Q: During a recent survey, the surveyor noted that we had two 64 gallon capacity containers which we use for document shredding, sitting side-by-side in the laboratory work room. He stated we couldn’t have them in the room because they exceeded 32 gallons capacity. I was under the impression that if it was in a secured area and in a room with positive latching and sprinkled it was OK. How far off am I? What about other areas, such as medical records?
A: Section 126.96.36.199 of the 2000 edition of the LSC says trash containers greater than 32 gallons must be stored in a hazardous room. Most authorities will consider document shredding containers to be equal to trash containers. Also, section 188.8.131.52 says all laboratories that employ flammable liquids in quantities less than what would be considered severe are considered hazardous areas. So, your laboratory is already considered to be a hazardous area, and should be protected accordingly. If it is new construction (plans for construction approved by local authorities on or after March 11, 2003) it would be required to be fully protected with automatic sprinklers and be protected with 1-hour fire rated barriers. If it is existing conditions (plans for construction approved by local authorities before March 11, 2003) then it needs to be protected with automatic sprinklers or with 1-hour fire rated barriers. You are allowed to have as many 64-gallon document shredding containers in the laboratory as you would like, since the laboratory is already classified as a hazardous area. Unless there are other contributing factors, it appears to me that the surveyor is incorrect in this finding. The medical records area would have to qualify as a hazardous room in order to allow the 64 gallon containers in there. [Editor’s note: The 2012 edition of the LSC will exempt approved document shredding containers up to 96 gallons capacity from having to be stored in a hazardous room.]