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The industrial accident that occurred in Rouen in September 2019 led to a reinforcement of accident management. In particular, feedback from this event has identified the need to know the quantity and nature of products stored. Certain sites are therefore required to keep a detailed inventory of stored materials.
This report can be used by the prefect or emergency services to manage an accidental event.
Stock status
From January1, 2021, all ICPE facilities subject to authorization will be required to maintain an up-to-date inventory of stored materials.
Note: in practice, this obligation is already included in many prefectoral decrees.
In addition to hazardous materials, this statement must also include non-hazardous combustible materials or materials not subject to ICPE classification: e.g. wood, paper, cardboard, polymers, chemicals, etc. present on site.
Detailed inventory status
Who should set it up?
As of January1, 2022, the following are required to maintain a detailed inventory of stored materials:
- facilities subject to registration or authorization classified as 1510 (covered warehouses);
- Seveso plants,
- sites authorized under one of the following headings: 1436, 2718, 4330, 4331, 4722, 4734, 4742, 4743, 4744, 4746, 4747 or 4748.
What should it contain?
For hazardous materials, it must indicate the different families of hazard statements for substances, products, materials or waste, when these statements may 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 families of products, materials or waste. Storage facilities presenting particular risks for managing fire and its consequences, such as battery storage facilities, are specifically listed.
It is accompanied by a general plan of the activity or storage areas used to produce the report.
Where the site has an internal operations plan (POI), the status of stored materials refers to it.
In addition, a report in synthetic format is to be set up. This should provide easy-to-understand information on the substances, products, materials or waste present in each activity or storage area. This format is made available to the prefect to meet the public's need for information in the event of an accident.
How to store it?
These conditions are to be defined by the operator in conjunction with the Prefect, the fire and rescue services, the Classified Installations Inspectorate and the health authorities. The condition of stored materials must be such that they can be used to manage an accidental event.
How often should I update?
It is updated :
- at least weekly;
- for hazardous materials and combustible liquefiable liquids and solids, at least daily.
In addition, a physical inventory must be carried out at least once a year. This can be done on a rotating basis, rather than all at once.
Conclusion
Thestate of the stored materials will thus provide the authorities with the information they need to manage an industrial accident, without being dependent on the site operator.
The Lubrizol action plan has also strengthened fire prevention at fuel warehouses and flammable liquid storage facilities, and introduced new measures for Seveso plants.
EHS regulations are constantly evolving for companies, so it's essential to keep up to date with the latest developments.
Photo credit: Markus Winkler