The Ins and Outs of Lubricant Storage Regulations Page 1 of 3

The Ins and Outs of Lubricant Storage

Regulations
Garrett Bapp, Noria Corporation
Tags: lubricant storage and handling
Machinery Lubrication (10/2015)

Imagine youre going about your daily work routine and you receive a call that a gearbox has
just discharged oil everywhere. You go into reactive mode. You havent arrived on the scene yet
to assess the extent of the situation, but you have a general idea of what needs to be done
stop the equipment to prevent further damage and put down material to absorb the oil that has
leaked out already.

Next, you think about how to fix the equipment. Exactly how much oil has leaked out? How
much oil was in the equipment? Did the oil reach a drain or water source? Do you have the
proper tools and equipment to handle a situation like this? Do you need to notify your states
department of natural resources? Could the situation have been prevented?

Unfortunately, this is the reality many people face everyday when they report to work. At any
time, an accident or machine failure could occur, discharging oil. The good news is you can
prepare yourself and others for these situations before they arise. In some circumstances,
government regulations may come into play. Therefore, it is important to know what these
regulations are and if they apply to your plant.

OSHA and EPA

Regulations
According to the U.S.
Environmental Protection Agency
(EPA), any container that can
hold 55 gallons or more of
lubricant is considered bulk
lubricant storage. This means it
is not necessary to count the
storage volume for top-up
containers, 5-gallon pails and
even small equipment. However,
you will need to concern yourself
with containers that have a capacity of 55 gallons or more, including gearboxes, reservoirs,
hydraulic units, storage containers, etc. These capacities should be included in your total oil
storage amounts when determining whether federal regulations apply.

The Occupational Safety and Health Administration (OSHA) breaks down this accumulative
amount into 1,320 gallons of above-ground storage and 42,000 gallons of underground storage.
Facilities with accumulative amounts less than these volumes will not be required to have a Spill
Prevention, Control and Countermeasures (SPCC) plan. Still, it is a good idea to put some

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provisions in place for accidental oil discharges. For plants with storage amounts greater than
these OSHA standards, the first step should be to plan for an oil spill.

Preparing for an Oil Spill

A written SPCC plan should address questions such as how will the facility prevent oil
contamination to waterways and adjoining shorelines, as well as what practices and preparations
will be used to prevent and respond to oil discharges. The EPA does not require the use of
specific methods or equipment but allows individual organizations to decide which techniques are
appropriate for them. However, plans should be in compliance with Good Engineering Practices
(GEPs) and may need to be certified by a professional engineer.

Providing secondary containment for bulk lubricant storage containers should also be considered.
This may involve active or passive measures. Active measures are those that require a worker to
put something into place before or while work is performed. This could be as simple as covering
nearby drains or responding to a spill with a containment kit. Spill containment kits usually
contain absorbent socks, mats, granules, disposal bags and nitrile gloves. These items can be
lifesavers until further actions can be taken. Passive measures to oil containment consist of
putting and leaving something in place, such as a retaining wall around a large tank or spill
containment pallets under totes or drums.

Secondary containment can be divided into two categories: general and specific. General
requirements address the most likely discharges from storage and equipment. This would
include spills of unknown volumes. Specific requirements target major container failures and
focus on size and design. Although the EPA does not define a specific failure volume, it
recommends documenting the volumes you choose. When designing your plan, both secondary
containment categories may be employed. In certain cases where secondary containment is not
practical, the EPA offers leniency. Additional measures may also be used as long as they are
outlined in your plan.

There are several other components of an SPCC plan, such as visual inspections, integrity
testing, overfill protection, security measures, training and recordkeeping. A number of
companies are available to help you develop your plan. You can also find more information by
visiting the OSHA or EPA websites and searching for Title 40 CFR Part 112. Of course, be sure to
check your local and state laws, which are usually more stringent than the federal regulations.

NFPA Regulations
The Flammable and Combustible Liquids Code of the National Fire Protection Association (NFPA)
is not as stringent for most lubricant users because oils are considered Class IIIB liquids, which
have a flash point equal to or greater than 200 degrees F. These flammable and combustible
fluid regulations are broken into two classes based on the liquids flash point. Fluids with a flash
point of 100 degrees F and above are considered combustible, while those with a flash point
below 100 degrees F are considered flammable. These classes also have subcategories with
additional limitations based on the flash point and boiling point.

20% of plants do not provide secondary

containment for bulk lubricant storage

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containers, based on a recent survey at

MachineryLubrication.com

Because petroleum products typically have flash points at or above 200 degrees F, they
generally are classified as Class IIIB combustible liquids. However, this does not mean that all
oils are grouped into Class IIIB. You will need to read your safety data sheets to determine
under which category your lubricant falls. OSHA does not regulate the Class IIIB group but
makes suggestions for other classes that can be used for oil storage.

The NFPA regulations also have provisions for the design, construction and capacity of storage
cabinets. With so many cabinet options on the market, it can be confusing as to which type
should be purchased. My advice is to choose the one that best suits your needs and is not too
large, unless you know extra space will be required in the future.

The Flammable and Combustible Liquids Code also provides ventilation and storage
requirements for storage rooms. If you are striving for world-class lubricant storage, this
information can help you properly set up your lube room and modernize any outdated practices.

A Proactive Approach
Even if these lubricant storage regulations do not apply to your facility, you should still take a
proactive approach. Usually its not until an incident occurs that you discover how unprepared
your plant actually is. Workers often stand around not doing the right thing or not knowing what
to do. They may grab an absorbent boom or mat to keep oil from spreading, or apply kitty litter
to soak up a spill. While it will be easy to see the deficiencies in your plan as you look back on
the incident, its much better to prevent these spills in the first place.

4 Keys for Better Lubricant Storage

1. Develop Training Programs A training program that notifies
workers once and then gets lost in the daily shuffle will not be
effective. These programs must be updated and include periodic
training for personnel.
2. Purchase the Proper Equipment How can you be prepared if you
dont have the right tools? Having the proper safety equipment can
prevent disaster.
3. Use Visual Cues in the Field Walk down key drains that can
navigate to waterways, identify them appropriately and share this
information with all plant personnel.
4. Listen to Personnel on the Plant Floor These are the individuals
who see the flaws within the systems they use every day. Listen to
their suggestions and then take action.

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