Warehouse storage: Shaving cream subject to process safety rule?

PSM standards on aerosol products

In a recently issued letter of interpretation, OSHA explains that warehouses that store large quantities of common aerosol products such as shaving cream must follow the Process Safety Management (PSM) Standard at §1910.119 if the total weight of the flammable gases in the cans on premises equals or exceeds 10,000 pounds. OSHA’s reasoning is as follows:

• Flammable gases such as butane, isobutane, and propane are PSM-covered highly hazardous chemicals;
• §1910.119 applies if the quantity of flammable gas equals or exceeds the threshold quantity of 10,000 pounds;
• There is a covered activity, such as storage and onsite movement (e.g., forklifts moving pallets of boxes of aerosol cans); and
• None of the PSM exemptions apply because the aerosol distribution center/warehouse is not a retail facility.

SOURCE: PSM and Aerosol (Flammable Gas) Containers Stored in Warehouses/Distribution Centers [1910.119; 1910.119(a); 1910.119(d)(3)(ii)]; OSHA letter of interpretation – 6/28/2019