Review of AS1940 for Compliance Certifiers and End Users

Should there be a fire in your building where flammable liquids from your Flammable Goods Cabinet have been released and enhanced that fire, insurance inspectors may go over your Class 3 Flammable Goods Cabinet with a fine-tooth comb, searching for a reason to reject your claim. If it was found that your cabinet did not comply, for any reason — pedantic or not — then your insurance company could delay or reject your claim, saying that you did not take all due care and responsibility to ensure the Flammable Goods Cabinet complied with AS1940…

1. There is no requirement for a Flammable Goods Cabinet to be “Yellow”.
2. “(a) The walls, floor, door and roof shall be of double-walled sheet steel construction, with a space of at least 40 mm between the walls. NOTE: This space may be either an air space or filled with non-combustible insulation.”
   We note that there are cabinets coming into NZ from the USA which use imperial measurements, with a 1.5 inch air space = 38.1 mm (which does not comply). Breaches (a). Therefore, a 40 mm air cavity plus the thickness of each skin. All of our cabinets are manufactured with 1.2 mm sheet steel and therefore measure at least 42.4 mm overall.
3. “(c) The inner base of the cabinet shall form a liquid-tight compound at least 150 mm deep, and shall be designed to prevent the compound from being used as a storage space.”
   Cabinets made in the USA and most other countries do not require a 150 mm deep bund. Most are only 50 mm–100 mm deep. Breaches (c).
   We know most compliance certifiers are all over this and require sequentially closing doors to close in the correct sequence every time, but another problem to look for is thin-walled cabinets which are pop riveted together… The pop rivets can become loose over time and can “rack” the cabinet sideways across the top, which puts the doors out of alignment. Even if the doors have a sequentially closing mechanism, the RH door can try to climb over the LH door, creating that gap at the top and bottom where fumes could escape and ignite. Also creating a door which does not self-latch and is not held shut, breaching (b).
4. “(c) The inner base of the cabinet shall form a liquid-tight compound at least 150 mm deep, and shall be designed to prevent the compound from being used as a storage space.”
   Cabinets made in the USA and most other countries do not require a 150 mm deep bund. Most are only 50 mm–100 mm deep. Breaches (c).
5. “(d) Any shelves shall be perforated to permit free air movement and shall be capable of carrying the maximum possible load.”
   Please note the wording of the above clause.
   Any shelves shall be perforated (perforated does not mean just 3 holes or 6 holes) to permit free air movement.
   Free air movement is the requirement… without free air movement, the cabinet shelf will not comply, which breaches (d).
   The risk:
   EG. Commonly used 20L flat bottom drums sitting on a shelf inside a cabinet completely covering the 6 holes in that flat shelf.
   Below this shelf is, say, Benzene or Formaldehyde or the like, maybe with its container lid loose giving off fumes. The bottom compartment where these chemicals may be kept then becomes a concentrated area of fumes which cannot escape through any Free Air Movement (supposedly perforations) which become encapsulated in the bottom compartment rather than being exhausted through the cabinet’s designed upper exterior vent outlets. The fumes should have exited through the perforated shelves towards the upper vent.
   Once the cabinet doors are opened, the fumes can escape and the technician is likely to be exposed day after day. The fumes from these and many chemicals are known to cause cancers and the likes of leukaemia.
   How many breaths would it take to contract such a disease? Who would be liable?
6. “(e) All leakage shall be directed into the lower compound.”
   No leakage can be directed on a flat shelf with 6 holes in it covered with flat bottom drums — instead, a greasy mess on the shelf may be the outcome. Breaches (e).
7. “(f) All cabinet doors shall be self-closing, close-fitting, and held shut automatically by catches at two or more points.”
   Self closing… meaning there is no human management to make this happen. Close fitting … meaning no gaps with doors in any sequence. Held shut automatically … meaning slam shut locks.
   See compliant sequentially closing doors, robust and positive https://youtu.be/ktERBv0siz0
8. “(g) Where doors are equipped with a device to hold them open when necessary, they shall be released automatically as soon as the temperature exceeds a nominal 80°C.”
   80 Degrees C is the law… but many substances will ignite and explode at substantially lower temperatures. Certifiers need to be aware of which low temperature ignition substances are stored inside the cabinet. Examples: Acetone –20°C, Benzene –12°C, Ethanol 16.6°C, Kerosene 38°C, Methanol 11–12°C.
9. “(h) The materials of any components that are critical to the cabinet’s structural integrity shall not melt at temperatures less than 850°C. Seals or gaskets are accepted but avoid their use if their failure could affect the protective function of the cabinet.”
   Aluminium pop rivets will melt at 610°C, die-cast garage door handles at 385°C. Also, WorkSafe requires no protruding items from a cabinet that could catch clothing in the event of people rushing past to vacate a fire.