The SEVESO III Directive – when does a storage facility become a high-risk establishment?

Storing goods can be a bit like playing Minesweeper. One wrong move when receiving a delivery and you’re already facing the consequences of strict legislation. But don’t worry! Today we’ll explain what the SEVESO III Directive is, what it requires, when a warehouse becomes a high-risk facility, and what that means. We’ll help you avoid costly procedural pitfalls when handling chemicals.

What is the SEVESO III Directive?

The SEVESO III Directive is EU legislation designed to prevent industrial accidents involving dangerous substancesor to limit their consequences should they occur. It covers establishments where dangerous goods are manufactured, used or stored.

The SEVESO III Directive imposes specific technical and organisational obligations on companies, including:

  1. the implementation of safety management systems,
  2. the preparation of emergency plans,
  3. and regular reporting to supervisory authorities.

The Directive also imposes an obligation on us regarding land-use planning. And rightly so, because Ioannis Pissourios, Georgia Gemenetzi and Milan Husar, in their paper “A Critical Review of the Implementation of the Seveso III Directive in the Framework of Land-Use Planning”, have shown that planning the distances between establishments and residential areas reduces the risk of a situation where an accident in one place triggers further accidents.

Equally important is transparency in dealings with local communities.

Izabela Gabryelewicz and others, in their study ‘SEVESO III Directive – Information on Establishments with a High or Increased Risk of a Major Industrial Accident’, confirm that it is the operator’s duty to ensure the public has access to information about high-risk establishments.

In short: SEVESO III sets out the rules of the game for anyone who stores hazardous substances above specified thresholds. And if your facility is located near residential areas, the stakes are even higher.

What regulations determine when a storage facility is classified as a high-risk establishment?

In Poland, the classification of a storage facility as a high-risk establishment is governed by several interrelated legal acts.

  1. Directive 2012/18/EU (SEVESO III) – Sets out the general principles for the classification of establishments and the obligations of Member States.
  2. The Act of 27 April 2001 on Environmental Protection Law (Journal of Laws 2022, item 1079), Title IV “Major Accidents” – The main piece of national legislation implementing SEVESO III. Article 249 introduces the principle that anyone who operates or intends to operate an establishment posing a major or high risk is obliged to design, operate and decommission it in a manner that prevents industrial accidents.
  3. Regulation of the Minister for Development of 29 January 2016 on the types and quantities of dangerous substances determining whether an establishment is classified as a ZZR or a ZDR (Journal of Laws 2016, item 138)- It contains two tables: the first sets out the classification of substance groups (e.g. toxic, flammable, carcinogenic) together with the thresholds for ZZR and ZDR, and the second lists specific substances and their individual quantity thresholds.
  4. Regulation of the Minister for Development of 23 February 2016 on the safety report (Journal of Laws 2016, item 287) – applies to high-risk establishments (ZDR).
  5. Regulation of the Minister of the Interior and Administration of 8 June 2016 on operational and emergency response plans (Journal of Laws 2016, item 821) – regulates how an establishment must prepare for emergency scenarios.

When does a warehouse become a high-risk facility? If the quantities of hazardous substances in your warehouse exceed the lower threshold set out in the 2016 Regulation. That is why it is worth knowing, what the basic legal requirements are for the storage of dangerous goods in Poland.

When does a logistics facility become a high-risk facility?

We have set out in detail below four specific situations that transform your facility into a high-risk facility

1. Storage of chemicals exceeding the lower quantity thresholds

The simplest situation in which a warehouse becomes a high-risk facility is when the lower quantity thresholds for hazardous substances are exceeded.

Examples of lower quantity thresholds (high-risk facility):

  • Petroleum products (petrol, diesel, kerosene) – 2,500 tonnes.
  • Ammonium nitrate (depending on concentration and form) – from 350 tonnes, 1,250 tonnes or 5,000 tonnes.

When you receive a large consignment and your stock levels rise above these thresholds, the warehouse automatically becomes a high-risk facility. There is no room for compromise here – the operator must implement the required preventive procedures (PZA, SZB and notification to the authorities).

2. Expansion of a logistics centre handling ADR goods

Expanding the warehouse and increasing storage capacity necessitates a reassessment of risk. A larger warehouse automatically means a higher permissible stock of dangerous goods across the entire site.

All it takes is for the stock levels to exceed the lower quantitative thresholds following the expansion, and the hall becomes a high-risk storage facility. At that point, the company automatically moves to a higher level of official classification and must implement additional obligations.

3. Accumulation of different categories of substances

Polish law (and the SEVESO III Directive) applies the principle of additivity – the mathematical summation of different categories of dangerous substances. How does this work?

And how is it calculated?

