What the Law Actually Says
Construction Regulation 25 is not vague, it is direct and enforceable.
It states:
“A contractor must… ensure that where flammable liquids are being used, applied or stored… it is done in a manner that does not cause a fire or explosion hazard, and that the workplace is effectively ventilated.”
This is the foundation.
If there is a fire risk, you are already non-compliant.
Smoking and Ignition Sources
The regulation goes further:
“No person smokes in any place in which flammable liquid is used or stored… and the contractor must affix a suitable and conspicuous notice…”
This is not optional signage.
This is a legal control measure.
And it is reinforced in General Safety Regulations 4:
“No employer shall permit any fire, flame or naked light… or anything which may generate static electricity… in any area where flammable liquid is used or stored.”
That includes:
- Grinders
- Welding
- Static discharge
- Poorly controlled electrical equipment
Quantity Control – One of the Most Ignored Requirements
Construction Regulation 25 clearly states:
“Only the quantity of flammable liquid needed for work on one day is taken out of the store for use.”
Yet most sites:
- Stockpile materials
- Keep open containers in work areas
- Store excess “just in case”
This is direct non-compliance.
Storage and Housekeeping
The regulation is explicit:
“All containers… are kept tightly closed when not in actual use… and after their contents have been used up, are removed from the construction site…”
And critically:
“No flammable material, including cotton waste, paper, cleaning rags… is stored together with flammable liquids.”
This is where real-world risk increases.
Rags + thinners + poor ventilation = ignition waiting to happen.
Fire Protection Requirements
Construction Regulation 25 requires:
“An adequate amount of efficient fire-fighting equipment is installed in suitable locations around the flammable liquids store…”
Not somewhere on site.
Not in the office.
At the point of risk.
Decanting – A Hidden Hazard
One of the most overlooked clauses:
“Where flammable liquids are decanted, the metal containers are bonded and earthed.”
Why?
Because static electricity can ignite vapours instantly.
Most sites:
- Pour between containers
- Use plastic containers
- Have no earthing controls
This is a serious compliance failure.
The Real Risk: Vapour, Not Liquid
General Safety Regulations 4 makes this very clear:
“No employer shall permit any person to work in a place where the vapour of any flammable liquid… constitutes an actual or potential fire or explosion hazard…”
And further:
“Any vapour… must be efficiently dispersed and diluted into the atmosphere…”
This is where ventilation becomes critical.
If vapour accumulates:
- You have created an explosive atmosphere
- One spark is enough
What Compliance Actually Looks Like
A compliant construction site demonstrates control, not assumption.
You should see:
- Controlled flammable liquid storage (fire-resistant where required)
- Clearly marked “No Smoking / No Open Flame” zones
- Daily issue control of materials
- Containers sealed when not in use
- Waste removed daily
- No mixing of combustibles and flammable liquids
- Fire extinguishers positioned at the hazard
- Controlled and ventilated work areas
- Safe decanting procedures (bonding and earthing)
Most contractors believe they are compliant because:
- They have extinguishers
- They store materials “somewhere safe”
But the law is not asking for effort, it is asking for specific controls.
Construction Regulation 25 is clear, General Safety Regulations 4 is even stricter.
If your site is not actively managing:
- Vapour
- Ignition sources
- Quantities
- Storage
- Handling
Then you are not compliant, and you are operating with a high-risk exposure.
ZSC helps you integrate safety into your project design, ensuring that all regulatory requirements are met, and your project proceeds without safety concerns. Contact us to learn how we can make your project safer and compliant from start to finish on 021 010 0209 or This email address is being protected from spambots. You need JavaScript enabled to view it.
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