Bulk plants, tank farms, fleet fueling sites and fuel delivery trucks handle flammable liquid every hour of the day. The most serious hazards are not always obvious ones: a static spark while a tank truck is loaded through an open dome, benzene vapor at a loading rack, an oxygen-poor atmosphere inside a tank being cleaned, or a fall from the top of a truck. This guide sets out what OSHA, the EPA and the fire code require for each, what the fuel makers' safety data sheets recommend, and how to choose and use the equipment that goes with them.
Who sets the rules
| Source | Role | Examples in this guide |
|---|---|---|
| OSHA 1910.106 | Flammable liquid handling, storage, bulk plants and service stations | Bonding, safety cans, storage cabinets, no-smoking signs, emergency power cutoff |
| OSHA 1910.1028 and Table Z-2 | Benzene exposure | Who is covered, and the limits that apply |
| OSHA 1910.146 | Permit-required confined spaces | Tank cleaning entry |
| EPA 40 CFR 112 (SPCC) | Oil spill prevention | Secondary containment, loading racks, sorbents |
| International Fire Code | Fuel-dispensing facilities, as adopted by states | Emergency fuel shutoffs and signs (see our fuel storage fire extinguisher guide) |
| Safety data sheets | The fuel maker's PPE recommendations | Goggles, gloves, respirators, clothing |
Equipment at a glance
| Work area | Main hazards | Equipment to plan for |
|---|---|---|
| Loading rack | Static ignition, benzene vapor, spills, falls from truck tops | Bonding cables, goggles, nitrile gloves, gangways or fall arrest, spill kits |
| Tank farm | Spills, fire, tank entry | Secondary containment, sorbents, gas monitors, confined space equipment |
| Container filling and shop | Static, small spills, stored flammables | Safety cans, flammable storage cabinets, drip pans, spill pallets |
| Dispensers and fleet fueling | Fire, spills | Emergency shutoff signs, no-smoking signs, spill kits, fire extinguishers |
| Delivery trucks | Spills at customer sites, fire | Vehicle spill kit, fire extinguisher, gloves and goggles |
Static electricity and bonding
Fuel flowing through hoses and filters builds a static charge. Both gasoline and diesel safety data sheets classify the fuel as a static-accumulating flammable liquid and warn that bonding and grounding may not remove the hazard entirely.
Loading tank trucks through open domes. At bulk plants, OSHA requires a bond whenever gasoline or other liquids below a 100°F flash point are loaded through an open dome. The bond is required for higher-flash products too, such as diesel, when the truck may still hold vapor from an earlier gasoline load.
| OSHA bonding requirement (1910.106(f)(3)(iv)) | Detail |
|---|---|
| Bond wire | Metal wire permanently connected to the fill stem or rack, with a clamp on the free end |
| When to connect | Before the dome covers are raised |
| When to remove | Only after filling is complete and all dome covers are closed and secured |
| Fill method | Through a downspout reaching near the bottom of the tank |
| Not required | Loading through closed bottom or top connections; non-static-accumulating products such as asphalt and most crude oils |
Bottom loading through closed connections avoids both the open-dome static hazard and the trip to the top of the truck.
Filling containers. OSHA does not allow flammable liquids below a 100°F flash point to be dispensed into containers unless the nozzle and container are electrically connected, either by a bond wire or by a grounded metal floor plate under the container. At service stations, those liquids may only go into metal containers with a tight closure and a spout. The fire code, as adopted in states such as Ohio, adds that portable containers must not be filled in a vehicle's trunk, passenger compartment or truck bed, and fuel makers' safety data sheets say to place the container on the ground and keep the nozzle in contact with it throughout filling.
What happens without it. A static spark during filling of a portable steel tank set off fires and explosions at the Barton Solvents plant in Iowa. The U.S. Chemical Safety Board found the tank was grounded but the nozzle, hose and pump were not bonded to it. The Board cited NFPA 77's advice to bottom-fill portable tanks at no more than 1 meter per second until the fill pipe is submerged about 6 inches.
Benzene
Gasoline contains benzene, which OSHA regulates as a carcinogen. Whether the full benzene standard applies depends on where in the supply chain the work happens.
| Operation | Benzene rule that applies | Limits |
|---|---|---|
| Bulk plants and terminals without vapor control on all loading and unloading | Full benzene standard, 1910.1028 | 1 ppm over 8 hours; 5 ppm over 15 minutes; action level 0.5 ppm |
| Bulk loading with vapor control on all loading and unloading | Exempt, except hazard communication and emergency provisions | — |
| Everything after the bulk plant: delivery trucks, cardlock and retail dispensing | Exempt, unless fuel is dispensed indoors more than 4 hours a day | Table Z-2: 10 ppm over 8 hours, 25 ppm ceiling, 50 ppm peak |
OSHA confirmed in a 1988 letter to fuel marketers that the standard covers all bulk plants and bulk terminals unless they meet the vapor control exemption. Where the full standard applies, it brings exposure monitoring, regulated areas, respirators and medical surveillance, and requires eye and face protection and clothing to prevent contact with liquid benzene.
