ICPE 1510 Post-Lubrizol: Impact on Covered Warehouses

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🔎 Things to remember

Post-Lubrizol Regulatory Changes: Following the lessons learned from the industrial accident in Rouen (2019), the regulations for Section 1510 were tightened to strengthen risk prevention, clarify the definition of “combustible material,” and mandate the presence of a roof.

Major revision of volume thresholds: The upper threshold for the Registration system (and the lower threshold for Authorization) has been raised from 300,000 m³ to 900,000 m³. This increase significantly expands the scope of Registration at the expense of traditional Authorization.

End of Dual Classifications: To simplify administrative management, dual classifications are being eliminated for several materials (wood, paper/cardboard, plastics, polymers/tires). As long as they are stored in a 1510 covered warehouse, they are directly included under this single category.

Stricter safety and operational measures: The decree imposes a strict timeline for retroactive requirements, including maintaining a detailed inventory of stored materials, drafting a fire safety plan, managing the levels of flammable liquids, and updating Internal Operating Plans (IOPs) to ensure a water supply for more than two hours.

One year after the Lubrizol accident, regulations have been tightened regarding industrial risk prevention and accident management. This development is part of the government’s Lubrizol action plan, which aims to draw lessons from the major accident that occurred on September 26, 2019, in Rouen. What are the main measures affecting warehouses classified under category 1510? This applies to the storage of combustible materials and products in covered warehouses. Sites not currently classified under this category may be newly classified.

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What is a combustible material or product?

Combustible materials or products are materials or products, including waste, that are not classified as noncombustible.

Non-combustible: materials or products made exclusively of materials classified A1 or A2-s1-d0 as defined by the Order of November 21, 2002, or materials or products qualified as non-combustible following tests carried out in accordance with a protocol recognized by the Ministry of the Environment.

Examples of combustible materials involved: packaging, pallets, plastic film, textiles, cardboard, etc.

Need help managing your waste? Check out Tennaxia's waste management software .

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Who is now subject to ICPE category 1510?

ICPE Category 1510, which pertains to covered warehouses, now applies to facilities equipped with a roof (new) that are used to store combustible materials or products in quantities exceeding 500 metric tons (unchanged) and that exceed the classification thresholds, unless such facilities are:

warehouses used for the storage of materials, products or substances classified under a single heading of this nomenclature (*)
or buildings intended exclusively for the storage of motor vehicles and their trailers (unchanged)
or establishments open to the public (ERP) (unchanged)
or exclusively refrigerated warehouses (**)

(*) New: a warehouse is considered to be used for the storage of products classified under a single nomenclature heading when the total quantity of other combustible materials or products present in the warehouse is less than or equal to 500 tonnes.

Please note: storage facilities classified under headings 4XXX or under headings 1511, 1530, 1532, 2160, 2662, 2663 may now be covered by heading 1510, depending on the quantity of combustible materials/products, whereas previously these storage facilities were not necessarily classified under heading 1510.

(**) New definition: a warehouse is exclusively refrigerated when the quantity of combustible materials or products other than the materials or products kept in the refrigerated warehouse (temperature and/or humidity conditions regulated and maintained at a temperature of 18°C or less, depending on the product's specific conservation criteria) is less than or equal to 500 tons.

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How to classify: an upcoming application guide

The Ministry of Ecological Transition is now implementing its Implementation Guide for Section 1510 (updated in June 2024). This official document definitively clarifies the calculation methods for complex configurations (multiple buildings, dispersed inventories, and work-in-progress).

In particular, it introduces a strict aggregation rule: if two covered storage facilities containing combustible materials are less than 40 meters apart, their volumes must be added together to determine the classification requirements (Declaration, Registration, or Authorization).

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What changes have been made to the classification thresholds?

A new criterion to take into account

Warehouse construction projects subject to systematic environmental assessment (*) are now subject to authorization, whatever their volume.

* concerns works and constructions creating a footprint greater than or equal to 40,000 m² in an area other than :

urban zones known as "zones U" where a local urban development plan applies;
sectors where construction is authorized, when a carte communale is applicable;
the urbanized parts of the commune, in the absence of an applicable local urban plan or carte communale.

