STORAGE OF FLAMMABLE PRODUCTS

R.D. 379/2001
Regulations regarding the storage of chemical products and the additional technical instructions for specific products and their categories. This section looks at the main characteristics regarding storage, ie: tanks, drums, portable containers, bottles, etc. It also considers the location of the storage, ie: above ground, below ground, inside, cupboards, etc. and the protective measures against the risks that are present in these storage areas.

ADDITIONAL TECHNICAL INSTRUCTIONS FOR FLAMMABLE LIQUIDS “APQ-001”

Product classification:
They are classified as A, A1, A2, B, B1, B2, C and D, depending on their flammability and the conditions of storage.

Combustion temperature or Flashpoint.
This is the minimum temperature at which a flammable liquid gives off enough vapour to create a flammable mixture with the air surrounding the surface of the liquid or inside a container. In the test to determine the flashpoint, a flame is used as a source of ignition.

The liquid is heated slowly from a theoretical lower temperature and as the temperature increases, a flame is applied to the vapour chamber. The point of ignition is the temperature at which a spark is observed when the flame or source of ignition is applied.
Temperature of spontaneous ignition.

This is the minimum temperature at which a substance in contact with air ignites spontaneously without any source of ignition. At this temperature there is enough energy to start combustion.

Spontaneous ignition can sometimes be called the temperature/point of auto-ignition and could also appear as ignition point. It is important to ensure that there is no confusion with the temperature of ignition or flashpoint, especially if data from tests or tables is not available. In cases where these values are not available, it must be assumed that the auto-ignition temperature is much higher than the flashpoint. In the majority of cases this is between 200 and 700 ºC. This parameter should be used as a reference for operations with a significant rise in temperature but without an ignition source such as heat treatment, heat exchangers with insulating oils, covered electric motors, etc.

The ignition temperature of hydrocarbons in the air decreases as the molecular mass increases. For example:
Methane  ................................537 ºC
n-butane ................................405 ºC
n-decane ................................208 ºC

The ignition tempetature of hydrocarbons in the air, eg: paint thinners, decreases as the container ́s size increases

The ignition temperature of toluene is 580 ºC in a container of 0,05 l.
The ignition temperature of toluene is 480 ºC in a container of 15 l.
The ignition temperature of methanol is 475 ºC in a container of  0,05 l.
The ignition temperature of methanol is 375 ºC in a container of 15 l.
The temperature of autoignition can decrease significantly due to a catalyst, such as particles of iron oxide dust, atmospheres rich in oxygen and under high pressures.

CLASS A Liquefied products, whose absolute vapour pressure at 15 °C is greater than 1 bar. Depending on the tem-
perature at which they are stored,, they can be considered as the following:
a. Subclass A1. Products of class A that are stored liquefied at a temperature below  0 °C.
b. Subclass A2. Products of class A that are stored liquefied in other conditions.

CLASS B* Products of which the ignition point is below 55 °C and are not included in class A. Depending on their 
ignition point, can be considered as the following:
a. Subclass B1. Products of class B of which ignition point is below 38 °C.
b. Subclass B2. Products of class B in which the ignition point is equal or greater than 38 °C and below 55 °C.
CLASS C Products which have an ignition point in the range of 55 °C and 100 °C.
CLASS D Products which have an ignition point greater than 100 °C.

ADDITIONAL GUIDANCE FOR STORING FLAMMABLE LIQUIDS“APQ-001” (CONT.)

These technical intructions apply to the storage, loading, unloading and the decanting of flammable liquids, such as paints and thinners, with the following exceptions:

1. Storage with a capacity below 50 l. of class B products, 250 l. of class C or 1,000 l. of  class D.
2. Storage within a process area where the capacity is limited to what is necessary for the continuity of the process.
3. Storage of products where the flamepoint is higher than  150 °C.
4. Storage of products where specific industrial safety regulations exist.

Exclusions that apply to the additional guidance for storing flammable liquids:

1.Internal use in process installations
2.The storage of paint, clearcoat or similar mixtures where they are going to be used within a 30 day period and only once.
3.The temporary storage of products waiting to be redistributed  and where the expected storage will not exceed 72 hours continuously.
In all cases, if the products are to be stored for more than 8 days per month or 36 days per year, the storage cannot be considered temporary and the long term storage guidelines should be followed.

