Things to keep in mind to comply with the APQ regulations
In October 2017 Royal Decree 656/2017 of 23 June, which approves the Chemical Storage Regulations, known as APQ, entered into force. We will explain it carefully below.
What the APQ regulation is all about
You should know that the purpose of this new regulation is to improve safety in hazardous chemicals storage facilities, with the priority objective of preventing damage to people, property and the environment. This regulation includes Additional Technical Instructions, hereinafter ITC, which introduce certain variations from the previous one, with particular emphasis on the storage of hazardous chemicals in mobile containers.
Please note that this new regulation became necessary due to all the technological advances and the experience gained since the publication of its predecessor, in which many parts of it became obsolete. Legislation should also be adapted to the European framework in accordance with Regulation (EC) No. 1272/2008, also known as CLP. This stipulates the classification, labelling and packaging of chemical substances and mixtures, as well as the REACH regulation, acronym for registration, evaluation, authorisation and restriction of chemical substances and mixtures.
This new regulation aims to establish safety conditions for both the storage, loading and unloading or transfer of hazardous chemicals, whether liquids, solids or gaseous. This will apply to newly built installations, as well as modifications or extensions of existing ones.
In order for a facility for the storage of hazardous chemical compounds to operate legally, it must comply with the regulations, as well as with its ITCs. Only by ensuring these two conditions can an activity covered by the law and that guarantees the safety of workers, as well as the protection of the environment.
How to comply with the regulations
You have to know, at the outset, if the warehouse is subject to the regulations. And there are certain exceptions depending on the type of substance in question, as well as depending on the activity to which it is intended or the quantity stored. In the event that any substance is considered to be dangerous or exceeds the quantities set out in that regulation, it is necessary to go to the relevant ITCs and apply the appropriate requirements.
If more than one ITC needs to be applied, the most severe will always be applied
Each ITC presents different constructive indications for the warehouse, as well as different needs regarding the safety devices available. In general, there are differences in the requirements for mobile and fixed vessels.
All warehouses affected by the regulation have to be notified and legalized. Please note that all these administrative procedures will be carried out in the Industry delegations corresponding to the autonomous community where the warehouse is located.
The storage of chemicals in Barcelona, always controlled by the
This procedure consists of two parts. The first is a notification, where the owner informs the Administration of its warehouse, together with the quantities and substances stored, and presents the documentation that justifies compliance with the standard. In each ITC there is a section that specifies the documentation required for this. These work will be carried out by a collegiate engineer.
In the second part, the operator has to communicate the commissioning to the competent body, once all the works of execution of the facilities have been completed. Among the documentation necessary for this justification is the certificate of management of the work made by a collegiate engineer or the proof of payment of the liability insurance.
The importance of the inspector
In order for installations that store hazardous chemical compounds to be completely safe, a series of mandatory periodic inspections and inspections must be carried out.
These inspections will consist of a plan to check the availability and proper functioning of equipment and facilities. A history will be available with the aim of not exceeding the life of the same, as well as to reflect the repairs or modifications that are made to them.
It believes that the company is obliged to appoint a person responsible for such reviews, foreign or own. It shall comply with the requirements required by law and shall act in front of the Administration as an inspector in activities required by the various regulations. The designation has to be documented.
The main annual inspections for compliance with the regulation, apart from the recommendations of the manufacturers, can be mentioned: checking the correct condition of auxiliary installations, alarms, pumps, and so on; thicknesses of vessels or pipes; or that of cathodic protection if it existed.
If you're not sure if your warehouse is eligible to be listed under the APQ storage regulations, don't hesitate to consult with an expert. Safety is always the most important thing.
