Know How

The two questions in the title above are inextricably linked. Why? We will try to answer this in the following article.

ADR warehouse

The very phrase "ADR warehouse" is a term used by practitioners and has no origin in theory or any legal act. Those who would like to find such a definition or one comprehensive legal act regulating the storage of dangerous goods will be disappointed, and potential investors must be patient and know the subject well, because it is not easy. An ADR warehouse is simply a warehouse where goods considered dangerous are stored (ADR is an abbreviation derived from French, from the convention dealing with the carriage of dangerous goods by road).

To talk about the storage of dangerous goods in a warehouse, we have to face two problems:

• construction of an appropriate (safe) warehouse,
• safe organisation of work and internal logistics.

We must treat security in a very broad way, i.e. as the security of people, the environment and the environment. "Safe warehouse" is a warehouse built, of course, in accordance with the current construction law and "fire" regulations. Until then, it's no different than building a warehouse for neutral goods. It only gets worse…

Next, we must look at the construction issues from the point of view of specific goods and their properties (included in the safety data sheets, MSDS) that we intend to store.

For example, for class 1 hazardous materials ("ADR Convention"), many different additional conditions and requirements provided for in the Act of 21st June 2002 on explosives for civil use and the Regulation of the Minister of Economy of 27th October 2010 on storage rooms and facilities for storing explosives should be taken into account .

Both of legal acts mentioned above approach the issue of the distance of buildings where hazardous materials are stored from other buildings and facilities, roads, etc. In the course of designing, it may turn out that having a specific area at our disposal, we will not be able to implement our investment intentions on the originally planned scale due to the maintenance of much greater distances, which may be reduced, for example, by building embankments or additional walls/partitions.

Next, we must look at the construction issues from the point of view of specific goods and their properties (included in the safety data sheets, MSDS) that we intend to store.

The regulations also impose additional requirements on internal infrastructure. Forklifts must have an electric drive, the floor in the warehouse must discharge electric charges, for some classes of materials it will be necessary to install additional emergency exhaust ventilation or electrical installations and lighting that meet ATEX standards (for explosive atmospheres).

Safe storage seems to be much more complicated in terms of regulations than the construction of a suitable facility. In addition to the many additional requirements provided by the standards for explosives or the ADR convention (which exclude the simultaneous storage of certain groups of materials), specific provisions on occupational health and safety apply. Additional conditions include: detailed access control, verification of employees who come into contact with hazardous materials, etc. Everything gets complicated when the quantities we want to store exceed certain thresholds provided for in subsequent specific regulations.

Current regulations provide for two thresholds for specific groups of materials (classification different from the one used in the ADR regulations in road transport), the exceeding of which (for the entire area belonging to the investor, geodetic criterion of one plant), obliges the storage company to obtain special statuses: ZZR - increased plant and ZDR- upper-risk undertaking. In both cases, decisions on granting such a status, after a tedious and long-term analysis of documentation and a solid audit, are taken by the fire brigade and the Regional Inspectorate for Environmental Protection.

We must remember that already starting construction, we must obtain an environmental decision in which we specify the potential impact on the environment. Only after exceeding the area of 5000 m2, the warehouse base is automatically considered as potentially influencing. However, in each case, the commune head/mayor consults the Regional Inspectorate for Environmental Protection. The status and documentation itself is very strongly related to specific groups of goods, so their change involves updating the documentation. For logistics companies, this is a real administrative horror…

You should also remember about shortened inspection periods of equipment, all installations and devices in connection with the storage of hazardous materials. And as if all this was not enough, at the very end additional conditions may be imposed by the insurer ...

The short list of companies that have such a status proves how difficult this business is. ADR warehousing is where only "eagles dare". The above-mentioned considerations on the ADR warehouse and safety related to the storage of dangerous goods are only an introduction to much more detailed publications on this issue.