Environmental Health and Safety Update
Flammable Liquid Storage Limits and
FDNY Permitting Requirements
Overview
The New York City Fire Department (FDNY) requires all work areas that store, handle and/or use
combustible/flammable liquids to have a permit if the quantity is over the permit threshold set in the Fire
Code. The FDNY also restricts the maximum amount of all combustible/flammable liquids that may be
stored in any work area. Chemical Owners are responsible for maintaining their stocks of
combustible/flammable liquids below their work area limit. This Update provides information on storage
permit thresholds and limits for work areas.
Applicability
This procedure applies to all WCMC Chemical Owners who purchase and maintain combustible and
flammable liquid inventories in their work area.
Responsibilities
Environmental Health and Safety provides guidance, training and assistance on flammable liquid
storage issues as needed and assists chemical owners with obtaining FDNY permits where required.
Chemical Owners are responsible for maintaining compliance with the FDNY combustible and
flammable liquid storage limits and ensuring that the area where combustible/flammable liquids are
stored, handled and/or used has a proper FDNY permit if those materials are over the permitting threshold.
Procedure
1. Based on the fire rating and fire protection system of the work area, the FDNY restricts the amount of
combustible/flammable liquids that may be stored or used. All Chemical Owners are required to
determine the permit thresholds of their spaces. All Chemical Owners should utilize their chemical
inventory to assist in calculating the inventory of combustible/flammable liquids that are stored or
used in their spaces. For additional information on the chemical inventory, please visit the
ChemTracker Chemical Inventory System EHS update.
2. In general, most work areas can be categorized as either a laboratory or a non-laboratory space. Below
are the permit thresholds and storage limits for each category of space:
Laboratory Units:
All laboratory units will have an FDNY permit prior to occupancy. The laboratory permit type
for each laboratory unit can be found on the Health and Safety Door Sign (HSDS) posted at the
laboratory’s entrance. If the laboratory does not have an HSDS, follow these steps:
1. Contact EHS to determine flammable storage limits for the laboratory.
2. Submit a HSDS request via the EHS website at
http://www.med.cornell.edu/ehs/forms_and_resources/door_sign_request_form.html.
March 2013
Weill Medical College of Cornell University ▪ Environmental Health and Safety
402 East 67th Street, Room LA-0020 ▪ Phone 646-962-7233 ▪ FAX 646-962-0288
ehs@med.cornell.edu ▪ http://weill.cornell.edu/ehs
EHS Update – Flammable Liquid Storage Limits and FDNY Permitting Requirements
The table below lists the permit thresholds for different laboratory types, the maximum storage
limits and the FDNY Certificate of Fitness that is required if the permit threshold is exceeded.
Type
Type I
Type II
Type III
Type IV
Permitting
Threshold
1 gallon
1 gallon
1 gallon
1 gallon
Maximum Storage
Limits (with Permit)
30 gallons
25 gallons
20 gallons
15 gallons
Certificate of Fitness
C-14 (Supervising
Chemical Laboratories)
a. Non-Laboratory Units:
For non-laboratory units, the permit threshold depends on the materials stored or used in the
space. The table below lists the permit thresholds for various materials and the FDNY Certificate
of Fitness that is required if the permit threshold is exceeded.
Materials
Class I Liquids (excluding
laboratories, paints, varnishes,
lacquers, gasoline and other
petroleum-based Class I liquids)
Gasoline and other petroleum-based
Class I liquids (excluding
laboratories, paints, varnishes, and
lacquers)
Rubbing alcohol
Alcohol-based hand rubs/sanitizers
(Class I)
Alcohol-based hand rubs/sanitizers
(Class II)
Oil-based paints, varnishes, and
lacquers
Class III combustible liquids
Permitting
Threshold
Maximum
Storage Limits
(with Permit)
Certificate of
Fitness
5 gallons
2½ gallons
5 gallons
5 gallons
Determined by
the FDNY
Permit type
issued
C-98/C-26 (Storage
And Use Of
Flammable and/or
Combustible
Liquids)
10 gallons
20 gallons
70 gallons
i. For all non-laboratories and non-permitted units, the Chemical Owners must ensure that
combustible/flammable liquids are maintained below the permitting threshold.
ii. If routine operations require that the unit maintain an inventory of
combustible/flammable liquids in excess of the permitting threshold, the Chemical
Owner of the unit must contact EHS for assistance in initiating the permitting process
with the FDNY. The FDNY permit type issued will determine the maximum
combustible/flammable liquids that can be stored/used in the unit.
