January HSEES Deadlines Reminder

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January 1, 2024: Traceability of Used Oils on Trackdéchets

All collection of used oils must be documented with a digital manifest on the Trackdéchets platform.

To learn more about changes in used oil management: https://hse-reglementaire.com/nouvelles-modalites-de-gestion-des-huiles-usagees/

January 1, 2024: Change in Gas Detection Threshold for Combustion Installations Declared Under 2910

The sensitivity of gas detection in combustion installations declared under heading 2910 must be improved: its detection threshold must be reduced from 60% to 30% of the LEL (Lower Explosive Limit).

For installations whose declaration file predates March 1, 2023, this detection must be modified by January 1, 2024.

January 1, 2024: Radon Risk Assessment and Other Ionizing Radiation: New Methods for Calculating Effective Doses

1) The dose coefficients used to calculate the effective dose from radon exposure have been updated. Previously, an effective dose threshold of 6 mSv/year (*) could be reached at around 950 Bq/m³.

Consequently, this 6 mSv/year threshold can now be reached for radon activity concentrations in the air of:

• 450 Bq/m³ for sedentary activity
• between 100 and 150 Bq/m³ for a non-sedentary activity

(*) if this threshold is exceeded, the employer must implement certain measures (e.g., appointment of a radiation protection advisor, dosimetry, enhanced individual monitoring, etc.).

To learn more about radon: Radon Exposure: All Businesses Are Concerned - HSE Blog - https://hse-reglementaire.com/

2) For other ionizing radiation (e.g., use of sealed sources, etc.), the rules for calculating effective doses have been modified.

01/01/2024: Greening of Vehicle Fleets

Companies managing a fleet of more than 100 light vehicles (*) must now acquire low-emission vehicles for at least 20% of their fleet renewal.

(*) vehicles managed by a company's subsidiaries headquartered in France, as well as vehicles managed by its establishments located in France, are taken into account when assessing the size of the fleet managed by the company.

01/01/2024: Ban on the Disposal of Certain Waste in Non-Hazardous Waste Landfills

The ban on disposing of recoverable non-hazardous waste in non-hazardous, non-inert waste storage facilities applies from January 1, 2024, to the loading of skips or other relevant containers consisting of more than 30% by mass of biowaste.

01/01/2024: New Certibiocides

As a reminder, the use, sale, and purchase of certain types of professional-use biocides are subject to obtaining an individual Certibiocide certificate.

The following individual certificates are created, replacing the certificate for "professional user and distribution of certain types of biocide products intended exclusively for professionals":

• Certibiocide Disinfectants (product types 2, 3, and 4 for individuals acting as decision-makers, purchasers, or distributors)
• Certibiocide Pests (product types 14, 18, and 20 for individuals acting as professional users, distributors, or purchasers & product types 8, 15, and 21 for individuals acting as professional users, distributors, or purchasers)
• Certibiocide Other Products (product types 8, 15, and 21 for individuals acting as professional users, distributors, or purchasers)

Professionals engaged in the activity of professional user, distributor, or purchaser of product type 21, and professionals engaged in the activity of decision-maker, purchaser, or distributor of product types 2, 3, and 4 have one year to obtain their certificate. Certifications issued until December 31, 2023, are valid until the expiry date indicated on the certificate.

01/01/2024: Rooftop installation of a renewable energy production system or a greening system on new buildings, during major renovations, or extensions

Obligations to integrate a renewable energy production process or a greening system (or equivalent device) apply to the construction, extension, and renovation of the following buildings:

• buildings or parts of buildings used for commercial, industrial, or artisanal purposes, the construction of warehouse buildings, the construction of hangars not open to the public that are commercially operated, and the construction of covered parking lots accessible to the public, when they create more than 500 m² of ground footprint;
• buildings or parts of buildings used for offices, when they create more than 1,000 m² of ground footprint.

This concerns planning permission applications for such projects submitted from January 1, 2024.

01/01/2024: Requirements for installations subject to the registration regime under at least one of headings 4331 or 4734

As part of the implementation of the government plan known as "post-accident of September 26, 2019," existing installations classified under heading 4331 or 4734 under the registration regime are now subject to the following provisions:

• Prohibition of storage of Category 1 flammable liquids (hazard statement H224) in fusible containers such as mobile receptacles with a unit volume greater than 30 L;
• Supplemented fire defense plan;
• Completion of a thermal flux study to determine the distances corresponding to thermal effects in the event of an 8 kW/m² fire, at target height or, failing that, at human height.

01/01/2024: Radiation protection (e.g., use of sealed or unsealed sources) – strengthening of enhanced individual monitoring (SIR) for exposed workers

As a reminder, workers classified in Category A and B or exposed to radon are subject to enhanced individual monitoring (SIR).

1) As of January 1, 2024, a specific training obligation on risks related to ionizing radiation and on the individual dosimetric monitoring system comes into force for occupational physicians and occupational health professionals.

Note: As of January 1, 2026, occupational physicians and health professionals who have not received the specific training can no longer provide enhanced individual monitoring.

2) As of January 1, 2024, when the host company has an autonomous occupational health and safety service (SPST) holding additional accreditation, the enhanced individual monitoring (SIR) of external company workers is provided, jointly with the external company's SPST, by the autonomous SPST according to the terms defined in the agreement concluded between the companies.

Note: Previously, an agreement was made when the external company's SPST was not accredited to provide individual health monitoring for workers exposed to ionizing radiation.

The agreement must be appended to the prevention plan and sent to the DREETS and the labor inspectorate. Furthermore, the CSEs (external company and host company) are informed of its implementation.