David J. Castro Rodriguez and colleagues, in their paper “Assessing the Major Industrial Accident Potential Based on Dangerous Substance Criteria”, propose a simple yet effective indicator Q_cs (compliance index).

Q_cs = Σ (q_x / U_x,s).

Where:

  • q_x – is the actual or maximum quantity of a given substance in stock,
  • U_x,s – is the upper-tier threshold for a given hazard category as set out in Annex I of the Directive.

Example: You have 1,800 tonnes of flammable products in stock (lower threshold, e.g. 2,500 t) and 800 tonnes of toxic substances (lower threshold, e.g. 1,000 t). You calculate the fractions for each category and add them together. If the total exceeds 1, the warehouse becomes a high-risk facility.

The authors go further and create a 7-zone risk scale (ranging from green – low potential, through yellow and orange, to red and black – high). This allows even warehouses below the formal SEVESO III thresholds to assess the risk of an accident.

4. Long-term storage of fuels and fertilisers

The continuous storage of many tonnes of ammonium nitrate poses a colossal chemical risk of explosion. We therefore advise meticulously recording every kilogramme brought in via the WMS system, so as not to exceed the strict limit under any circumstances.

Why have such stringent requirements been introduced in the regulations?

The aim of the law is to eliminate any chance of an environmental disaster. Just imagine a massive fire in a huge warehouse in the middle of a large city full of high-rise blocks of flats. You can read here what the storage of lithium-ion batteries really entails, and you will understand the terrifying scale of the problem.

That is why every officially certified and registered high-risk warehouse requires investors to make simply colossal investments in fire safety measures. Emergency detection systems for highly flammable gases or smoke are installed there. We write more about safety regulations in warehouses here.

Frequently Asked Questions (FAQ) about the SEVESO III Directive

Is a chemical warehouse subject to the SEVESO III Directive?

Yes. When hazardous substances (e.g. flammable substances in Class 3 or oxidisers in Class 5.1) are permanently stored inside a warehouse and reach the specified mass thresholds, the SEVESO III Directive applies to you. The only exemptions are for short-term transit shipments en route to their final destination.

What are the obligations of a SEVESO high-risk establishment?

When personally managing such a facility, you must draw up a set of detailed internal policies. Strict fire safety regulations require every certified high-risk warehouse:

  1. To draw up, in collaboration with an external auditor, a meticulous and comprehensive Major Industrial Accidents Prevention Policy.
  2. Design a modern Safety Management System (SMS) that operates efficiently around the clock.
  3. Immediately report this official fact to the Chief Fire Officer and the Regional Environmental Inspector.

Which substances determine SEVESO classification?

Official guidelines clearly explain to the logistics sector what the SEVESO III Directive entails, logically categorising hazardous substances into specific names and global categories under GHS/CLP. According to the regulations, these are overwhelmingly:

  • petroleum-based petrol, caustic chlorine and agricultural-grade ammonia;
  • heat-activated oxidisers and flammable liquids in drums;
  • highly compressed refrigerant gases used by welders and environmental toxins.

Conducting a compliance analysis under the SEVESO III Directive and implementing procedures can be time-consuming and requires specialist knowledge. Rather than devoting your team’s valuable time to tedious record-keeping and training, you can entrust this burden to professionals. Contact us and ensure your logistics operations are both compliant and safe.

Bibliography

  1. Castro Rodriguez, D. J., Shi, H., Vitale, M., Demichela, M., & Barresi, A. (2025). Assessing the major industrial accident potential based on dangerous substance criteria: A framework for Seveso and non-Seveso facilities. Chemical Engineering Transactions, 116, 409–414. https://www.cetjournal.it/cet/25/116/069.pdf
  2. Directive 2012/18/EU of the European Parliament and of the Council of 4 July 2012 on the control of major-accident hazards involving dangerous substances. (2012). Official Journal of the European Union, L 197, 1–37.https://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX:32012L0018
  3. Gabryelewicz, I., Wędrychowicz, M., Woźniak, W., & Besta, P. (2022). SEVESO III Directive – Information on Establishments with a High or Increased Risk of a Major Industrial Accident. Rocznik Ochrona Środowiska, 24.https://www.researchgate.net/publication/365895561
  4. Pissourios, I. (2025). A critical review of the implementation of the Seveso III Directive in the framework of land-use planning: A comparative study of Greece, Cyprus, and Slovakia. Land, 14(6), 1194.https://doi.org/10.3390/land14061194
  5. Regulation of the Minister for Development of 29 January 2016 on the types and quantities of dangerous substances present on site. (2016). Journal of Laws, item 138. https://eli.gov.pl/eli/DU/2016/138/ogl
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