REGISTRATION WITH THE DEPARTMENT OF INDUSTRY

New projects for storing flammable liquids in buildings or non industrial establishments can be part of a larger project or a project on their own. Where a storage facility is being designed on its own, the plans will be drawn up and signed by a competent design engineer. Where the design engineer is not the general project designer, they must work alongside the general architect and comply with the basic aspects of the installation as stated in the general design project of the building.
A project which refers to the storage regulations of chemical products should be composed of the following documents.

TECHNICAL APPENDIX

This should list, as a minimum, the following sections:
Warehousing and containers types, a description of capacities, dimensions and other characteristics. It should list the products to be stored with their safety data sheets and make reference to the regulations regarding new substances and their classification. It should also contain details of the packaging and labelling of harmful substances and the maximum pressures and temperatures expected. It should also demonstrate compliance with the design regulations.
Systems, equipment and methods of protection against fire, defining the regulations, the measures that will be used and carrying out the calculations required.
Other considerations of safety and a description of their characteristics.
The methods used to protect materials against corrosion and/or other dangerous effects.
Information about the transfer of chemicals, their characteristics and quantities.

Study of the classified zones.

Geographical and topological aspects of the surrounding area,considering  natural disasters that may happen, such as, landslides, flooding, etc. and a description of the protective measures required in each case.
Certification of the compliance with these complementary technical instructions or other measures employed.

REGISTRATION WITH THE DEPARMENT OF INDUSTRY (CONT.)

PLANS
These should include the following as a minimum:
Geographical maps preferably using scales 1:25,000 or 1:50,000. Each map should show the storage and access routes, urban concentrations and relevant topographical risks within  a 10km radius centered on the warehouse.
A general map of the area showing the safe distances according to the regulations.
Separate plans of the installation should be provided which should show the position of all fixed fire fighting equipment. A detailed plan of the fire  alarm system should be provided as well as the drainage, antipollution systems and all other safety equipment.
Detailed plans for each type of container and their safety systems should be provided.

PROPOSAL
Instructions for the use, maintenance and the safety of the installation, regarding personnel, goods and the environment.

FOR WAREHOUSES WITH A CAPACITY LESS THAN THE FOLLOWING



The project should be submitted with a written document signed by the owner of the warehouse or it ́s legal representative. This document should describe the products that are going to be stored along with their characteristics. It should also describe the warehouse and all the safety measures that are going to be used.

REGISTRATION WITH THE DEPARMENT OF INDUSTRY (CONT.)

COMMERCIAL PREMISES OPEN TO THE PUBLIC

The quantity of stored liquid must not exceed 0,8 m3 (800 liters) per square meter of floor area, without exceeding the following total quantities of:
0,2 m3 (200 liters) of class A product; 0,25 m3 (250 liters) of product  subclass B1 with boiling point below 38 ºC; 0,5 m3 (500 liters) of product subclass B1 with boiling point of 38 ºC or higher, 1,0 m3 (1,000 liters) of product subclass B2; 2,5 m3 (2,500 liters) of product class C; 10 m3 (10,000 liters) of product class D.

The floor area of the warehouse may be calculated by adding the maximum capacity likely to be reached to the same floor area for adjacent aisles.

For liquids soluble in water within classes B, C and D the above quantities may be doubled. The same applies when the area of storage has an automatic fire extinguising system installed.

Containers shall never exceed one meter in height or be piled one on top of another (whatever is the greater), unless adequate shelves or supports are available. Filling, transferring or handling of liquids in classes A and B1 is not allowed below ground level.

Where these operations are carried out above ground level, a maximum of 0,04 m3 (40 liters) per square meter of floor area must be followed and a low voltage electrical installation must be in operation. This must be installed in accordance with the current regulations for electrical installations in areas with a risk of explosion or fire (EX).
In these buildings, people other than employees from the warehouse are expected to have access.

For example, customers who purchase large quantities of paints and solvents for retail sale, may collect their own stock. A safe and organised warehouse is essential. 

