First, get an overview of what you actually have in storage
The first step is not buying a new chemical cabinet or another shelf.
First, you need to know which substances and mixtures are actually present in the operation, in what quantity and where they are stored.
In practice, we recommend creating a simple list of chemical products containing at least the trade name, the manufacturer or supplier, the maximum stored quantity, the storage location and the basic hazard classification.
A current safety data sheet should be available for every product.
In practice: If a company cannot say within a few minutes what it has in its chemical store and provide the safety data sheets for it, that is the first sign that its system for handling chemical substances is not set up well.
The list of chemicals is also the basis for further obligations. It shows whether the store holds flammable substances, corrosive substances, oxidising substances, substances toxic to health or substances hazardous to the aquatic environment.
A safety data sheet is not a document for a binder
The safety data sheet is one of the most important documents for correct storage.
Under the REACH Regulation, it must provide the information needed for the safe use, handling and storage of a chemical substance or mixture.
Section 7 – Handling and storage is particularly important for a store.
It should state, for example, requirements for:
- conditions for safe storage,
- incompatible materials and chemical substances,
- the required temperature,
- protection against sunlight or humidity,
- ignition sources,
- ventilation,
- suitable packaging.
However, important information is also found in other sections of the safety data sheet.
Section 2 describes the hazards of the product. Section 6 deals with measures in the event of accidental release. Section 8 contains information on exposure limitation and personal protective equipment. Section 10 describes stability, reactivity and incompatible substances.
The safety data sheet should therefore be the basis for the actual layout of the store, not merely a document saved on a computer.
Chemical substances cannot be stored simply according to where they fit
A very common mistake is storing according to the size of the packaging or by supplier.
However, chemicals must be segregated primarily according to their hazardous properties and mutual compatibility.
Particular attention is required, for example, for:
- flammable liquids,
- oxidising substances,
- acids,
- bases,
- substances that react with water,
- acutely toxic substances,
- substances hazardous to the environment.
Some chemicals may be relatively stable on their own, but when mixed they can react violently or form hazardous gases.
It is therefore not correct to automatically place all chemical products in one common containment tray.
Chemical compatibility is precisely one of the things that must be checked against the safety data sheets before the store is designed.
Labelling of packaging must remain legible
Hazardous substances and mixtures placed on the market are subject to the European CLP Regulation.
Depending on its classification, the packaging of a hazardous product mainly bears:
- product identification,
- hazard pictograms,
- a signal word,
- hazard statements,
- precautionary statements for safe handling,
- supplier details.
The packaging must also be designed so that its contents cannot escape under normal conditions and so that the packaging material is not damaged by the stored substance.
It is therefore highly inadvisable in an operation to decant chemicals into anonymous canisters, beverage bottles or other containers without clear identification.
If a chemical substance is decanted into a working or process container, it must still be safely identifiable and there must be no real risk of mix-ups.
In practice: A canister labelled "thinner" or "chemicals" is not a sufficient system. Employees must know unambiguously what the container holds and what risks are associated with the substance.
Spill containment and water protection
A chemical store is not only a question of protecting employees.
Many chemical substances also pose a risk to surface or groundwater.
Under Section 39 of Act No. 254/2001 Coll., the Water Act, anyone handling water-polluting substances must take appropriate measures to prevent these substances from entering surface water or groundwater.
For hazardous water-polluting substances, particularly hazardous water-polluting substances, or handling of water-polluting substances on a larger scale or with increased risk, the requirements are considerably more specific.
The store must be designed so that any spill of a chemical substance cannot flow uncontrolled into the soil, rainwater sewer, foul sewer or the surrounding environment.
In practice, the following are used, for example:
- containment trays,
- impermeable floors,
- emergency sumps,
- raised thresholds,
- closable sewer inlets,
- sorbents.
The specific solution must match the type of chemical, the quantity and the method of storage.
It is not correct to automatically assume that one universal containment tray will solve the whole chemical store.
Beware of sewer inlets directly in the store
A floor drain can be a major risk in a chemical store.
If the packaging fails, the substance can flow within seconds out of the area where it can be contained.