3. For any unit/space that requires an FDNY permit, the unit must be under the personal supervision of a
Certificate of Fitness holder. For laboratories, the FDNY requires a Certificate of Fitness for
Supervising Chemical Laboratories (C-14). For non-laboratory units, the FDNY requires the Storage
and Use of Flammable and/or Combustible Liquids (C-98/C-26) Certificate of Fitness.
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EHS Update – Flammable Liquid Storage Limits and FDNY Permitting Requirements
4. If the amount of combustible/flammable liquids stored or used is over the storage limits, Chemical
Owners must reduce the amount and modify purchasing practices in order to maintain compliance
with FDNY regulations.
Definitions
Class I Flammable Liquids are liquid mixtures, substances or compounds which will emit a flammable
vapor and have a closed cup flash point below 100°F (38°C). Examples include Acetone, Acetonitrile,
Ethanol, Hexanes, Isopropanol, Methanol, N,N,N',N'-Tetramethylethylenediamine, and Xylene. To
determine whether a chemical is flammable, refer to the manufacturer’s label or the Safety Data Sheet
(SDS; formerly Material Safety Data Sheet, or MSDS).
Combustible liquids are liquids which emit a flammable vapor at temperatures between 100 degrees
Fahrenheit and 300 degrees Fahrenheit when tested in a Tangliabue open cup tester. Examples include
Acetic acid, naphtha and Stoddard solvent. Combustible liquids are referred to as Class II or Class III
liquids:



Class II liquids - flash points at or above 100°F (37.8°C) and below 140°F (60°C).
Class IIIA liquids - flash points at or above 140°F (60°C) and below 200°F (93.4°C).
Class IIIB liquids - flash points at or above 200°F (93.4°C).
Rubbing alcohol is a liquid that typically contains 70% of either ethyl or isopropyl alcohol. Rubbing alcohols
are considered a Class I flammable liquid (flash point below 100°F).
Alcohol-based hand rubs/sanitizers are defined by the New York City Fire Code as alcohol-containing
preparations designed for application to the hands for anti micro-bacterial or other medicinal purpose. They
usually contain ethanol or isopropanol in an amount not exceeding 70 percent by volume. They are typically
classified as either a Class I flammable liquid (flash point below 100°F) or a Class II combustible liquid
(flash point at or above 100°F and below 140°F).
Laboratory Units are enclosed, fire-rated spaces used for testing, research, experimental or educational
purposes. A laboratory unit may consist of a single room or an entire floor of a building depending on its
construction.
Safety Data Sheets (SDSs) are documents created by chemical manufacturers or suppliers which identify
a chemical’s physical and health hazards, exposure limits, precautions, personal protective equipment
required when handling the material, and procedures that should be followed in the case of an emergency.
SDS’s are available from the manufacturer. Additional information can be found on the EHS MSDS
website can provide assistance.
Health and Safety Door Signs (HSDS) provide emergency contact and hazard information for laboratory
spaces. Additionally, this sign identifies all areas included within that laboratory unit as well as the
flammable liquid storage limit. Please visit EHS website to get more information or request a door sign at
http://www.med.cornell.edu/ehs/forms_and_resources/door_sign_request_form.html.
References
FDNY: New York City Fire Code
WCMC EHS: Laboratory Chemical Hygiene Plan
WCMC EHS: ChemTracker Chemical Inventory System update
WCMC EHS: Health and Safety Door Sign program
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