Hand Sanitizer Risks

Published 28 June 2020

1              Hand Sanitizers

  1. Hand sanitizing and sterilizing liquids containing alcohol are deemed to be flammable and can be categorised as either combustible liquids, flammable liquids or flammable substances, depending on the applicable legislation.
  2. Quantities which may be legally stored on any premises are determined by the various applicable legislation, mostly by the local municipal authorities, and is determined by the Closed-cap Flash Point of the actual product. The highest found in the 5 municipalities by-laws I have considered, is 1100 litres without a flammable goods store or certificate being required.
  3. Ethanol (Ethyl Alcohol) is not poisonous and is the constituent of alcohol beverages which are consumed by humans.

Potential for Poisoning by Absorption

Various studies have been undertaken, but most of what I have found have been based on Ethanol based hand sanitizers and they have been found to be non-toxic and pose minimal risks, with quantities being absorbed through the skin being minimal.

During one study (link below) the following test methods and results were obtained.

Methods

Twelve volunteers applied three hand-rubs containing 95% (hand-rub A), 85% (hand-rub B) and 55% ethanol (hand-rub C; all w/w). For hygienic hand disinfection, 4 mL were applied 20 times for 30 s, with 1 minute break between applications. For surgical hand disinfection, 20 mL of each hand rub was applied to hands and arms up to the level of the elbow 10 times for 3 minutes, with a break of 5 minutes between applications. Blood concentrations of ethanol and acetaldehyde were determined immediately prior and up to 90 minutes after application using head space gas chromatography.

Results

The median of absorbed ethanol after hygienic hand disinfection was 1365 mg (A), 630 mg (B), and 358 mg (C). The proportion of absorbed ethanol was 2.3% (A), 1.1% (B), and 0.9% (C). After surgical hand disinfection, the median of absorbed ethanol was 1067 mg (A), 1542 mg (B), and 477 mg (C). The proportion of absorbed ethanol was 0.7% (A), 1.1% (B), and 0.5% (C). The highest median acetaldehyde concentration after 20 hygienic hand disinfections was 0.57 mg/L (hand-rub C, after 30 min), after 10 surgical hand disinfections 3.99 mg/L (hand-rub A, after 20 minutes).

Conclusion

The overall dermal and pulmonary absorption of ethanol was below toxic levels in humans and allows the conclusion that the use of the evaluated ethanol-based hand-rubs is safe.

https://bmcinfectdis.biomedcentral.com/articles/10.1186/1471-2334-7-117

  • Methanol (Methyl Alcohol) is highly toxic and can lead to serious poising and death. Methanol is a nondrinking type of alcohol (also known as wood alcohol which is mostly used to create fuel, solvents and antifreeze. It is a colourless liquid, it is volatile, flammable, and unlike ethanol, poisonous for human consumption. Methanol is also used to produce a variety of other chemicals, including acetic acid.

The initial symptoms of methanol intoxication include central nervous system depression, headache, dizziness, nausea, lack of coordination, and confusion.

Potential for Poisoning by Absorption

Various studies have been undertaken, but most of what I have found have been based on inhalation of fumes during industrial processes.

During one study (link below) the following test methods and results were obtained.

Methods

Available articles published from 1970 to 2016 that investigated the dose-response relationship for methanol exposure (i.e., the exposure concentration and the biological markers/clinical symptoms) were evaluated; the MEDLINE and RISS (Korean search engine) databases were searched. The available data from these articles were carefully selected to estimate the range and median of a lethal human dose. The regression equation and correlation coefficient (between the exposure level and urinary methanol concentration as a biological exposure marker) were assumed from the previous data.

Results

The lethal human dose of pure methanol was estimated at 15.8–474 g/person as a range and as 56.2 g/person as the median. The dose-response relationship between methanol vapor in ambient air and urinary methanol concentrations was thought to be correlated. An oral intake of 3.16–11.85 g/person of pure methanol could cause blindness. The lethal dose from respiratory intake was reported to be 4000–13,000 mg/l. The initial concentration of optic neuritis and blindness were shown to be 228.5 and 1103 mg/l, respectively, for a 12-h exposure.