Would you like to learn more about the environmental obligations under ICPE category 1510?

What about volumes?

The authorization system has been made more flexible. The lower threshold for this system has been raised from 300,000^m3 to 900,000^m3 (warehouse volume).

As a result, the registration system has been extended. The upper threshold of this regime has been raised from 300,000^m3 to 900,000^{m3 (}warehouse volume).

The declaration system remains unchanged, and still covers volumes of 5,000^m3 or more but less than 50,000^{m3 (}warehouse volume⁾.

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The dual classification under ICPE category 1510 has been eliminated for certain storage facilities

As long as they are carried out within a warehouse classified under heading 1510, storage activities :

paper/cardboard or combustible materials (heading 1530) ;
wood (heading 1532) ;
plastics (heading 2662) ;
tires and products in which at least 50% of the total unit mass is composed of polymers (heading 2663);

are no longer to be classified under their respective headings, but must be integrated and encompassed under heading 1510.

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Fire prevention and management

The decree of April 11, 2017 (“AMPG 1510”), as amended by the post-Lubrizol reforms, establishes the general requirements applicable to covered warehouses subject to reporting, authorization, or registration under heading 1510. It was amended to strengthen the requirements regarding fire prevention and management. It imposes stricter requirements, all of which have now taken effect.

The affected sites must be in full compliance with the following requirements:

Insurance Reports (effective January 1, 2021): Requirement to make the contents of risk assessment reports (recommendations resulting from the insurer’s risk analysis) available to inspectors.
Real-time inventory (effective January 1, 2022): Facilities subject to registration or authorization must maintain a detailed, location-specific record of stored materials at all times.
POI Update (effective January 1, 2022): Inclusion in the Internal Operations Plan (POI) of procedures for cleaning up the environment after a disaster, as well as measures to ensure a water supply for more than 2 hours.
Fire Safety (effective January 1, 2022 / through December 31, 2023): Demonstration of the constant availability of trained personnel (January 2022) and full completion of the fire safety plan (December 2023).
Storage of liquids (effective January 1, 2023, or 2026, as applicable): Strict compliance with storage height limits for liquid hazardous materials.
Isolation Distances (effective January 1, 2025): Compliance with the minimum regulatory distances between the outer walls of warehouse bays and any outdoor storage areas.
Impact Studies (Past Deadlines): Conducted studies on thermal effects and smoke dispersion, and implemented the required mitigating measures (sprinkler systems, REI 120 firewalls).

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Summary

Volume or warehouse conditions	New ICPE Regulations	Post-Lubrizol Regulatory Requirements
Project subject to a systematic environmental assessment (e.g., land area ≥ 40,000 m² outside U/urbanized zones)	Authorization (A)	A new systematic evaluation criterion, regardless of the warehouse's size.
Volume greater than or equal to 900,000 m³	Authorization (A)	Relaxed threshold (raised from 300,000 m³ to 900,000 m³). Subject to the requirement for a strengthened Internal Operations Plan (POI).
Volume of 50,000 m³ or more but less than 900,000 m³	Registration (E)	The scope of the regulation has been significantly expanded following the increase in the upper threshold. There is a requirement to maintain a detailed inventory of stored materials.
Volume of 5,000 m³ or more but less than 50,000 m³	Declaration with Periodic Inspection (DC)	Thresholds remain unchanged, but new periodic inspections by accredited organizations have been introduced.

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Conclusion

As part of the Lubrizol action plan, regulations applicable to the storage of combustible materials and products in covered warehouses have been significantly tightened.

We recommend :

until the application guide is updated, list the combustible materials stored in warehouses on your site, including the associated tonnage and warehouse volume;
once the guide has been published, to determine your possible classification under heading 1510 based on the classification procedures indicated in the guide;
in the event of classification under heading 1510 :
- apply for grandfathering rights before January^1, 2022
- identify and apply the applicable requirements of AMPG 1510

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Photo credit: Marcin Jozwiak