SUMMARY OF REQUIREMENTS FOR COMPLIANCE TO APQ-001

LOCATION OF THE WAREHOUSE

In general, for all warehouses with portable containers having an individual capacity of less than 3,000 liters, the unstable liquids of classes B, C and D should be treated as if they were a product of subclass B1. Flammable aerosols should be treated as if they were of subclass B2.
Storage of product classes A and B1 are not allowed underground.

PROTECTION AGAINST RISKS

A. Transport: Portable containers must comply with the dangerous goods blity road regulations (ADR).

B. Pressure relief valves: Containers which have a capacity greater than 250l. should have an emergency venting valve. The capacity of this valve must not be less than the capacity on a fixed container. Thermal relief devices, such as fusible plugs, should be used when the product may block other methods of venting. The operating temperature of these devices must not be greater than 150 ºC.

C. Volumes and quantities: When liquids of mixed classes are to be stored in the same stack or shelf, the whole group of liquids should be treated as being in the most restrictive class. If the warehouse is organised in stacks or separate shelves, the total quantities stored must not exceed the quantities permitted for each class.

D. Evacuation: Warehouses within buildings must have at least two independent escape routes, which are clearly signed. The length of the emergency exit corridor must not be greater than 25 m. Access to other areas should have 60 min. automatic fire doors. The corridor should be a minimum of 1 m. wide, except where specific warehouses demand a greater width.

E. Electrical installation: It should comply with the current regulations for areas with a risk of explosion (EX). It should also comply with regulation MI-BT-026.

F. Location: Where shelving is used with wooden shelves or platforms, they must be strong and have a minimum thickness of 25 mm. The containers should be packed, palletised and stacked ensuring stability and following the maximum stacking height. This is to prevent excessive weight in the lower pallets. The highest point of the stored products must be at least 1 meter below any beam,  building structure, sprinkler head or other vertical obstruction. This height must not exceed the values given in tables II and III of section three of the ITC.

G. Ventilation: The warehouse must have natural or forced ventilation. This must comply with regulation 3 of section three of the ITC.

H. Spillages: The floor and the first 100 mm of the walls around the warehouse area should be resistant to liquids including doors and openings.
Alternatively, the floor may drain to a safe place.

I. Protection against fire: Section three of the ITC lists the necessary fire protection measures for mobile containers and are shown in section 5, of table 5.

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EXPLOSIVE ATMOSPHERE REGULATIONS (EX)

Directive 1999/92/CE establishes a framework for the regulation of the safety mecanisms, equipment and installations which all companies must comply with, as long as their activity involves risks derived from explosive atmospheres (ATEX).

This legislation requires the evaluation of the health risks, which must be collected in the document “Protection Against Explosion”. This document brings together and identifies the zone classifications which are potentially explosive and indicates the technical means and organisational methods to prevent the formation of explosive atmospheres (ATEX).

It also establishes mecanisms that allow the reduction of the damaging effects of an explosion in a manner that guarantees the safety of the workforce.

WHAT IS ATEX?
ATEX comes from the abbreviation of ATmosphere EXplosive, which comes from a series of European Directives and which member states of the EU are obliged to comply with.

Relevant regulations:
Directive 94/9/CE - ATEX 100:
Regarding the apparatus and protective systems for use in explosive atmospheres.

Directive 1999/92/CE - ATEX 137:
Regarding the protection of the health and safety of the employees exposed to the risks derived from the presence of explosive atmospheres in the workplace.

MAIN TYPES OF EXPLOSIVEATMOSPHERE
Explosive gas atmosphere:
Is a mixture with the air, under atmospheric conditions, of a flammable substance in a gas or vapour state, where, in case of ignition, the combustion propagates to all of the unburnt mixture.

Explosive atmospheres involving dust:
Is a mixture in air, under atmospheric conditions, with flammable substances in the form of dust or fibres, in which, in case of ignition, the combustion propagates to the rest of the umburnt mixture.