Conclusion

The concentration of biological exposure indices and clinical symptoms for methanol exposure might have a dose-response relationship according to previous articles. Even a low dose of pure methanol through oral or respiratory exposure might be lethal or result in blindness as a clinical symptom.

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5625597/

  • Assumption

I have been unable to ascertain any information or data regarding the absorption of Methanol through the skin. Assuming however that it has the same absorption rate as Ethanol, and therefore if used in hand sanitizers, similar results of absorption as in the first mentioned study will result.

The lethal human dose of pure methanol was estimated at 15.8–474 g/person as a range and as 56.2 g/person as the median. Based on a 55% (if indeed accurate) concentration in hand sanitizers, and therefore absorption quantities of 0.9% (the lowest potential during the study), could lead to permanent blindness or death.

  • Risk of Use

Use of hand sanitizers and disinfectants from dubious sources are extremely dangerous.

Never purchase or use them if: –

  • they are not bar-coded.
  • they do not contain the manufacturers name and address on the label.
  • The contents are not included and clearly listed on the label.

Always obtain a Material Safety Data Sheet (MSDS)

Always check the MSDS and ensure that: –

Section 2 – Composition / Information on Ingredients lists

  • The chemical name / active ingredient lists Ethanol and not just Alcohol.

Section 3 – Hazardous Ingredients / Identity Information does not list

  • Any hazardous substances and in fact indicates “None”

Section 5 – Fire and Explosion Hazard Data includes

  • Flash Point Test Method “Closed Cup ASTM D 56” and does not say “None” (This would indicate no testing at a SANAS accredited laboratory who would have also identified the alcohol as being either Ethanol or Methanol)

2              Fire Risk

(Ethyl Alcohol 99.9%) has a flash point of between 12oC and 16oC. Diluting it to a 70% component decreases the flash point and it is required to be measured in a SANAS accredited facility. The results are to be included in the Material Safety Data Sheet (MSDS) to be obtained from the manufacturer / supplier and used to calculate the maximum quantities and conditions of storage.

2.1          Storage

Both hand sanitizers and surface sterilizers containing alcohol should be quantified together.

I would suggest prudence be applied and limit stock in areas for own use to no more that 50 litres in any room or area.

Storage for resale, at for example warehouses, supermarkets and pharmacies, also needs to be limited. A risk based approach must be considered and must include additional fire risk. In the event of a fire, repercussions could include an insurance claim being disputed.

2.2          Closed Cup Flash Point.

It is the authors opinion that legally, the product/s need to be tested and the Closed-cup Flash Point determined and included on Labels and Material Safety Data Sheets (MSDS’s)

3              Supporting information

I have spent time researching the South African legislation regarding alcohol-based hand sanitizers and disinfectants.

In essence I have looked at: –

1.           Act 85 of 1993 Occupational Health and Safety Act

2.           Act 15 of 1973 Hazardous Substances Act [as amended by Act 16 of 1976, Act 31 of 1981 and Act 53 of 1993]

3.           GNR 1031 of 30 May 1986 General Safety Regulations

4.           ASTM STANDARD D56: “STANDARD TEST METHOD OF FLASH POINT BY TAG CLOSED TESTER.”

5.           SANS 490:2013 Disinfectant alcohol-based handrub

6.           SANS 10228:2012 The identification and classification of dangerous goods for transport by road and rail modes

7.           SANS 10234:2008 Globally Harmonised System of classification and labelling of chemical (GHS) – Specifically part 8.2 – Safety Data Sheets and 8.3 (M) SDS Content – 8.8.3. table 3 Section 9

8.           Province of Western Cape Provincial Gazette Extraordinary 5832 of 28 February 2002 Cape Town Community Fire Safety B-laws

9.           City of Johannesburg Metropolitan Municipality Emergency Services By-Laws Notice 826 Gauteng Provincial Gazette Extraordinary No 179 Dated 21 May 2004