Eye protection and eyewash
Gasoline and diesel safety data sheets call for goggles or a face shield wherever splashing is possible, and say to flush the eyes for at least 15 minutes after contact. The benzene standard's appendix recommends splash-proof goggles, with a face shield if the face could be splashed. Look for the D3 splash marking under ANSI Z87.1.
Plan an eyewash station at loading racks and drum-filling areas, within reach of the work, so a worker can begin the 15-minute flush immediately. Browse safety goggles, face shields and eyewash products.
Gloves
| Fuel | Glove materials named on the safety data sheet |
|---|---|
| Gasoline (Marathon) | Nitrile, Viton or PVA for repeated or prolonged contact |
| No. 2 ultra-low sulfur diesel (Marathon) | Neoprene, nitrile or PVA |
| Ultra-low sulfur diesel (Shell) | Viton for longer-term protection; nitrile for incidental contact |
Nitrile is the common denominator. In Ansell's permeation tests, its 22-mil nitrile glove resisted unleaded gasoline for more than 480 minutes, while natural rubber latex was not recommended. Thin disposable nitrile is for splashes, not immersion, so match glove thickness to the task and check the glove maker's breakthrough data. Browse chemical-resistant gloves.
Respirators
Fuel makers' safety data sheets call for a NIOSH-approved organic vapor cartridge respirator, or supplied air, where vapor levels can exceed exposure limits. Any required respirator use falls under OSHA's written respiratory protection program, with medical evaluation and annual fit testing. One limitation matters around fuel tanks: a NIOSH and OSHA hazard alert on tank gauging deaths warns that organic vapor cartridges do not protect against light hydrocarbon gases or oxygen-deficient air. Where either is possible, supplied air or a self-contained breathing apparatus is required. Browse respiratory protection and detection.
Flame-resistant clothing
OSHA has no standard that names flame-resistant clothing for fuel distribution. Its 2010 enforcement policy, which requires flame-resistant clothing where there is a flash fire hazard, covers oil and gas drilling, servicing and production rather than bulk plants. For fuel distribution, the decision comes from the employer's own PPE hazard assessment, insurer requirements, and the safety data sheet. Shell's diesel sheet, for example, says to wear antistatic and flame-retardant clothing. Where a flash fire exposure is identified, choose garments certified to NFPA 2112 and follow NFPA 2113 for selection and care. Browse flame-resistant clothing.
Safety cans and flammable storage cabinets
Safety cans. OSHA defines a safety can as an approved container of no more than 5 gallons, with a spring-closing lid and spout cover, designed to relieve internal pressure in a fire. OSHA also limits container size by flammability category.
| Container | Category 1 | Category 2 | Category 3 | Category 4 |
|---|---|---|---|---|
| Safety can | 2 gal | 5 gal | 5 gal | 5 gal |
| Metal container (non-DOT) | 1 gal | 5 gal | 5 gal | 5 gal |
| DOT metal drum | 60 gal | 60 gal | 60 gal | 60 gal |
Gasoline's flash point is −45°F and diesel's is roughly 136 to 168°F; check the category on your fuel's safety data sheet. Type I safety cans have one opening for filling and pouring; Type II cans have separate fill and pour openings with a hose.
Storage cabinets. Outside a cabinet or storage room, OSHA limits each fire area to 25 gallons of Category 1 liquid and 120 gallons of Category 2, 3 or 4 in containers.
| OSHA cabinet rule (1910.106(d)(3)) | Detail |
|---|---|
| Capacity | No more than 60 gallons of Category 1, 2 or 3, or 120 gallons of Category 4, per cabinet |
| Fire performance | Interior stays at or below 325°F during a 10-minute fire test, with doors closed and joints tight |
| Metal construction | At least 18-gauge, double-walled with a 1½-inch air space, three-point lock, door sill raised at least 2 inches |
| Label | "Flammable—Keep Fire Away" |
Browse safety storage, including Type I and Type II safety cans and flammable storage cabinets.
Tank cleaning and confined space entry
A fuel tank being cleaned is a permit-required confined space. OSHA's rule defines a hazardous atmosphere as flammable vapor above 10% of its lower flammable limit, or oxygen below 19.5% or above 23.5%. Gasoline's lower flammable limit is 1.4% in air, so very little vapor is needed to reach 10% of it.
| OSHA confined space requirement (1910.146) | Detail |
|---|---|
| Testing order | Oxygen first, then flammable gases and vapors, then toxic gases |
| Instrument | Calibrated direct-reading instrument |
| Attendant | At least one attendant outside the space for the whole entry |
| Retrieval | Full-body or chest harness and retrieval line; a mechanical retrieval device for vertical spaces more than 5 feet deep |
| Equipment provided at no cost | Testing and monitoring, ventilation, communications, PPE, lighting, barriers, ladders, rescue equipment |
The testing order matters because combustible gas sensors need oxygen to read correctly. Multi-gas monitors that read oxygen, flammable gas (as % LEL), carbon monoxide and hydrogen sulfide cover these steps in one instrument; calibrate and bump-test them as the maker directs. Browse the MSA Altair 5X multigas detector and calibration gas, and fall protection and rescue equipment for retrieval.