PROTECTION AGAINST EXPLOSION
The ATEX Directives establish the necessary measures for the protection and safety of employees within the explosion risk areas. Following measures are obligatory for the employer:

GENERAL
In places where explosive mixtures can take place, the working environment should be adequately protected, so that work can be carried out safely.
In places where explosive atmospheres take place, the following technical measures should be taken along with proper supervision of the working environment whilst employees are present in these environments

ADOPTION OF MEASURES FOR PROTECTION AND PREVENTION AGAINST EXPLOSION

Taking specific technical or organizational measures depending on the type of activity, following a priority order and in accordance to the following basic principals:
Avoid the formation of explosive atmospheres.
Avoid the ignition of explosive atmospheres.
Reduce the effects of a possible explosion.
The previous measures will be combined or will be completed with others to avoid propagation of explosions, where necessary.
The application of measures will be revised periodically and when important changes have occured.

DEVELOPMENT OF DOCUMENTATION FOR PROTECTION AGAINST
EXPLOSION “ATEX”

Including  as required by law.
Evaluation and definition of the risks of explosion.
The necessary measures to fulfill the requirements of Directive 1999/92/CE.
The different areas classified into zones.
The areas where the minimum requirements of Annex II of regulation Directive 1999/92/CE apply.
That the place and the equipment is designed, used and maintained according to the safety requirements.
That the work equipment is used according to the safety requirements

ZONE CLASSIFICATION
Gases, vapours and fogs are classified into zones, according to the following criteria:

ZONE 0 (GAS)
ZONE 20 (DUST)
Work area where an explosive atmosphere consisting of a mixture of air and flammable substances (in the form of gas, vapour, fog or dust), is permanently present for frequent or long periods of time.

ZONE 1 (GAS)  
ZONE 21 (DUST)
Work area where it is possible, under normal conditions of operation, the formation of temporary explosive atmospheres consisting of a mixture of air and flammable substances in the form of gas, vapour, fog or dust.

ZONE 2 (GAS)
ZONE 22 (DUST)
Work area where it is not usual, under normal conditions of operation, the formation of temporary explosive atmospheres consisting of a mixture of air and flammable substances in the form of gas, vapour, fog or dust, but when created, will only be present for short periods of time. 

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PROTECTION AGAINST FIRE AND EXPLOSION

There are two ways to achieve the protection level required against fire and explosions: reducing the sources of ignition, and using suitable facilities and equipment.

a) Reduce ignition sourceRooms used for handling or storing paint, should have ventilation system that prevents the formation of explosive atmospheres. To achieve this, follow these recommendations:

• Keep cleaning solvents in the designated areas.
• Close containers used for paints, solvents, thinners and in general all containers that can concentrate dangerous gases during their evaporation, as soon as possible after use.
• Close cleaning equipment for spray guns when not in use.
• Store used cleaning cloths contaminated with wastes in fireproof containers provided with a lid. Remove daily from the paintshop.
• The quantity of prepared flammable products stored in the paintshop should not exceed what is necessary for the shift or work period.

b) Avoid sources of ignition: specially on those places where there is a risk of explosion or fire, due to the nature of work. It is important to follow this recommendations:

• Separate and isolate the rooms with a risk of fire from other working places.
• Avoid mixing putties wastes with other chemical wastes, as the high temperatures achieved while drying in putties might lead to ignition in contact with other chemical products.
• Avoid storing empty paint and metallic cans that might lead to the creation of sparks by hitting against each other.
• Observe and comply with the regulations concerning safety low voltage installations.

c) Ensure availability of fire extinguishing equipment:

• Place adequate fire extinguisher close to the Spray booth and in an accessible place (fire class A and B).
• All painting area must have 25mm fireplugs in place and scale complying with the Industrial Facilities Firefighting Regulation.
• Use foam resistant to alcohol, carbon dioxide, chemical powder or water sprays as fire extinguisher. Never use direct water stream.
• Keep fire exposed cans cool with water spraying.
• The fire will produce dense black smoke and the products of combustion may be dangerous if inhaled.

HOW TO USE A FIRE EXTINGUISHER

1. PULL OUT THE SAFETY PIN: Support the top of the cylinder and hold on to the hose with the left hand. Activate  the extinguisher by squeezing the levers fully with the right hand.
2. AIM: the nozzle at the base of the fire.
3. MAINTAIN: the flow of the extinguisher by continuing to squeeze the levers fully.
4. DISTRIBUTE:  the contents of the extinguisher by waving the nozzle from side to side at the base of the fire until the extinguisher is empty.

