What are the basic legal requirements for the storage of hazardous goods in Poland?

We recently came across an interesting post on LinkedIn by the magazine “Logistyka” on the storage of dangerous goods at intermodal terminals. It discussed safety standards. Legal requirements are just as important here. So, what are the legal requirements for storing dangerous goods in Poland? We’ll tell you all about it today.

What is an ADR warehouse under Polish regulations?

We have already written an article explaining what an ADR warehouse is, but we will expand on this topic, as there is really quite a lot to explain here.

This may surprise you, but the term ‘ADR warehouse’ does not appear in any Polish legislation. You won’t find a definition of it in either laws or regulations. It is purely an industry shorthand used by logistics professionals to describe a facility for storing dangerous goods.

So where did this abbreviation come from? It originates from the European Agreement concerning the International Carriage of Dangerous Goods by Road, signed in 1957. This convention regulates transport, packaging and the marking of vehicles.

The rules for storing chemicals in a building are a complex mix of building regulations, fire safety regulations and EU directives.

The link between transport and storage is provided by common UN numbers, hazard classes and safety data sheets. These inform us of physicochemical hazards and emergency response requirements. Each package, meanwhile, must bear GHS pictograms – graphic warnings regarding toxicity or flammability.

What legislation governs the storage of dangerous goods?

As we mentioned, there is no single specific document here. Unfortunately, for this reason, you have to navigate your way through a dozen or so different laws. Don’t worry! To make things easier, we will now present the documents you should familiarise yourself with before you start transporting dangerous goods:

• Regulation of the Minister of Infrastructure of 12 April 2002 – sets out building classification, fire resistance class and permissible fire load.
• Regulation of the Ministry of the Interior and Administration of 7 June 2010 – specifies what constitutes a fire hazard, including flammable gases, explosives and liquids with a flash point below 55°C.
• Regulation of the Ministry of Labour and Social Policy of 26 September 1997 – sets out general health and safety standards within the premises.
• Regulation of the Minister of Development of 29 January 2016 – implements the quantitative thresholds from the SEVESO III Directive, determining whether a facility falls into the ZZR or ZDR category.
• Regulation of the Minister of Economy of 22 December 2005 – national implementation of the EU ATEX Directives, setting out requirements for equipment in potentially explosive atmospheres.
• CLP Regulation (No 1272/2008) and SEVESO III Directive – these are EU acts forming the basis of the system for the classification, labelling and packaging of chemicals and the management of major accident hazards.

You can see that this is a considerable responsibility. That is precisely why it is so important to understand, at the very least, how the transport of dangerous goods differs from the ordinary transport of goods.

What stringent technical requirements must the building meet?

Safety comes at a cost. Building a specialised warehouse for dangerous goods can cost 30–70% more than erecting a standard warehouse. The facility must be single-storey and have a lightweight roof structure made of flame-retardant materials to safely vent pressure in the event of an explosion.

The floor, on the other hand, must be non-sparking, fire-resistant and non-absorbent, and must dissipate static electricity in the case of flammable substances. External doors must open outwards and be non-combustible to ensure a safe evacuation for you and others.

Ventilation of the building is also of paramount importance. Typically, 3 to 6 air changes per hour are required, but for highly toxic substances this figure rises to 10 air changes. Added to this are drainless emergency drainage systems in case of leaks and lighting systems that meet the stringent ATEX standards.

How should chemicals be correctly classified and segregated in logistics?

Every dangerous cargo is assigned to one of the 13 ADR classes. You’ll find everything here: from explosives (Class 1), through gases (Class 2), to corrosive substances (Class 8) and lithium batteries (Class 9). Interestingly, you cannot store radioactive materials (Class 7) in a standard warehouse, as they require separate permits.

There is a truly strict segregation of goods in place here. Some substances react so violently with one another that their proximity poses a risk of disaster. For example, oxidisers must be strictly isolated from flammable substances. If you bring them close together, you will cause a fire.

When does a warehouse become a high-risk facility?

When you store large quantities of specific substances, the SEVESO III Directive comes into play. If you exceed the so-called lower quantity thresholds, your warehouse is classified as a High-Risk Facility (HRF). Exceeding the upper thresholds, in turn, means it is classified as a Major Hazard Facility (MHF).

If you operate an HRP, your task is to create an accident prevention programme and register the facility with the National Fire Service. If you operate an HRP, you will also need to report on safety to the Regional Environmental Protection Inspector. HRPs are inspected once every three years, and HRP facilities annually.

What changes do the ADR regulations for 2025–2027 bring?

The new edition of the regulations comes into force on 1 January 2025 and mainly affects the e-mobility market. As many as 11 new UN numbers have been added, most of which target batteries and electric vehicles directly. These include:

1. UN 3551 (sodium-ion batteries),
2. UN 3552 (sodium-ion batteries contained in or packed with an appliance),
3. UN 3556 (vehicle powered by a lithium-ion battery),
4. UN 3557 (vehicle powered by a lithium metal battery),
5. UN 3558 (vehicle powered by a sodium-ion battery).

Refer to special provision 677. It states that damaged batteries posing a risk of a hazardous reaction are assigned transport category ‘0’. In practice, this means the strictest storage restrictions. Furthermore, from 2026, lithium batteries packed with equipment will have to have a state of charge (SoC) of no more than 30%.

When should you opt for ADR storage outsourcing?

Building your own warehouse that complies with the stringent requirements of ADR, ATEX and environmental regulations is a massive investment. The costs of constructing or adapting such a facility are as much as 30–70% highercompared to a standard warehouse. On top of this come the procedures for obtaining the necessary administrative approvals, which can drag on for months.

However, the building itself is just the start. You’re left with the task of maintaining a qualified workforce with up-to-date certifications, paying for specialist insurance and keeping track of the shortened infrastructure inspection intervals.

Outsourcing is the best alternative for you. As a specialist operator, we will take on the full burden of legal compliance, training and tedious paperwork. This will give you peace of mind and allow you to focus fully on generating revenue.

The scale of operational challenges in this sector is immense. This is evidenced by the fact that there are few companies on the market with the full expertise to handle ADR logistics. By entrusting your goods to proven experts, you are investing in your own safety. Contact us and operate in accordance with the law and safety regulations.