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July 15, 2014
Are Your Container Storage Area Aisles Wide Enough?

The general standards for hazardous waste treatment, storage, and disposal facilities (TSDF) require the TSDF owner or operator to maintain aisle space to allow the unobstructed movement of personnel, as well as equipment for fire protection spill control and decontamination. The rule somewhat qualifies this requirement by saying that such aisle space must be maintained “unless it can be demonstrated to the Regional Administrator that aisle space is not needed for any of these purposes.”

Nothing is mentioned in the rule (which also applies to large and small quantity generators accumulating hazardous waste on-site without a permit) about how wide the aisles between containers should be. That decision is up to you, unless you live in a state that either specifies the aisle width in the TSDF’s permit or in the regulation. Some states add to their version of the federal rule that there must be enough aisle space to allow for inspections of the containers.

Many environmental professionals determine the aisle space for containers based on the size of the containers used at their facility. For example, four feet of aisle space may be just right for 55-gallon (gal) containers, as it allows enough space for inspections and emergency equipment. Those that recommend this width also suggest grouping no more than two containers side by side. Access to leaking containers should always be a concern, if for no other reason than a leak might result at any time from the forklift used to move the containers. Four to five feet between containers provides for easy inspections and movement of personnel and equipment, and allows an open 85-gal salvage drum to be placed over a leaking container and then flipped to hold the container contents. So follow the applicable requirements in your state and minimize spills and the consequences of emergency situations by thoughtfully organizing your container storage area.

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