10.         Mangaung Metropolitan Municipality By-laws relating to Firefighting Services as promulgated in Provincial Gazette № 60 of October 2013

11.         Nelson Mandela Bay Metropolitan Municipality – Fire Services By-Law

12.         Durban Metropolitan Unicity Municipality – Municipal Notice No 27 of 2000 – Interim Code Relating To Fire Prevention And Flammable Liquids And Substances

4              Legislation and Standards

4.1         Government Notice R1301 of 30 May 1986 – General Safety Regulations

1. Definitions

“flammable liquid” means any liquid which produces a vapour that forms an explosive mixture with air, and includes any liquid with a closed-cup flash point of less than 55o Celcius.

4. Use and storage of flammable liquids

10.       An employer shall cause every flammable liquid store to be –

(b) constructed of fire-resisting material with a fire-resistance of two hours;

(c) constructed in such a way that, in case of a spillage, a volume of the flammable liquid in question equal to the quantity of flammable liquid ordinarily kept in store plus 10 percent of that quantity, can be contained;

(d) ventilated to the open in in such a manner that vapour cannot accumulate inside the store; and

(e) clearly marked with a sign indicating that it is such a store and also indicating the amount of flammable liquid which may be stored therein.

(11) taking into account the construction and location of the premises in question and the quantity and types of flammable liquids involved, an employer shall install and adequate amount of efficient fire-fighting equipment in suitable locations in and around every building in which such substances are used, handled or stored, or as my be recommended by the fire chief of the local authority concerned.

Note 1:           The definition refers to two factors which separately determine whether a liquid is indeed a flammable liquid.

(i)         Vapour forms an explosive mixture with air, or

(ii)        Has a closed-cup flash point of less than 55o Celcius

Note 2:           The closed-cup [in some regulations it is referred to as “closed-cap”] flashpoint is determined by means of a test and is described later.

Note 3:           This regulation does not legislate nor speak to quantities of any flammable liquid, but only regulates the store itself. These quantities are defined elsewhere.

4.2         Act 85 of 1993 Section 10 – General duties of manufacturers and others regarding articles and substances for use at work

(3)       Any person who designs, manufactures, imports, sells or supplies any substance for use at work shall –

(b)   take such steps as may be necessary to ensure that information is available with regard to the use of the substance at work, the risks to health and safety associated with such substance, the conditions necessary to ensure the substance will be safe and without risks to health when properly used and the procedure to be followed in the case of an accident.

Note 4:           The risks to health and safety and the conditions referred to and included in the requirement that “information is available”, includes within the steps to be taken:-

  • Determining the toxicity and flammability of the substances;
  • What hazards and risk are associated with transport, storage and use, and
  • What to do in case of an accident

This information is contained in MSDS’s and other labelling and MUST include for the purposes of this guideline, the Close-Cup Flash Point, which therefore MUST be determined.

4.3         SANS 10234:2008 Globally Harmonized System of classification and labelling of chemicals (GHS)

3.1.39 “flammable liquid” liquid that has a closed-cup flash point not exceeding 93 °C

3.1.41 “flash point” lowest temperature (corrected to a standard pressure of 101,3 kPa) at which the application of an ignition source causes the vapours of a liquid to ignite under specified test conditions

8 Safety data sheets

8.3         SDS content

8.3.1      An SDS shall provide a clear description of the data used to identify the hazards. The minimum information given in table 3 shall be included, where applicable and available, on the SDS under the relevant headings. If specific information is not applicable or not available under a particular subheading, it shall be clearly stated.

8.3.2      Some subheadings relate to information that is national or regional in nature, for example “EC number” and “occupational exposure limits”. Information should be included under such SDS subheadings that are appropriate and relevant to the countries or regions for which the SDS is intended and into which the product is being supplied.