It is therefore necessary to know where the drains are connected and how the outflow of chemicals is prevented in an accident.
Outdoor stores, loading areas and places where chemicals are pumped over must be handled similarly.
It is therefore not enough to assess only the shelves themselves. What matters is the whole path of the chemical substance from receipt through the store to the point of use.
When an emergency plan may be required
If a company handles water-polluting substances on a larger scale, or if their use involves increased danger to surface water or groundwater, the Water Act imposes an obligation to prepare an emergency plan.
The emergency plan is submitted for approval to the competent water authority.
If a potential accident could affect a watercourse, its administrator also becomes involved in the process.
An emergency plan should not be a general, several-page directive detached from actual operations. It must correspond to the specific chemical substances, storage locations, sewer system, emergency equipment and organisational procedures of the company.
Above all, employees must know what to do in a real spill.
Inspections of stores and tank tightness
The Water Act also contains specific inspection obligations.
For selected handling of water-polluting substances, stores and stockpiles must be inspected at least once every 6 months, including any leak detection systems, and any defects found must be remedied without delay.
Stores must be protected by an impermeable surface against the escape of water-polluting substances into groundwater.
For pipework, tanks and equipment intended for storing or transporting hazardous and particularly hazardous water-polluting substances, the Water Act also requires tightness tests. In general, the interval is at least once every 5 years, unless a technical standard or the manufacturer specifies a shorter period; the Act also contains some special exceptions.
In an operation, it is therefore not enough for the store to be technically well built. You need to demonstrate that its condition is checked regularly.
Acutely toxic substances are subject to a special regime
Special attention must be paid to substances and mixtures classified under CLP as acutely toxic category 1 or 2.
Under Section 44a of Act No. 258/2000 Coll., on the Protection of Public Health, these substances and mixtures must be stored in premises that can be locked and are secured against burglary and entry by unauthorised persons.
At the same time, mix-ups, harmful interaction with one another and release into the environment must be prevented.
Other special obligations also apply to handling these substances.
The company must have the handling overseen by a professionally competent person. Employees who carry out the individual activities must demonstrably be trained, and repeat training is carried out at least once every 2 years.
The Act also requires records of these substances and mixtures to be kept. The quantity received and issued, the stock level, and details of the person and department to which the substance was issued are recorded. The records are retained for at least 5 years after the stock level reaches zero.
If you have acutely toxic substances of category 1 or 2 in storage, it is therefore advisable to review this part of the system separately.
Flammable substances need more than the right shelf
For flammable liquids, it is not enough to follow the safety data sheet alone.
You also need to check the fire safety solution of the building, the quantity of flammable substances stored, the ventilation, possible ignition sources and, depending on the nature of the operation, the risk of an explosive atmosphere forming.
The problem often arises gradually.
The store was originally designed, for example, for several tens of litres of flammable products, but over the years the stock has increased to several pallets. The building and fire safety solution, however, has remained the same.
It is therefore advisable to compare the current maximum stored quantity with the state for which the store was originally designed and approved.
Beware of chemical quantities across the whole site
For larger stores, one more area needs to be checked – the Major Accident Prevention Act.
Under Act No. 224/2015 Coll., the quantity of selected hazardous substances located in the whole establishment is monitored.
It is therefore not only about one store.
The overview may include chemicals in the raw materials store, production, storage tanks, technology, intermediate stores and other parts of the operation.
The user of the establishment must draw up a list of relevant hazardous substances and calculate their proportional quantities.
If the quantity does not reach the limits for classifying the establishment in group A or B, a non-classification protocol is prepared under the conditions of the Act.
If the quantity of a particular hazardous substance exceeds 2% of the relevant qualifying quantity under the Act, the non-classification protocol or its update must be submitted to the regional authority within 1 month.
This is an area that is often forgotten in ordinary chemical stores.
The store and the work environment are connected
Another question is employee exposure.
A closed original package in a store usually presents a different risk from decanting, dosing, mixing or cleaning equipment.
