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The industrial accident that occurred in Rouen in September 2019 led to stricter accident management regulations. In particular, the feedback gathered following this event identified the need to know the quantity and nature of stored products. Certain sites are therefore required to maintain a detailed inventory of stored materials .
This inventory may be used by the prefect or emergency services when managing an accidental event.
Inventory of stored materials
As of January 1st , 2021, all ICPE facilities subject to authorization must keep an inventory of stored materials up to date.
Note: In practice, this requirement is already included in many prefectural decrees.
In addition to hazardous materials, this inventory must include non-hazardous combustible materials or those not subject to ICPE classification, such as wood, paper, cardboard, polymers, and chemicals present on the site.
Detailed inventory of stored materials
Who must implement it?
As of January 1st , 2022, the following are required to keep a detailed inventory of stored materials up to date:
- facilities subject to registration or authorization classified under 1510 (covered warehouses);
- Seveso establishments,
- sites authorized under one of the following headings: 1436, 2718, 4330, 4331, 4722, 4734, 4742, 4743, 4744, 4746, 4747, or 4748.
What must it contain?
For hazardous materials, it must indicate the various hazard statement categories for substances, products, materials, or waste, where these statements could lead to classification under one of the 4XXX headings of the ICPE nomenclature.
For products, materials, or waste other than hazardous materials, the statement must mention the main categories of products, materials, or waste. Storage areas presenting specific risks for fire management and its consequences, such as battery storage, must be listed specifically.
It must be accompanied by a general plan of the activity or storage zones used to compile the statement.
When the site has an internal emergency plan (POI), the statement of stored materials must reference it.
In addition, a summary version of the statement must be implemented. It must provide simplified information on the substances, products, materials, or waste present in each activity or storage zone. This format is made available to the prefect to meet the public's information needs in the event of an accident.
How should it be kept?
These conditions are to be defined by the operator in consultation with the prefect, fire and rescue services, the classified installations inspectorate, and health authorities. The statement of stored materials must be usable during the management of an accidental event.
How often should it be updated?
It is updated:
- at least weekly;
- for hazardous materials and combustible liquid or liquefiable solid cells, at least daily.
Furthermore, a physical inventory must be carried out at least annually. It may be conducted on a rolling basis rather than all at once.
Conclusion
Thestatement of stored materials will thus help secure the information available to authorities for managing an industrial accident, without being dependent on the site operator.
The Lubrizol action plan has also strengthened fire prevention in warehouses for combustible materials and in flammable liquid storage areas, and has introduced new measures for Seveso establishments.
As HSE regulations for businesses continue to evolve, it is essential to maintain a regulatory watch to stay up to date.
Photo credit: Markus Winkler