Surface Treatment: Strengthened Fire Risk Requirements for Classified Facilities

‍

Classified facilities under the registration regime for headings no. 2564 or no. 2565, or under the authorization regime for heading no. 3260

An order dated April 20, 2023 (https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000047584832) amended the general regulatory orders applicable to classified facilities under the registration regime for headings no. 2564 or no. 2565, or under the authorization regime for heading no. 3260, respectively:

• order of April 9, 2019, as amended, relating to general requirements applicable to facilities under the registration regime for heading no. 2564 (cleaning, degreasing, stripping of surfaces using organohalogenated liquids or organic solvents) or heading no. 2565 (metal coating or surface treatment by electrolytic or chemical means) of the nomenclature of classified facilities for environmental protection;
• order of June 30, 2006, as amended, relating to general requirements applicable to facilities under the authorization regime for heading no. 3260 of the nomenclature of classified facilities for environmental protection.

The amendments introduced primarily aim to strengthen the requirements applicable to these facilities to prevent fire risk. This strengthening of requirements was partly recommended by the Bureau of Industrial Risk Investigations and Analyses (BEA-RI) in its 2022 activity report (The Bureau of Industrial Risk Investigations and Analyses (BEA-RI) | IGEDD - https://www.igedd.developpement-durable.gouv.fr/).

Existing facilities (*)

The key changes introduced by the order of April 20, 2023, are as follows:

RequirementDeadline

Electrical installations

• New obligation for at least annual inspection, also covering hot spot detection (thermography or equivalent). Inspection reports must be made available to the classified facilities inspectorate.

• New obligation to archive electrical installation inspection reports in a register. This register must specify the date corrective measures were implemented in response to the verifier's comments.

1^st July 2024

Firefighting Measures

The installation must be equipped with:

•       A fire detection system activating a fire alarm audible throughout the building and automatically shutting down systems likely to spread the fire (bath vapor extraction system, bath heating):

•       In premises where flammable liquids are stored or used (with hazard statement H224, H225 or H226) and;

•       In premises housing the surface treatment installation.

•       A probe installed in each extraction system to detect an abnormal rise in vapor temperature. This probe triggers a fire alarm.

The operator must develop:

•       A list of fire detectors including justification for their sizing;

•       An emergency procedure detailing the steps to follow if the fire alarm is triggered.

The operator must implement an annual inspection of this installation as part of a maintenance contract.

These inspections are archived in a register including a list of anomalies and the corrective measures taken to address them.

1^st July 2024

Liquid level detection in treatment installations linked to the heating system

The operator must implement a weekly test of this system. This test must be recorded in a logbook.

1^st July 2024 for installations classified under heading no. 3260

Immediately for installations classified under heading no. 2565

Does not apply to installations classified under heading no. 2564

Hazardous Areas

• Premises housing equipment at risk of electrical failure (at least the main low-voltage switchboard and power cabinets related to bath heating and electrolytic treatments) must systematically be considered hazardous areas.

è As such, they must be identified as such on the risk location plan.

è If explosive atmospheres are identified there, all electrical, mechanical, hydraulic, and pneumatic installations must comply with the provisions applicable to these premises.

Immediately

(*) For installations classified under the registration regime for headings no. 2564 or no. 2565, existing installations are those regularly authorized prior to April 12, 2019, and subsequently falling under the registration regime, or regularly registered before April 12, 2019.

For installations classified under the authorization regime for heading no. 3260, existing installations are those regularly authorized before September 6, 2006, or for which the complete authorization application file predates September 6, 2006.

New installations

For newly authorized (heading no. 3260) or registered (headings no. 2564 or no. 2565) facilities, beyond the new provisions presented in the previous paragraph, additional new requirements are introduced.

In particular, premises housing equipment at risk of electrical failure (at least the main low-voltage switchboard and power cabinets related to bath heating and electrolytic treatments) must have:

• walls made of A1 or A2s1d1 class materials,
• REI 120 exterior and partition walls,
• REI 120 floors and fire-resistant doors and closures (including those with glazing and hardware) and their EI 120 closing devices.

Failing this, the equipment must be protected by an automatic extinguishing system adapted to the risk (fire of electrical origin).

For newly authorized facilities (heading no. 3260), smoke extraction requirements for premises are strengthened:

• Minimum smoke extraction area of 2%
• Ground-level reset.
• Sufficient fresh air supply
• Automatic opening after automatic extinguishing, if applicable
• Strengthening of minimum technical characteristics for smoke extraction and compartmentalization (sizing of vents and compartments, reliability requirements, required materials, compliance with standards, etc.)
• For buildings housing a treatment line: division into compartments of 1,600 m² with a maximum length of 60 m.