whereby they could cite you for having any flammable liquid or gas stored outside a fire rated cabinet regardless of the quantity.  

Flammable Liquids

Q: Are there any special storage requirements for flammable liquids and flammable aerosol cans in the work area?

A: Yes, flammable liquids in all forms and capacities must be stored in compliance with section 8.4.3.1 of the 2000 edition of the Life Safety Code, which in turn requires compliance with NFPA 30, 1996 edition. According to NFPA 30, class IA flammable liquids are permitted to be stored outside of a protected cabinet as long as the container is not greater than 1 gallon. As long as the aerosol can is less than 1 gallon, you should not have a problem with keeping it in a regular cabinet. Once you reach an aggregate total of 5 gallons of class IA flammable liquids, then they need to be stored in a fire-rated cabinet.