New requirements: loss prevention in covered warehouses

Regulations concerning the prevention of incidents in covered warehouses have changed: for warehouses subject to authorization under heading 1510, you must now refer to the decree of August 17, 2016. We invite you to review this change.

I. Classification of ICPE warehouses

Covered warehouses storing at least 500 tons of combustible materials and products may be classified under heading 1510 of the nomenclature for installations classified for environmental protection (ICPE) based on their volume:

The following warehouses are not covered by heading 1510:

• depots used for the storage of categories of materials, products, or substances falling under the ICPE nomenclature,
• buildings intended exclusively for the storage of motor vehicles and their trailers,
• establishments open to the public (ERP),
• and cold storage warehouses.

II. Incident prevention in covered warehouses

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

• subject to authorization under heading 1510;
• subject to authorization under heading 1510 and also falling under one or more of the following headings: 1530 (Paper/cardboard depots), 1532 (Wood storage), 2662 (Polymer storage), or 2663 (Storage of tires or polymer-based products).

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

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of August 5, 2002, regarding incident prevention in covered warehouses subject to authorization under heading 1510 is repealed and replaced by the decree of August 17, 2016.

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

• general provisions (conditions of application, definitions, status of stored materials);
• rules regarding site layout and accessibility;
• rules regarding fire behavior in warehouses (fire classification of materials, smoke extraction, compartmentalization, storage cell surface area, material incompatibility, storage conditions, containment, and confinement of potentially polluted water and runoff);
• rules regarding fire-fighting equipment (automatic detection, fire hydrants, fire extinguishers, fire hose reels);
• provisions regarding warehouse operations (emergency exits, electrical installations, lighting, ventilation, boiler rooms, cleanliness, rules for work permits and hot work permits, safety instructions, equipment maintenance, fire defense plans for floor areas exceeding 50,000 m², and surveillance and security).

The provisions applicable to existing installations, i.e., those commissioned before September 15, 2016, or for which an application for an operating permit was submitted by December 31, 2016, are defined in Annex I of the order.

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

The provisions applicable to them are those of articles 3, 5.I, 10, 14, 15, 22, 23, 24, and 25. The main changes compared to the order of August 5, 2002, include:

• • the development of an internal operation plan (POI) is no longer mandatory for operators of warehouses with a floor area exceeding 50,000 m². These operators must now establish a fire defense plan based on a single-cell fire scenario. This fire defense plan must be included in the POI "if one exists." The status of stored materials, safety data sheets (SDS), floor plans, risk zone maps, and access instructions for emergency services must be appended to the fire defense plan.
  • a document or file based on a risk analysis of the work must be prepared for repair and renovation projects. This document or file may be the prevention plan if required by the labor code.
  • safety instructions must specify the requirement for a document/file for repair and renovation work, precautions for the use and storage of 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 network isolation devices.
  • floor plans and access instructions for emergency services must be made available to fire and rescue services.
  • fire hydrants must have a nominal diameter of DN 100 or DN 150. External access to each cell must be within 100 meters of a fire hydrant, and these must be strategically distributed.

• • the flow rate and quantity of water required for extinguishing and cooling operations are calculated according to the technical document D9 "Practical guide for sizing water requirements"

• the automatic extinguishing system may serve as an automatic fire detection system in storage cells if it meets the conditions of the order of August 17, 2016

Existing facilities commissioned after January 1^st , 2003, or for which the authorization request was submitted after July 1^st , 2003

All provisions of the decree of August 17, 2016, are applicable, with the exception of articles 4, 5, 6, 7, 13, and 15, which are applicable according to the terms defined in the table in Annex I. The following changes compared to the decree of August 5, 2002, should be noted:

• the development of an internal emergency plan (POI) is no longer mandatory for operators of warehouses with a floor area greater than 50,000 m² (see 1. above);
• the maximum area of smoke extraction zones may be increased to 1,650 m² "for technical reasons," whereas it must, in principle, 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 for hazardous substances and mixtures covered by the 4xxx headings of the ICPE nomenclature is no longer limited to 5 m from the interior floor, provided an automatic extinguishing system compatible with the stored products is present;
• unit heater heating systems may be authorized in storage cells under certain conditions (see below).

New facilities

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

III. Fire prevention for gas-fired unit heater systems in storage cells

The decree of August 17, 2016, amends several decrees to allow the use of gas-fired unit heater systems in storage cells when certain conditions are met in the following facilities:

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

• the unit heaters must be type C as defined by the FD CEN/TR 1749 standard (November 2015 version);
• the piping supplying gas to a unit heater must be located outside the warehouse and penetrate the exterior wall or roof of the warehouse directly at the unit heater to minimize the length of piping inside the cells. Any remaining internal piping within the cell must be enclosed in a duct made of A2 s1 d0 class material, designed to vent any gas leaks outside the warehouse;
• the gas supply piping must be made of steel and assembled using welds that have undergone an initial inspection by a competent body before the air heater is commissioned;
• air heaters and their gas supply piping must be protected against mechanical impact (e.g., handling equipment);
• all parts of the air heaters must be at a minimum distance of 2 m from any combustible material;
• a risk control measure (RCM) must be implemented to ensure that, in the event of a gas leak (pressure drop in the gas line) or flame failure detection at an air heater, the unit is safely shut down by the automatic closure of 2 isolation valves located on the gas supply piping, on either side of the warehouse's exterior wall or roof;
• any part of the air heater in contact with ambient air must remain below 120°C. If this temperature is reached, an RCM must trigger the safe shutdown of the air heater and the closure of the two aforementioned isolation valves.
• air heaters, gas supply piping and their ducts, as well as the associated RCMs, must undergo an initial inspection and periodic inspections at least annually by a competent body.

Conclusion

Regarding loss prevention in covered warehouses, these must now comply with the provisions of the decree of August 17, 2016. This decree applies to them based on their commissioning date or the date of their authorization request.

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