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Regulations for covered warehouses authorized, registered and declared under heading 1510 have evolved. Thus, the general requirements applicable to these warehouses are now defined by the Order of April 11, 2017.
I. Are your covered warehouses affected?
Covered warehouses storing at least 500 tonnes of combustible materials and products may be classified under heading 1510 of theICPE (installations classées pour la protection de l'environnement) nomenclature, depending on their volume:
Examples of materials concerned: edible oils, dairy products in their packaging, pallets, plastic film, textiles...
The exceptions are as follows:
- warehouses used to store categories of materials, products or substances covered by the ICPE nomenclature (e.g. plastics classified under heading 2662 or 2663),
- buildings intended exclusively for the storage of motor vehicles and their trailers,
- establishments open to the public(ERP),
- and refrigerated warehouses.
II. General requirements applicable to warehouses subject to heading 1510
The order of April 11, 2017 sets out the general requirements applicable to covered warehouses subject to authorization, declaration or registration under heading 1510.
In addition, facilities subject to heading 1510 that also fall under headings 1530, 1532, 2662 or 2663 are fully governed by this Order of April 11, 2017.
1. Applicability of the decree to new and existing plants
The decree applies in full to recent installations (notion of new installation in the regulations). These are installations with at least one of these criteria after April 16, 2017:
- proof of filing,
- the start of consultation with local authorities on the registration application,
- signature of the order to launch the public inquiry into the authorization request
However, if the application was submitted before July 1, 2017, the petitioner could ask the Prefect for a derogation. This derogation allows the installation to be considered as existing and not new.
Other installations are considered as existing. For requirements relating to fire resistance and behavior, the definitions given in the technical standards in force at the time of registration of the authorization or declaration must be taken into account.
Extensions or modifications to existing installations are considered as new installations when they require the filing of either:
- a new declaration
- a new registration request
- authorization beyond July 1, 2017
- or when the operator submits a request to the Prefect and the installation complies with the decree.
2. Contents of the order
The order is structured as follows:
The points of the decree that apply to existing facilities are defined in appendices IV (authorization), V (registration) and VI (declaration).
3. For existing installations
This decree imposes rules that are very similar to the decrees it repealed. In particular, it clarifies certain definitions:
- bulk and mass storage materials are more precisely defined
- new zones are defined (preparation or reception of orders) to exempt them from certain obligations.
Main requirements for existing installations :
- all authorized warehouses are now required to draw up a fire protection plan;
- in the event of a disaster, the operator must carry out an environmental and health impact assessment;
- the operator of a licensed or registered warehouse must organize an evacuation drill every 6 months;
- the maximum surface area of smoke extraction panels is now 1,650 m², compared with 1,600 m² previously;
- the operator must now define the measures required to reduce the risk of a fire occurring during the period of temporary unavailability of the sprinkler system. Personnel trained in fire safety tasks must be present at all times during this period;
- In addition to the instructions, there are measures for keeping the location of hazardous materials permanently up to date, and for informing the fire and rescue services, as well as the measures to be implemented when fire-fighting resources are unavailable.
Conclusion
If you operate a warehouse subject to heading 1510, whatever your submission regime (declaration, registration or authorization), this decree concerns you.
In terms of applicable requirements, it's important to study Annexes IV (authorization), V (registration) and VI (declaration). This will enable you to determine which ones actually apply to you. You will then be able to identify potential new requirements applicable to your site.
The elements outlined above will help you in this reflection.