PERSONAL SAFETY PRECAUTIONS:
NEVER get too close to the fire.
NEVER let the fire come between you and the exit route to the outside.
NEVER enter an unfamiliar area to put out a fire, especially in a chemical laboratory.
Notify the competent person or organisation, if necessary.

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BASIC CONCEPTS IN STATIC ELECTRICITY

STATIC ELECTRICITY IN THE TRANSFER OF FLAMMABLE SUBSTANCES

The generation of electrostatic charges in the handling and transfer of flammable liquids causes frequently serious accidents.

Though commonly known, these dangers are not usually taken into consideration where safety measures are concerned. It is very important to avoid the generation of static charges in the presence of flammable atmospheres and to ensure its rapid elimination when created.

FORMATION OF STATIC ELECTRICITY
The formation of static electricity is mainly produced by:

Electrostatic dischargers can occur between metallic parts of different charges or between the surface of the liquid itself and a metallic part, such as a dipstick or stirrer in the presence of a flammable atmosphere inside a tank  or in the area immediately surrounding  the container.

PREVENTION MEASURES TO BE CONSIDERED

Control of flammable atmospheres.
All flammable liquids within an open container and above its flamepoint gives off a quantity of vapours capable of creating a flammable mixture with the air. For that reason, it is necessary to take into consideration that the risk won ́t be enoughly controlled if we only consider the elimination and control of the source of the ignition, as other risks exist apart from the risk of static electricity.

Control of the flow rate of liquid and the filling system of containers.
It is recommended to avoid high speed flow through pipes, and ensure a smooth surface in contact with the liquid specially controlling the presence of water or impurities which are notorious in the generation of static electricity.

Use of antistatic additives.
Used to increase the conductivity of the products, making it easier to discharge the static electricity generated.

Electrical installation and protected equipment.
The electrical installations, equipment and other electrical materials used in locations where the transfer and storage of flammable liquids takes place must be designed and installed in accordance with the complementary instructions Ml BT 026 of the electrotechnical regulations for low voltage (Directive 79/196/CEE) referring particularly to the guidelines for premises with a risk of fire and explosion. Also it is obligatory to comply with the regulation UNE 20-322-86 “Classification of locations with risk of explosion due to the presence of gases, vapours and flammable clouds.

Control of mechanical impact and other sources of ignition.

The proximity of dangerous atmospheres close to sources of ignition, other than sparks from electrostatic discharges, must be controlled as much as possible. Special attention must be paid to the effects of mechanical impacts which must be avoided at all cost.

The mechanical parts of pumping equipment, like the suction tubes of portable pumps and hose connections, should be constructed from antistatic materials, usually an alloy of aluminium and zinc (Al-Zn).

PREVENTION MEASURES TO BE CONSIDERED (CONT.)

Equipotential bonding cables and grounding:
 it is imperative that static electrical charges are eliminated easily without causing danger. This is achieved fundamentally by the method of interconnecting all of the conductive surfaces, which may form an electric charge and connecting them at the same time to earth.

Control of resting time:
it is fundamental to maintain a waiting time, which is also called the resting time from the end of the transfer until the beginning of operations which may generate sources of ignition, such as opening of lids, collecting samples, etc., that might generate energy by impact or mechanical dents or even electrostatic sparks. These resting times provide a wide margin of safety in the working process and depend on the type of product being transferred.

For conductive flammable liquids the resting time should be a minimum of 30 seconds and for non conductive liquids with a resistivity greater than 1,011 Ωcm, the resting time should be a minimum of 1 minute.

Personnel work clothing.
The personnel that work in installations where transfer of flammable liquids takes place must not use clothes made from synthetic fibres and the clothing should be preferably of cotton, including the underwear. It is also advisable to limit the use of woollen clothing where possible.

Footwear and in this case the gloves, should also be conductive.

This will offer enough protection, provided that the floor is conductive, which also has to be taken into consideration.

The normal shoe with a leather sole offers, especially if the humidity is enough , a greater level of conductivity.

Nevertheless, for people with very dry skin or when using other insulating materials along with leather soles, metal rivets going through the sole are highly recommendable.

Control of ambient humidity and safe working procedures:
the maintenance of a relative humidity of above 60% is highly recommended in environments that may be flammable along with the capacity of those exposed to the risk to carry out safe working procedures.