8.3.3      Guidance on the preparation of an SDS under the requirements of the GHS can be found in annex C.

Note 5:           In South Africa we refer to a Material Safety Data Sheets (MSDS)

9.6.1.1   A flammable liquid is classified in one of four categories as indicated in table 9.

Table 9 — Categories and classification criteria for flammable liquids

Category        Classification Criteria

1                      Closed-cup flash point < 23 °C and initial boiling point < 35 °C

2                      Closed-cup flash point < 23 °C and initial boiling point > 35 °C

3                      Closed-cup flash point > 23 °C and < 60 °C

4                      Closed-cup flash point > 60 °C < 93 °C

9.6.1.2   For classification purposes, flammable liquids shall be tested in accordance with the test methods given in annex A of SANS 10228:2006.

Note 6:           This defines only the category to which a numeral value is assigned.

Note 7:           The test method of determining the classification is as per SANS 10228:2012 [A later revision than the one mentioned.]

Note 8:           These SA National Standards are incorporated in terms of Occupational Health and Safety Act 85 of 1993, Section 44(1) and are therefore part of the Act and legally required to be complied with.

Testing and determining of the closed-cup flash point of any potentially flammable liquid is therefore legally required.

9.6.2      Hazard communication

The label elements for flammable liquids are given in table 10. See also:

a) clause 6 for general and specific considerations concerning labelling;

b) annexure A, Allocation of label elements; and

c) annexure B, Hazard communication and classification summary tables.

Table 10 — Label elements for flammable liquids

Category        Symbol                       Signal word   Hazard statement

1                      Flame                          Danger            Extremely flammable liquid and vapour

2                      Flame                          Danger            Highly flammable liquid and vapour

3                      Flame                          Warning           Flammable liquid and vapour

4                      No symbol required     Warning           Combustible liquid

Note 8:           Once the category has been determined and a numeral value assigned, the container and packaging labels require the information in Table 10

Note 9:           The Supplement to SANS 10234 List of GHS classification and labelling of chemicals consists of an alphabetical list of chemicals classified in accordance with the GHS and a numerical list of the reclassified chemicals in accordance with the CAS (Chemical Abstracts Registry) numbers.

Note 10:         In 5.2.2 mention is made of “accredited laboratories”. In South Africa this refers to laboratories that are accredited by SANAS (South African Accreditation System).

3.1.14    CAS number

Number allocated to a chemical by the American Chemical Society’s Abstract Service

4.4         SANS 10228:2012 The identification and classification of dangerous goods for transport by road and rail modes

Note 11:         This is applicable as other standards refer to the methods incorporated into the standard.

9            Class 3: Flammable liquids

9.1         General

9.1.1      Class 3 includes the following substances:

a)    flammable liquids (see 9.1.2 and 9.1.3); and

b)    liquid desensitized explosives (see 9.2).

9.1.2      Flammable liquids are liquids, or mixtures of liquids, that might contain solids in solution or in suspension (for example paints, varnishes and lacquers, but not substances that, on account of their other dangerous characteristics, have been included in other classes), that give off a flammable vapour at or below 60 °C, closed-cup test (which corresponds to 65,6 °C, open-cup test).

9.5         Test methods for flammable liquids

The testing of flammable liquids for classification purposes shall be in accordance with the test methods given in A.3 for

a)    flash point A.3.1,

b)    initial boiling point A.3.2,

c)    viscosity A.3.3,

d)    solvent separation A.3.4, and

e)    combustibility A.3.5.

A.3         Test methods for flammable liquids of class 3

A.3.1      Tests for flash point

A.3.1.1   General

The flash point is not an exact physical constant for a given liquid. It depends to some extent on the construction of the test apparatus used and on the testing procedure. Flash point data should therefore specify the name of the test apparatus.

A.3.1.2   Non-viscous flammable liquids

One of the following closed-cup methods shall be used:

a)    the Abel apparatus, specified in ISO 13736; or

b)    the Pensky-Martens apparatus (close-cup method) specified in ISO 2719 (identical with ASTM D93 and IP 34).

