New obligations: loss prevention in covered warehouses

Regulations relating to loss prevention in covered warehouses have changed: for warehouses subject to authorization under heading 1510, reference must now be made to the order of August 17, 2016. We offer an update on this change.

I. ICPE classification of warehouses

Covered warehouses storing at least 500 tonnes of combustible materials and products may be classified under heading 1510 of the ICPE (installations classées pour la protection de l'environnement) nomenclature, depending on their volume:

The following warehouses are not concerned by heading 1510:

• warehouses used to store categories of materials, products or substances covered by the ICPE nomenclature,
• buildings intended exclusively for the storage of motor vehicles and their trailers,
• establishments open to the public (ERP),
• and refrigerated warehouses.

II. Loss prevention in covered warehouses

The order of August 17, 2016 sets out the requirements applicable to loss prevention in covered warehouses:

• subject to authorization under heading 1510 ;
• subject to authorization under heading 1510 and also covered by one or more of the following headings: 1530 (paper/board storage), 1532 (wood storage), 2662 (polymer storage) or 2663 (storage of tires or polymer-based products).

Note that when all the provisions applicable to new installations are complied with, the ministerial decrees relating to headings 1530, 1532, 2662 or 2663 do not apply.

The order of August 5, 2002 on loss prevention in covered warehouses subject to authorization under heading 1510 is repealed and replaced by the order of August 17, 2016.

The obligations of the August 17, 2016 order can be grouped into 5 parts:

• General information (conditions of application, definitions, status of stored materials) ;
• rules governing layout and accessibility;
• rules relating to the fire behavior of warehouses (fire classification of materials, smoke extraction, compartmentalization, surface area of storage cells, incompatibility of materials, storage conditions, retention, containment of water and run-off likely to be polluted);
• rules governing fire-fighting equipment (automatic detection systems, fire hydrants, extinguishers, RIAs);
• provisions relating to warehouse operations (emergency exits, electrical installations, lighting, ventilation, boiler rooms, cleanliness, rules relating to fire and intervention permits, safety instructions, equipment maintenance, fire defense plan if floor area exceeds 50,000 m², surveillance and guarding).

The provisions applicable to existing facilities, i.e. those commissioned before September 15, 2016 or for which an application for authorization to operate has been submitted up to December 31, 2016, are defined in Appendix I of the Order.

Existing plants commissioned before January^1, 2003 or for which an application for authorization was submitted before July^1, 2003

The provisions applicable to them are those of articles 3, 5.I, 10, 14, 15, 22, 23, 24 and 25. The main new features compared with the Order of August 5, 2002 are as follows:

• • operators of warehouses with a floor area in excess of 50,000 m² are no longer required to draw up an internal operations plan (POI). They are now required to draw up a fire defense plan, based on a single-cell fire scenario. This fire defense plan is to be included in the POI "if it exists". The status of stored materials, safety data sheets (SDS), plans of premises and risk areas, and instructions for emergency access must be appended to the fire defense plan.
  • a document or file drawn up on the basis of an analysis of work-related risks must be drawn up for repair and refurbishment work. This document or file may be the prevention plan required by the French Labor Code.
  • safety instructions must indicate the need for a document/file for repair and refurbishment work, precautions to be taken when using and storing incompatible products, measures to be taken in the event of a leak from a container or pipe containing hazardous substances, and procedures for implementing collection system isolation devices.
  • plans of the premises and instructions for emergency access are made available to the fire and rescue services.
  • the fire hydrants have a nominal diameter of DN 100 or DN 150. External access to each cell is less than 100 meters from a fire hydrant, and the hydrants are well spaced out.

• • the flow rate and quantity of water required for extinguishing and cooling operations are calculated in accordance with technical document D9 "Guide pratique pour le dimensionnement des besoins en eau".

• the automatic sprinkler system can act as an automatic fire detection system in storage cells if it meets the requirements of the Order of August 17, 2016

Existing plants commissioned after January^1, 2003 or for which the authorization application was submitted after July^1, 2003

All the provisions of the order of August 17, 2016 are applicable, except for articles 4, 5, 6, 7, 13 and 15, which are applicable according to the procedures defined in the table in appendix I. The following changes can be noted in relation to the order of August 5, 2002:

• operators of warehouses with a floor area in excess of 50,000 m² are no longer required to draw up an internal operations plan (see 1. above).
• the maximum surface area of smoke extraction sections may be increased to 1,650 m² "for technical reasons", whereas in principle it should be limited to 1,600 m² ;
• Mezzanine storage of any product falling under at least one of the headings 2662 or 2663 is prohibited;
• the storage height of hazardous substances and mixtures covered by ICPE nomenclature 4xxx is no longer limited to 5 m above the interior floor, provided an automatic extinguishing system compatible with the products stored is in place;
• unit heater heating systems may be authorized in storage cells under certain conditions (see below).

New installations

The order of August 17, 2016 applies in its entirety to new facilities, authorized on or after January 1, 2017, and to extensions or modifications to existing facilities requiring the submission of a new authorization application after January 1, 2017.

III. Loss prevention for gas-fired unit heaters in storage cells

The order of August 17, 2016 amends several orders to incorporate the possibility of using a gas unit heater heating system in storage cells when certain conditions are met in the following facilities:

All of the following conditions must then be met for loss prevention:

• unit heaters must be type C as defined in standard FD CEN/TR 1749 (November 2015 version);
• piping supplying gas to a unit heater must be located outside the warehouse and penetrate the outer wall or roof of the warehouse at the unit heater, to keep the length of piping inside the cells to a minimum. The residual part of the piping inside the cell must be located in a sheath made of class A2 s1 d0 material to evacuate any gas leaks outside the warehouse;
• the gas supply pipe must be made of steel and welded together, and must have undergone an initial inspection by a competent body before the unit is put into service;
• unit heaters and their gas supply pipes must be protected from mechanical impact (e.g.: handling equipment);
• all parts of unit heaters must be at least 2 m from any combustible material;
• in the event of a gas leak being detected (pressure drop in the gas line) or the absence of flame being detected on a unit heater, a risk control measure (RCM) must be put in place to bring it to a safe state by automatically closing 2 isolation valves located on the gas supply piping, on either side of the outer wall or roof of the warehouse;
• any part of the heater in contact with the ambient air must have a temperature below 120°C. If this temperature is reached, an MMR must be triggered to trip the unit and close the two above-mentioned isolation valves.
• Unit heaters, gas supply piping and sheathing, and associated MMRs must undergo initial and periodic checks by a competent body, at least once a year.

Conclusion

With regard to loss prevention in covered warehouses, these must now comply with the provisions of the Order of August 17, 2016. This order applies to them depending on the date of commissioning or the date of application for authorization.

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