The experts at Safety.BLR.com® have provided an answer to the following question: “We have a general industry Texas customer whose business insurance company is requiring that they store all their flammable aerosols in flammable lockers, even if there is less than 25 gallons. Is this true?”
Under the federal OSHA regulations, which are in effect in Texas and most states, flammable aerosols are considered a Category 1 flammable liquid. At industrial plants (which does not include chemical plants, refineries, or distilleries) up to 25 gallons of Category 1 flammable liquids stored in containers “may be located outside of an inside storage room or storage cabinet in a building or in any one fire area of a building” (29 CFR 1910.106(e)(2)(ii)(b)). Note that this limit applies only to those portions of an industrial plant where the use and handling of flammables is “only incidental to the principal business” (such as automobile assembly, construction of electronic equipment, furniture manufacturing, or other similar activities) or where flammable liquids are handled or used “only in unit physical operations such as mixing, drying, evaporating, filtering, distillation, and similar operations which do not involve chemical reaction”. You will need to determine if these standards apply in your situation.
The OSHA requirement in connection with storing Category 1 flammable liquids in a cabinet (meeting specified design and construction standards) states that “not more than 60 gallons of Category 1, 2, or 3 flammable liquids…may be stored in a storage cabinet” (29 CFR 1910.106(d)(3)).
So while it appears that, in some situations, fewer than 25 gallons of a Category 1 flammable liquid do not need to be stored in a storage cabinet, any quantity up to, but no more than, 60 gallons may be held in a storage cabinet.