5              Municipal By-laws

Note 12:         The definitions differ per municipality

5.1          Nelson Mandela Bay

“Combustible Liquid” means a liquid which has a closed-cap flashpoint of 93o Celcius or above

“Flammable Liquid” means a liquid or combustible liquid which has a closed-cap flash point of 93° Celcius or below

“Flammable Substance” means any flammable or combustible solids or liquids or flammable gas

“Store room” means a room for storage of flammable substances contemplated in section 65;

CHAPTER 5: PERMIT FOR USE, HANDLING AND STORAGE OF FLAMMABLE SUBSTANCES

51.         Use, handling and storage of flammable substances prohibited in certain circumstances

(1)   Subject to the provisions of subsection (3), no person may use, handle or store any flammable substance or allow such substance to be used, handled or stored on any premises unless that person is the holder of a permit issued by the chief fire officer in respect of the flammable substance and the premises concerned.

(2)   A permit contemplated in subsection (1) is not required if the flammable substance concerned is of any class and does not exceed the quantity stipulated in Schedule 2.

SCHEDULE 2

EXEMPTION FROM STORAGE PERMIT

A permit in terms of section 51 is not required if the flammable substances concerned are of a type and do not exceed the quantity stipulated below.

Class I             Liquids that have a closed-cap flash point of below 38° Celcius

Total maximum of 40 litres

Class II            Liquids that have a closed-cap flash point of 38° Celcius or above, but below 60,5° Celcius

Class IIIA        Liquids that have a close-cap flash point of 60,5° Celcius or above but below 93° Celcius

Total quantity of Class II and Class IIIA together may not exceed the maximum quantity of 210 litres

TABLE 1

Maximum quantities of hazardous substances for exemption from storage permits or certificates

3.         Group III: Flammable liquids

3.1       Flash point ≤ 18 º Celcius                                100 litres

3.2       Flash point > 18 º Celcius but ≤ 23 º Celcius                     420 litres

3.3       Flash point > 23 º Celcius but ≤ 61 º Celcius                     1 100 litres

3.4       Flash point > 61 º Celcius but ≤ 100 º Celcius                   1 100 litres

Note: 13          There is a difference between a storage permit and a storage certificate.

                        A certificate is a Certificate of Compliance issued by the fire chief and is for the flammable goods store.

                        A permit is the permit stating the quantities which may be stored in the flammable goods store.

Maximum quantities are calculated by the flash point. This is obtained from the product specific Material Safety Data Sheet (MSDS)

Note 14:         An administration area or office is not a store and quantities may not exceed those in Table 1.

                        A general warehouse is not a flammable goods store and most likely has no permit or certificate and similarly the quantities may not exceed those in Table 1.

5.2          Cape Town

‘‘Flammable Liquid’’ means a liquid, or mixtures of liquids, or a liquid containing solids in solution or in suspension that give off a flammable vapour at or below 60,5 ° Celcius

‘‘Flammable Substance’’ means a flammable liquid or a flammable gas

37(6)    The owner or person in charge of the premises may not store or use:—

(ii) a flammable liquid of a danger group (i), (ii), (iii) or (iv) in excess of 200 litres, unless he has obtained a flammable substance certificate from the controlling authority.

49(1)   The construction of a flammable store must be in accordance with the National Building Regulations (T1) read in conjunction with SABS 0400.

50(2)   A person may not extract flammable liquids from a container of a capacity exceeding 20 litres, unless the container is fitted with an adequately sealed pump or tap.

Note 15:          The maximum quantity permitted in an administration building or office is 200 litres.

                        None may be stored in a warehouse.

5.3          Mangaung

“dangerous good” means any substance, mixture of substances, product or material that has been declared to be a Group I, II, III, IV, V, VI, VII, VIII or IX dangerous good in terms of section 2(1) of the Hazardous Substances Act, 1973;

“hazardous substance” means any hazardous substance contemplated in the Hazardous Substances Act, No. 15 of 1973, any regulations made under that Act.”