Control of flammable atmospheres:
Detectors to measure the concentration of flammable vapours.

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WHAT TO DO IN CASE OF SPILLAGES

1. Stop and pick up the spillage with non flammable absorbent materials, such as sand, soil, absorbent granules, etc., and place in adequate containers for its subsequent treatment.
2. Eliminate any possible sources of ignition. Avoid any inhalation and ventilate the affected area.
3. Avoid allowing spillages to enter the drains or water courses, notifying the relevant authorities, should this happen.
4. Clean the affected area with detergent, avoiding the use of solvents.

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TREATMENT OF HAZARDOUS WASTES

(DIRECTIVE 94/62/CE CHEMICAL CONTAINERS AND WASTES OF CONTAINERS)

HOW TO DETERMINATE IF THE WASTES THAT ARE PRODUCED ARE DANGEROUS
Many companies ignore they are producing dangerous wastes and even those which are aware of the problem ignore the correct course of action for disposal and the consequences if these wastes are not properly disposed of.

The following questions and answers aim to clarify some of the doubts that may arise regarding the legislation of wastes in containers and should be of interest for companies that generate this waste.

IS IT POSSIBLE TO USE THE GREEN POINT  SYSTEM WITH INDUSTRIAL CONTAINERS?
No. The Ecoembes organisation doesn ́t allow this. An option would be to create voluntarily a similar system following the requirements of the law.

WHO IS RESPONSIBLE FOR THE FINAL DISPOSAL OF INDUSTRIAL CONTAINERS AND WASTES?
The end user of the container. In the case of industrial or commercial containers, of all the various companies that are involved in the sales chain from the moment the product is first marketed to the buying, selling  and distribution of the products, the responsibility for the proper transportation and disposal of the waste in accordance with the regulations, will be the end user of the product.

WHO MAY ACCEPT THE WASTE WASTE FOR PROCESSING AND DISPOSAL?
Only authorised companies,for its classification and ultimate disposal.

In all cases, the holder of the wastes will be obliged, while they are in his/her possesion, to maintain them in an adequate condition of safety and hygiene.

The containers that are nearly empty, but have wastes of solvents remaining are especially dangerous because of the risk of explosion if they come into contact with flame or heat.

Storage of the wastes should be in containers in well ventilated zones and which are not exposed to heat or sources of ignition whilst they are awaiting disposal.

Don ́t take wastes, cloths, gloves, etc., mixed with paints or oils to landfill sites or mix them with urban rubbish as this would cause hazards at landfill sites.

ARE ALL CONTAINERS THAT WERE ONCE USED FOR CHEMICAL PRODUCTS ALSO CONSIDERED DANGEROUS WASTES?
Not always, but to know whether it is considered dangerous waste or not, guidance should be taken from the European List of Wastes.  Order MAM/304/2002.

They are only considered dangerous if the percentage in weight of dangerous substance in the container is enough for the waste to present one or more of the listed characteristics in Annex three of the directive 91/689/CEE (Explosive, Combustible, Flammable, Irritant, Harmful, Toxic, Carcinogenic, Corrosive, Infectious, Teratogenic, Mutagen and dangerous for the environment).

Order MAM/304/2002 of 8th of February annex 2 B): “Any waste classified as dangerous  through a specific reference or generally dangerous substances should only be considered dangerous if the concentration of these substances (given as a percentage by weight) is enough for the waste to present one or more of the listed characteristics in annex three of the directive 91/689/CEE of the board”.

HOW IS THE CODING OF DANGEROUS WASTES CARRIED OUT?
To find out the code of each waste it is necessary to refer to Directive 91/689/CE and also to the Order MAM/304/2002 “European List of Wastes, procedures for classification and disposal of wastes”.

LABELLING GUIDELINES FOR DANGEROUS WASTES
General characteristics of the labelling:

• Size of the label: 10 × 10 cm. (minimum).
• The label should be firmly fixed onto the can and it can be of the following types:
• Labelling material: paper (placed inside the container), laminated on the exterior.
• Labelling on the back: using adhesive labels.

CAN ANYBODY REMOVE DANGEROUS WASTES?
No. Only specifically authorised companies for the handling and disposal of dangerous wastes within each of the autonomous counties.