However, if chemicals are regularly drawn off, decanted or dosed in the store, ventilation, local extraction and possibly also employee exposure to chemical substances may need to be addressed.
The decisive factor is not only the stored kilograms or litres. What matters is the method of handling.
For example, a store of closed drums of solvent will be different from the point of view of workplace air than a room where an employee decants solvent into open containers every day.
What a company should go through before an inspection
Before an inspection, we recommend taking the list of chemical products used and physically walking through the entire store.
For each product, verify:
- whether it is still actually in use,
- whether a current safety data sheet exists,
- whether the packaging is legibly labelled,
- whether the container is damaged or leaking,
- whether the product is stored in line with the requirements of the safety data sheet,
- whether there is no chemically incompatible substance next to it,
- whether any spill can be contained,
- whether the substance could get into the sewer or the soil.
Then it is advisable to check the store's documentation as a whole: the emergency plan, inspection records, tightness tests, employee training and any non-classification protocol under the Major Accident Prevention Act.
The most common mistakes in chemical stores
A very common problem is chemicals that the company has not used for several years but that still remain in the store.
Nobody knows exactly what the container holds any more, the safety data sheet cannot be found and the label is damaged.
Another common mistake is a shared containment tray for chemicals that can react dangerously with each other.
Problematic too are unlabelled working containers, damaged packaging, storage directly on the floor, an openly accessible sewer inlet or sorbent kept in a place that cannot be reached quickly in an accident.
In larger companies we often encounter a different problem: the chemical store is managed well, but nobody has counted the chemicals located directly in the production halls. The records then do not match the actual maximum quantity in the establishment.
What you can send us for assessment
If you want to verify whether your chemical store is set up correctly, send us a list of the stored chemical substances and mixtures, their safety data sheets, the maximum stored quantities and a simple floor plan or photographs of the store.
For larger operations, it is advisable to add the emergency plan, the fire safety solution, any non-classification protocol under the Major Accident Prevention Act and information on tanks, sumps and the sewer system.
From these documents we will check in particular the classification of the chemical products, storage conditions, chemical compatibility, labelling, protection against spills, the requirements of the Water Act and other obligations that may apply to the specific store.
The aim is not to create yet another unnecessary directive. The aim is to determine whether the actual state of the store matches the properties of the chemicals and the legal requirements.
You can find more information on the page Chemical substances in operation – NATURCHEM.
Brief summary
Correct storage of chemical substances does not start at the shelf, but with a list of the products actually used and their safety data sheets.
The storage conditions, incompatible substances, fire risk, ventilation requirements and the procedure in the event of a spill must be determined from the safety data sheets.
Packaging must be clearly identifiable, and any spill must not endanger employees, the soil, the sewer or water.
Special obligations may arise when storing water-polluting substances under the Water Act, acutely toxic substances of category 1 and 2, or larger quantities of hazardous substances under the Major Accident Prevention Act.
The best inspection is therefore not just to go through the documentation, but to compare it with the actual state of the store.
Factual basis of the article
The basic European rules for the classification, labelling and packaging of hazardous substances and mixtures are laid down by Regulation (EC) No 1272/2008 – CLP.
The requirements for safety data sheets and information on safe storage are based on the REACH Regulation and its Annex II. Section 7 of the safety data sheet deals with handling and storage, Section 6 with measures in the event of accidental release, Section 8 with exposure limitation and Section 10 with stability and reactivity.
Czech legislation on chemical substances is supplemented by Act No. 350/2011 Coll., the Chemicals Act.
Special conditions for handling substances and mixtures classified for acute toxicity category 1 or 2 are laid down in Section 44a of Act No. 258/2000 Coll., on the Protection of Public Health.
The protection of surface water and groundwater when handling water-polluting substances is governed mainly by Section 39 of Act No. 254/2001 Coll., the Water Act.
For larger quantities of selected hazardous substances, Act No. 224/2015 Coll., on Major Accident Prevention, must also be checked, including the obligation to draw up a list of hazardous substances, to sum the proportional quantities and, depending on the result, to prepare a non-classification protocol or to address the classification of the establishment in group A or B.