“storeroom” means a room, which is constructed, equipped and maintained as contemplated in section 43 of these by-laws;

21(1) No person may on any premises use, handle or store quantities of dangerous goods in excess of the quantities referred to below or permit them to be used, handled or stored, unless and until the person is in possession of a certificate of registration as provided for in Annexure A to these by-laws and issued in respect of the specific quantities and appropriate devices on approved premises: Provided that if only one of the groupings referred to below is present on the premises and the applicable maximum permissible quantity is not exceeded, the provisions of this section are not applicable:

Group III: Flammable liquids

3.1 With flash points > 18 ° Celcius Total quantity may not exceed 100 ℓ

3.2 With flash points > 18 ° Celcius Total quantity may not but <23 ° Celcius exceed 420 ℓ

3.3 With flash points > 23 ° Celcius Total quantity may not but < 61 ° Celcius exceed 1 100 ℓ

3.4 With flash points > 61 ° Celcius Total quantity may not but < 100 ° Celcius exceed 1 100 ℓ

PART VI

STOREROOMS FOR DANGEROUS GOODS

REQUIREMENTS FOR STOREROOMS

39. (1) The certificate of registration issued for any storeroom for dangerous goods as contemplated in section 21 of these by-laws must indicate the group and the largest quantity of dangerous goods which may be kept in the storeroom.

Note 16:          The maximum quantity permitted in an administration building is 200 litres

                        None may be stored in a warehouse.

5.4          Johannesburg

“Combustible Liquid” means a liquid which has a close-cap flash point of 38o Celcius or above

“Flammable Liquid” means a liquid or combustible liquid which has a closed-cap flash point of 93o Celcius or below

“Flammable Substance” means any flammable liquid, combustible liquid or flammable gas

35(1) Subject to the provisions of subsection (3), no person may use, handle or store any flammable substance or allow such substance to be used, handled or stored on any premises unless that person is the holder of a certificate of registration issued by the Chief Fire Officer in respect of the flammable substance and the premises concerned.

(2) A certificate of registration contemplated in subsection (1) is not required if the flammable substance concerned is of any class and does not exceed the quantity stipulated in Schedule 2.

49. No person may store or allow the storage of any flammable substance in any storeroom unless –

(a) that person has a certificate of registration contemplated in section 35; and

(b) the storeroom complies with the requirements of these By-laws and any other applicable law.

SCHEDULE 2

EXEMPTION FROM CERTIFICATE OF REGISTRATION

Class I             Liquids that have a closed-cap flash point of below 38o Celcius

Total maximum of 40 litres

Class II            Liquids that have a closed-cap flash point of 38o Celcius or above, but below 60.5o Celcius

Class IIIA        Liquids that have a close-cap flash point of 60.5o Celcius or above but below 93o Celcius

Total quantity of Class II and Class IIIA together may not exceed the maximum quantity of 210

5.5          Mangaung

“storeroom” means a room, which is constructed, equipped and maintained as contemplated in section 43 of these by-laws;

Note 17:          No other relevant definitions are included.

21(1) No person may on any premises use, handle or store quantities of dangerous goods in excess of the quantities referred to below or permit them to be used, handled or stored, unless and until the person is in possession of a certificate of registration as provided for in Annexure A to these by-laws and issued in respect of the specific quantities and appropriate devices on approved premises: Provided that if only one of the groupings referred to below is present on the premises and the applicable maximum permissible quantity is not exceeded, the provisions of this section are not applicable:

Max Storage without a Permit

Group III: Flammable liquids

3.1 With flash points > 18 ° Celcius Total quantity may not exceed 100 ℓ

3.2 With flash points > 18 ° Celcius but <23 ° Celcius Total quantity may not exceed 420 ℓ

3.3 With flash points > 23 ° Celcius but < 61 ° Celcius Total quantity may not exceed 1 100 ℓ

3.4 With flash points > 61 ° Celcius but < 100 ° Celcius Total quantity may not exceed 1 100 ℓ

5.6          eThekwini

“Class I Flammable Liquid” means a liquid that has a closed cup flash point below 21° Celcius;

“Class II Flammable Liquid” means a liquid that has a closed cup flash point from 21 ° Celcius up to and including 55° Celcius;