WHAT ACTION CAN BE TAKEN AGAINST COMPANIES THAT DON ́T COMPLY WITH THE LAW IN THIS MATTER?
Fines and closure, among others.

In the majority of cases, the necessary information for the classification of chemical wastes is held by the waste producing company, but it may be that such information is not known or where it is availabe, or those responsible for such matters don ́t know how to use it.

In order to carry out the classification, three helpful tools are available:

• Safety data sheets for the products that have been used in the formation of the
• wastes.
• European list of wastes.
• Analytical description by external laboratories.

In the majority of cases, the company itself can use the first two methods to reasonably determine the classification of the waste. The objective is to classify the wastes in their simplest form.

The best and most profitable for any company, is for the company itself to classify its own waste, although there are cases where this is not possible.

Never use drains or sewers to dump waste wastes, including chemicals soluble in water.

EXAMPLE OF DECLASSIFICATION OF A DANGEROUS WASTE:
Containers once holding solvents.
When consulting the European List of Wastes, a company in the process of classifying some containers that previously contained solvents, may encounter a dilemma as to what code to assign to the waste: 15 01 10 Metal containers

In principal they may be treated as contaminated metal containers, but it isn ́t always clear if they contain dangerous substances. The safety data sheet shows that this product contains dangerous substances and that leads us to believe that the container holds also this substance, though in smaller proportions. All this indicates it is a dangerous waste.

It is necessary to look at the hazard characteristics associated with each substance, to see if the H factor associated with this product  falls within the established thresholds which are considered to be dangerous and this may show the waste  to be present in quantities smaller than those established in the regulations and therefore not harmful.

To obtain information about the substance and it ́s respective dangers turn to section 3 in the data sheet where the following can be found about the components of the solvent.

Containers once emptied may keep impregnated solvent. This solvent normally evaporates within a few days, showing an empty inside, though some of the dangerous substances may still be left behind. Flammable substances (F= H3) evaporate leaving behind harmful substances (Xn= H5) and irritant substances (Xi= H4). The concentrations established in Order MAM/304/2002 are more restrictive for irritant substances, therefore will be the one to consider as a reference, as it is very difficult to estimate how much of each substance is left.

For the waste not to be considered harmful, the concentration must be less than 20% by weight, eg (the total weight of the container = the weight of the container + the weight of the substance).

According to information supplied by the manufacturer. the weight of an empty container is 500 grammes and the maximum quantity of irritant substances with the risk of R36 that could be contained is 100 grammes.

The weight of the empty solvent container, once dry is 525 grammes. As it contains 4.8% of irritant substances as a maximum, it follows that these 25 grammes of substance came from the solvent which is considered to be the total of the irritant substance. As the quantity of the irritant substance is less than 20%, the waste may be declassified and may be dealt with as non harmful waste.

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TRANSPORT OF DANGEROUS GOODS BY ROAD(ADR)

European Agreement on the International Transport of Dangerous Goods by Road signed at the United Nations, can be adopted by all the member states of the European Economic Community.

This agreement is law and all those who transport, load and unload dangerous goods must follow this regulation.

The loading, unloading or transport of paints, clearcoats or printing inks, is likely to mean that we are working with dangerous goods and because of this, we are obliged to follow the regulations for this type of work. If the regulations are to be followed properly, there are some basic questions that need to be answered:

Are there any exemptions within the ADR regulations and am I obliged to comply with all or some of these regulations?

PARTIAL
Partial exemptions for quantities in transport (Subsection 1.1.3.6):
In the case of partial exemption, the transportation card should read:
“Transport that does not exceed the limits prescribed in subsection 1.1.3.6”.

TOTAL
Total exemptions (LQ = Limited Quantity) (See section 3.4):
For the transport of dangerous goods packaged in limited quantities (in small containers and the insurance allows a total exemption of compliance of the ADR regulations). Indication on the waybill of the product ́s existance is not required.

If necessary:

• Are the containers correctly homologated for transport as dangerous goods?
• If carrying in bulk, have you got the necessary labelling?
• Should the truck have orange signs?
• Does the person loading, trasporting and unloading have the safety information at his disposal?
• Does the driver need to be licenced to transport dangerous substances?
• Do we have to prepare waybills and instructions for the drivers?

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