Spill containment
The EPA's spill prevention rules apply to facilities with more than 1,320 gallons of aboveground oil storage in containers of 55 gallons or more.
| SPCC requirement | Detail |
|---|---|
| Bulk storage tanks | Secondary containment for the entire capacity of the largest tank, plus room for precipitation |
| Drums, totes and skid tanks | Secondary containment for the largest container, plus room for precipitation |
| Loading racks | Containment for at least the largest single compartment of any truck loaded there; warning lights, barriers, signs, wheel chocks or brake interlocks so trucks cannot pull away while connected; inspect the truck's lowest drain and outlets before it leaves |
| Diked areas | Drain through manual valves; flapper-type drain valves are not allowed |
| General containment | Dikes, curbing, drip pans, sumps, booms or sorbent materials sized to the most likely discharge |
OSHA adds that spills at bulk plant loading points must be kept out of sewers, drains and waterways. Mobile refuelers are excused from the sized containment rule but not from general containment, so equipping each truck with sorbents and a drain cover is a sensible way to meet it. Browse spill kits, sorbents, pads, rolls and booms and spill control pallets, and see our guide to choosing the right sorbent.
Working on top of tank trucks
OSHA's long-standing policy is not to cite falls from the tops of trucks and rail cars under its fall protection rules, except where the vehicle is inside or next to a building or structure where protection is feasible. Its general duty clause can still apply. A loading rack is the kind of structure that policy describes, so plan gangways, cages or overhead fall arrest at the rack. Bottom loading removes the need to climb at all. Treat fall protection at the rack as best practice, and use fall protection rated to OSHA's 5,000-pound anchorage standard where workers tie off.
Signs and emergency shutoffs
| Requirement | Source | Detail |
|---|---|---|
| No smoking at bulk plants | OSHA 1910.106(f)(6) | Signs posted conspicuously wherever flammable vapor is normally present |
| No smoking at fueling | OSHA 1910.106(g)(8) | Signs within sight of the customer; engines shut off during fueling |
| Emergency power cutoff | OSHA 1910.106(g)(3) | Clearly identified switch, away from the dispensers, that shuts off power to all of them |
| Emergency fuel shutoff | IFC, as adopted in states such as Ohio | Outside, within 100 feet of but at least 20 feet from the dispensers, labeled "EMERGENCY FUEL SHUTOFF" |
| Self-service warnings | IFC, as adopted | "No smoking" and "Place container on ground before filling" at each self-service island |
OSHA does not require NFPA 704 diamonds, but its hazard communication rule requires tanks to be labeled or identified by signs or placards. Browse safety signs and labels.
Fire protection
Extinguisher requirements at pumps, tank farms and loading racks are covered in our fuel storage fire extinguisher guide. The short version: a 2-A:20-B:C unit within 75 feet of every pump, high-flow or wheeled units at tanks and racks, and 10-B:C or more on placarded fuel trucks. Browse fuel storage fire extinguishers.
Common mistakes
- Grounding the tank but not bonding the nozzle. That was the failure at Barton Solvents.
- Filling a gas can in the truck bed. The fire code prohibits it; put the can on the ground.
- Relying on organic vapor cartridges at a tank hatch. They do not protect against light hydrocarbon gases or low oxygen.
- Assuming the benzene standard doesn't apply. Bulk plants without full vapor control are covered.
- Testing a tank for flammables before oxygen. OSHA requires oxygen first.
References
- 29 CFR 1910.106 (flammable liquids), 1910.146 (permit-required confined spaces), 1910.1028 (benzene), 1910.1000 Table Z-2, 1910.1200(f) (container labeling).
- OSHA letter of interpretation to the Petroleum Marketers Association of America, May 23, 1988; OSHA enforcement policy on flame-resistant clothing, March 19, 2010; OSHA memorandum on fall protection on rolling stock, October 18, 1996.
- NIOSH and OSHA Hazard Alert, Health and Safety Risks for Workers Involved in Manual Tank Gauging and Sampling (2016).
- 40 CFR 112.1, 112.2, 112.7 and 112.8 (SPCC).
- U.S. Chemical Safety Board, Barton Solvents case study (2008), citing NFPA 77.
- Ohio Administrative Code 1301:7-7-23 (fire code motor fuel-dispensing provisions, based on the International Fire Code).
- Safety data sheets: Marathon Petroleum gasoline (2018) and No. 2 ultra-low sulfur diesel (2016); Shell ultra-low sulfur diesel (2013). Check your supplier's current sheets.
- Ansell Chemical Resistance Guide, 8th edition.
This guide is educational. Requirements vary by state, jurisdiction and code edition, and selection and compliance remain the employer's responsibility. Confirm requirements with your safety manager, fire marshal and SPCC plan preparer.
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