The Rouen plant fire in the fall of 2019 left a lasting impression on people because of its magnitude and potential environmental impacts. Industrial safety experts redoubled their efforts to analyze this accident. This work has led to the implementation of several regulatory changes. Gesip has been heavily involved in numerous working groups and has contributed its expertise to the development of the post-Rouen regulations. Here is an overview of these changes which improve industrial safety.
Developments for SEVESO classified facilities
Key dates of the post-Rouen regulation:
- September 27, 2020: POI Exercises become mandatory:
- every year (instead of every 3 years) in the SEVESO High Threshold sites,
- every 3 years in the other sites where a POI is prescribed.
- December 31, 2021: The IOP must now include details of "the means and methods planned, as far as the operator is concerned, for the restoration and clean-up of the environment after a major accident".
- January 1, 2022: "Inventory Status
- Daily check: status of stored hazardous materials (including waste) with hazard statements that may lead to classification under a 4XXX heading.
- Weekly check: status of other combustible materials.
- January 1, 2023:
- The POI becomes mandatory for Seveso low threshold installations.
- After January 1, 2023, all hazard studies or five-year reviews must mention the types of decomposition products that could be released in the event of a major fire. These decomposition products are ranked according to the quantities likely to be released and their toxicity, including environmental toxicity. Professional methodological guides recognized by the minister in charge of classified installations are being drafted. The list of these decomposition products must be sent to the prefect at the same time, and no later than June 30, 2025 for sites whose five-year review is after that date.
- The IOP must now include provisions for initial environmental sampling (relevant substances, sampling equipment, authorized personnel or organizations) of toxic substances, the types of decomposition products likely to be emitted in the event of a major fire and, where applicable, for SEVESO High Threshold sites, substances that cause significant inconvenience over long distances - in accordance with professional guide(s) to be published.
Modifications for the storage of flammable liquids on ICPE installations
Storage of flammable liquids in mobile containers
- The storage in a covered building of flammable liquids with hazard statements H224 and H225 is prohibited in mobile containers that are liable to melt, unless these storage buildings are equipped with qualified extinguishing means;
- The requirements for outdoor storage (layout rules, storage conditions, design and capacity of associated retention facilities, remote retention facilities and fire detection) have been reinforced.
The regulations require companies to anticipate access to additional water and foam. They will have to have 20% more water and emulsifiers available as of January 1, 2026.
Also read: Industrial fire, the risks of battery fires
Impacts for combustible product storage sites
- It limits the double rankings;
- It simplifies the procedure. Thus, it raises the authorization threshold for installations under the 1510 heading to 900,000 m³;
- It also includes products from Seveso categories.
The regulatory reference texts
SEVESO SITES :
- Decree n°2020-1168 of September 24, 2020 concerning the rules applicable to installations in which dangerous substances are present in such quantities that they can be the cause of major accidents.
- Order of September 24, 2020 amending the order of May 26, 2014 on the prevention of major accidents in classified facilities mentioned in Section 9, Chapter V, Title I, of Book V of the Environmental Code.
STATUS OF STORED MATERIALS
- Order of September 24, 2020 amending the ministerial order of October 4, 2010 on the prevention of accidental risks in facilities classified for environmental protection subject to authorization.
STORAGE OF FLAMMABLE LIQUIDS :
- Order of September 24, 2020 concerning the storage of flammable liquids in mobile containers.
- Order of September 24, 2020 modifying the ministerial order of October 3, 2010 relating to storage in manufactured aerial tanks operated within a classified installation subject to authorization under one or more of the headings 1436, 4330, 4331, 4722, 4734, 4742, 4743, 4744, 4746, 4747 or 4748, or for crude oil under one or more of the headings 4510 or 4511 of the ICPE legislation.
- Decree n° 2020-1169 of September 24, 2020 modifying the ICPE nomenclature and the nomenclature annexed to article R. 122-2 of the environment code.
LOGISTIC WAREHOUSES :
- Order of September 24, 2020 amending the ministerial order of April 11, 2017 on the general requirements applicable to covered warehouses subject to heading 1510, including when they also fall under one or more of the headings 1530, 1532, 2662 or 2663 of the ICPE nomenclature, as well as the orders on general requirements applicable to classified facilities subject to registration under headings 1511, 1530, 1532, 2662 and 2663 -
Support, development and validation of POIs by Gesip
Gesip puts its technical expertise and legal watch at the service of advice and support for industrial players in the development, revision and validation of their POI, in accordance with the most recent regulatory advances.