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One-day supply of flammable ink and adhesive

Summary A regional office asked how flammable inks and adhesives used at a packing plant fit OSHA’s flammable liquid rules. OSHA said containers needed for a day’s operations were in use rather than stored, and described a one-day supply in the production area as a de minimis condition under the cited provision. OSHA now archives the memo as potentially outdated.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1986-09-26
Date issued
September 26, 1986
Status
Archived by the agency
OSHA archives this memorandum and says it may no longer represent OSHA policy.
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Flammable Liquids
Source
View the official document

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OSHA archives this memorandum and says it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 26, 1986

MEMORANDUM FOR:
LINDA R. ANKU
REGIONAL ADMINISTRATOR

FROM:
JOHN B. MILES, JR., DIRECTOR
DIRECTORATE OF FIELD OPERATIONS

SUBJECT:
Handling and Use of Flammable Liquids

This is in response to your memorandum concerning the Paramont Packing Corporation and an on-going inspection by the Philadelphia Area Office. It also confirms discussions between Joe Bode and Walt Siegfried.

Based upon the information presented in your memorandum, the company appears to use flammable liquids incidental to their principle business. Therefore, the regulations of 1910.106(e)(2) would be applicable. Section 1910.106(e)(3) appears to be inapplicable, since the flammables are not used in unit physical operations, such as those described by the standard.

Containers of flammable ink and adhesive at the Paramont Packing Corporation which are necessary for a day's operation are not considered to be stored flammables. Such in-use flammables are not a citable violation of the standards at 29 CFR 1910.106(d) or (e). The current NFPA 30 Code clarifies this circumstance as follows: " The quantity of liquid that may be located outside of an inside storage room or storage cabinet or in any one fire area of a building, shall not exceed...A supply for one day." Violations of 29 CFR 1910.106(e)(2)(ii)(b) are de minimis violations, if no more than a one day supply of flammable liquid is located in the production area.

The handling of flammable liquids at the point of final use need to be in compliance with 1910.106(e)(2)(iv).

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