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ECOLAW Lee Cowan <br /> REGULATORY AFFAIRS <br /> 0 336 931.2104 KAY CHEMICAL COMPANY <br /> 336 605.0423 8300 CAPITAL DRIVE <br /> m 336 482.5294 GREENSBORO, NC 27409-9790 <br /> Lee.Cowan@ecolab.com <br /> November 20, 2019 <br /> RE: Storage of CIP Oven Cleaner <br /> To Whom It May Concern: <br /> Per the OSHA rule of 29 CFR 1910.106(e)(2)(ii)(b), the regulation allows employers to store <br /> up to: (1) 25 gallons of Class IA liquids in containers, (2) 120 gallons of Class IB, IC, II, or III <br /> liquids in containers, and (3) 660 gallons of Class IB, IC, II, or III liquids in a single portable <br /> tank, outside of an inside storage room or storage cabinet in a building or in any one fire area <br /> of a building. Therefore, an employer may store flammable and/or combustible liquids within <br /> the facilities defined in 29 CFR 1910.106(e)(2)(i), in containers up to the quantities listed in 29 <br /> CFR 1910.106(e)(2)(ii)(b), in a cabinet or drawer that does not meet the specifications of a <br /> flammable storage cabinet described under 29 CFR 1910.106(d)(3). Such storage is <br /> considered as storage outside of an inside storage room or flammable storage cabinet. <br /> Given that CIP Oven Cleaner, is Class II and 2.5 gallons, it meets the requirements as stated <br /> above. Additionally, the SDS requirements for storage state in Section 7: Conditions for safe <br /> storage: Do not store near acids. Keep out of reach of children. Keep container tightly <br /> closed. Store in suitable labeled containers. The container that the product comes in is both <br /> suitable and labeled appropriately. The original packaging for this product has undergone <br /> Environmental Stress-Crack Resistance which is designed to evaluate a plastic bottle's <br /> resistance to failure by cracking when in the presence of chemical and physical stresses and <br /> performed according to test method ASTM D2561, Procedure B. As such, CIP Oven Cleaner <br /> has been adequately evaluated and needs no special storage. <br /> Should you have questions or require additional information, please let me know. <br /> Sincerely, <br /> Lee Cowan <br /> Regulatory Affairs Specialist <br />