Chemical storage

The Chemical Storage Regulations

Royal Decree 656/2017 applies to new installations and modifications to existing ones where hazardous chemicals are stored in accordance with the CLP Regulation, in solid, liquid, or gaseous form, as well as flammable liquids with a flash point between 60 and 100 degrees Celsius in fixed containers, provided that the minimum quantities specified in its application table are exceeded. Excluded, among others, are products in transit for less than 72 hours, storage below the thresholds, installations with specific regulations, and process-integrated storage with a feed interval of less than 48 hours.

The supplementary technical instructions regulate flammable and combustible liquids in fixed containers (APQ-1), ethylene oxide (APQ-2), chlorine (APQ-3), anhydrous ammonia (APQ-4), gases in transportable pressure vessels (APQ-5), corrosive (APQ-6) and toxic (APQ-7) liquids in fixed containers, ammonium nitrate-based fertilizers (APQ-8), organic peroxides and self-reactive substances (APQ-9), and storage in mobile containers (APQ-10), the most common being warehouses for containers, drums, and other receptacles. The operator must ensure compliance with the regulations, the proper functioning of the installation, and maintain minimum liability insurance. The installations are subject to five-year periodic inspections by accredited bodies, in addition to the periodic reviews stipulated in each instruction.

Technical and organizational requirements of storage

• Classification and inventory. Identification of each product with its CLP classification, its safety data sheet and its quantities, basis for determining the applicable technical instruction and incompatibilities.
• Separation by incompatibilities. Sectorization, distances, separate containment basins and cabinets for flammable, oxidizing, corrosive, toxic and reactive substances, with compatibility charts.
• Spill containment and retention. Spill containment for fixed and mobile containers, with sufficient capacity and resistant materials, and controlled drainage systems.
• Ventilation and ignition. Natural or forced ventilation, control of ignition sources, electrical installations suitable for classified areas and protection against electrostatic discharges.
• Fire protection. Compartmentalization, detection, fire extinguishers and extinguishing systems appropriate to the products, and signage.
• Packaging and labelling. Original or suitable packaging, sealed, labelled in accordance with the CLP Regulation and in good condition; transfer to food containers is prohibited.
• Operations and emergencies. Loading, unloading and transfer procedures, personal protective equipment, showers and eyewash stations, absorption kits and action plan for spills, leaks and fires.
• Training and documentation. Personnel trained in risks and emergency response, and documentation of the installation, inspections and reviews.

Relationship with occupational risk prevention

• Royal Decree 374/2001. Assessment of risks from chemical agents in storage and associated operations, with prevention and protection measures and health surveillance.
• Royal Decree 486/1997. Conditions of workplaces: order, cleanliness, signage, evacuation routes and ventilation.
• Royal Decree 681/2003. Evaluation of explosive atmospheres and explosion protection document when flammable materials are stored.
• Royal Decree 840/2015. Additional obligations when the amounts reach the thresholds of the regulations on serious accidents.
• Royal Decree 773/1997. Personal protective equipment for handling, transfer and spill cleanup operations.
• Royal Decree 393/2007. Self-protection plan in affected establishments and coordination with emergency services.

Organizational application: how to manage chemical storage

1. Inventory all chemical products with their CLP classification, their safety data sheets and their maximum quantities, and determine if the facility is subject to Royal Decree 656/2017 and what technical instructions.
2. Design or adapt the warehouse: sectorization by incompatibilities, containment basins, ventilation, electrical installation suitable to the classified areas, fire protection and signage.
3. Assess the occupational risks of storage and receiving, transfer and removal operations, including explosive atmospheres when flammable materials are present.
4. Establish procedures for receiving, locating, transferring, managing empty containers and responding to spills, with protective equipment, showers and eyewash stations and containment measures.
5. Train staff on chemical risks, incompatibilities, use of protective equipment and emergency response.
6. Schedule and document periodic reviews and five-year inspections, facility maintenance, and inventory updates in response to changes in products or quantities.
7. Integrate the warehouse into the emergency or self-protection plan and coordinate with emergency services and external companies.

Preventive management software allows you to maintain an inventory of chemical products with their safety data sheets and classification, link them to job positions and risk assessments, schedule reviews and inspections with expiration notices, manage training and protective equipment, and record incidents and spills.

Limits and common mistakes

1. Store incompatible products together or without effective separation, especially oxidizers with flammables and acids with bases.
2. Exceeding the regulatory thresholds without adapting the installation or notifying the competent authority.
3. Using unsuitable, unlabeled or damaged containers, and transferring to food-grade containers.
4. Lack of containment areas, ventilation, or control of ignition sources in flammable storage facilities.
5. Lack of procedures, equipment, and training to respond to spills and leaks.
6. Allowing periodic reviews and inspections to expire or failing to update inventory after product changes.

Specific requirements depend on the products, quantities, and applicable technical instructions; this sheet is for informational purposes only.

Regulatory and reference framework

• Royal Decree 656/2017, of June 23. Regulation on the storage of chemical products and its supplementary technical instructions MIE APQ-0 to 10.
• Regulation (EC) 1272/2008 (CLP) . Classification, labelling and packaging of substances and mixtures.
• Royal Decree 374/2001, of April 6. Protection against risks related to chemical agents during work.
• Royal Decree 486/1997, of April 14. Minimum health and safety requirements in the workplace.
• Royal Decree 681/2003, of June 12. Protection against risks arising from explosive atmospheres in the workplace.
• Royal Decree 840/2015, of September 21. Measures for the control of risks inherent in major accidents with hazardous substances .
• Law 31/1995, of November 8. Law on the Prevention of Occupational Risks.

Royal Decree 656/2017 repealed Royal Decree 379/2001 and the regulations of the former ITC APQ-8 and APQ-9; the autonomous communities are the competent authorities in industrial safety for the communication and inspection of the facilities.