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.

Oxygen Cylinders in Fire Rated Cabinets

Q: In regards to oxygen cylinder storage, if the quantity of gas in storage is between 300 and 3000 cubic feet in a smoke compartment and the full cylinders are being stored in a fire-rated medical gas cabinet, the hospital was told that they do not need to be stored in a specially designated room. They were told the fire-rated cabinets act as a room themselves and they could place the cabinets anywhere in the smoke compartment. I don’t see it that way, and I believe that the cabinets only allow the cylinders to be stored without the need for separation from combustibles. Question is: What is permitted?

A: I believe you are correct. Section 11.3.2 of the NFPA 99-2012 says storage of non-flammable gases greater than 300 cubic feet but less than 3,000 cubic feet shall comply with the requirements of 11.3.2.1 through 11.3.2.3. Section 11.3.2.1 says storage locations shall be outdoors or within an enclosed interior space of noncombustible or limited combustible construction, with doors that can be secured against unauthorized entry. Section 11.3.2.2 says oxidizing gases cannot be stored with flammable gases, liquids or vapors.

11.3.2.3 says oxidizing gases must be separated from combustibles by one of the following:

  • Minimum of 20 feet
  • Minimum of 5 feet if the entire storage location is sprinklered
  • Enclosed cabinet on noncombustible construction having a minimum fire protection rating of ½ hour.

So… there you have it. Those yellow “Fire Cabinets” are double-walled construction and really only rated for 30 minutes and they are commonly called “NFPA 30” cabinets. But they are permitted to be used in lieu of having to meet the 5 foot or 20 foot distance requirement inside a designated room that is constructed with noncombustible or limited combustible materials, and has a door that is lockable. Limited combustible materials are traditionally gypsum wall board that has a thin layer of paper on the surface.

But make no mistake about it… while the oxygen cylinders may be stored inside the metal cabinets, they still must be stored inside a designated room with a lockable door.