“Class III Flammable Liquid” means a liquid that has a closed cup flash point from 55° Celcius up to and including 100° Celcius;

“Flammable Liquid” means any liquid or gas falling within the classifications Class O, Class I, Class II and Class III Flammable Liquid;

“Flammable Liquid or Substance” means any substance that is readily ignited or any Flammable Liquid;

“Flash Point” means the lowest temperature at which a substance gives off sufficient flammable vapour to produce a momentary flash on the application of a small flame;

CHAPTER IV FLAMMABLE LIQUIDS AND SUBSTANCES

21. No Person shall manufacture, store, convey, sell, use or handle Flammable Liquids or substances except in accordance with the provisions of this Code.

23. Certificate of registration to be obtained.

(1)        No Person shall—

(b) store, manufacture, sell, use or handle any Flammable Liquids or substances on any Premises in excess of the following quantities:

(i) Class I Flammable Liquid, 200 ℓ, or in the case of Liquefied Petroleum Gas, 48 kg;

(ii) Classes II and III Flammable Liquids, 400 ℓ;

(iii)     flammable substances, a quantity specified by the Chief Fire Officer;

27. Conditions for certificate of registration.

(1)(a) No Person shall on any Premises manufacture, store, use or handle or cause or permit to be manufactured, stored, used or handled—

(i) any quantity of Flammable Liquid or Substance in excess of the amount stated on the Certificate of Registration relating to such Premises;

(ii) any Flammable Liquid or Substance of a class other than the class or classes specified on the Certificate of Registration relating to such Premises;

(iii) any Flammable Liquid or Substance in a manner other than the manner stated on the Certificate of Registration relating to such Premises;

29. Supply of flammable liquids or substances

(2) No Person shall receive or accept delivery or cause or permit any Flammable Liquids or substances to be received at any one time—

(a) in excess of the quantities specified in section 23, at any Premises or Vehicle the Occupier or Person having control of which, as the case may be, is not in possession of a Certificate of Registration issued in terms of section 25 in respect of the said Premises or Vehicle;

(b) at any Premises or in or on any Vehicle in excess of the amount specified on the Certificate of Registration relating to such Premises or Vehicle.

49. Rules to be observed on unregistered Premises.—

(2) No Person shall use or handle or cause, allow or permit to be used or handled any Flammable Liquid or Substance on unregistered Premises, except in such a place in the open air as will prevent the accumulation of vapour or its ignition or in a room with ventilation which is adequate to remove the fumes therefrom and effectively prevent the accumulation of fumes therein

76. No Person shall use or permit the use of a store for the purpose of storing Flammable Liquid or Substance, unless it complies with the requirements of this Code and until warning notices conforming to sign W W 2 described in S.A.B.S. Specification 1186: Symbolic Safety Signs are legibly painted or otherwise displayed on the outer face of the door of such store and such notices shall at all times be maintained in such position and in a legible condition.

77. Construction and situation of store.—

(1) Every store shall be constructed in accordance with the following requirements—

(a) The walls shall be constructed of brick or concrete, the floor of concrete or other impervious material and the roof of reinforced concrete; provided, however, that the roof may be constructed of other Non-Combustible material where such store is not likely to endanger any room, Building or adjoining Premises in case of fire.

81. Storage in open air.—No Person shall store Flammable Liquid outside a Building or elsewhere in the open air except in accordance with the following requirements:

(1) The Flammable Liquid may only be stored in sealed Containers which shall be staked to a height not exceeding three Containers;

(2) No Flammable Liquid or drum shall be nearer than—

(a) 3 m from any boundary of the Premises or any drain;

(b) 6 m from any Building on the Premises;

(c) 15 m from any Building on adjacent Premises;

(3) the area in which storage takes or is to take place shall, if required by the Chief Fire Officer, be bunded to his satisfaction;

Disclaimer

Everything contained within this document is the opinion only of the author and should not be construed as legal or other advice.

Everyone is urged to obtain their own legal advice on matters of health and safety and should consult with professionals or legal practitioners.