Many environmental incidents at facilities start in a store room: drums stacked on bare soil without containment, two reactive substances side by side, or contaminated empty containers thrown out with general waste. Storing hazardous chemicals correctly is one of the first things inspectors look at, and one of the easiest to get right once you know the rules. This article brings together what the Environment Law's regulations and the Waste Management Law say about storage, with a practical checklist for your facility.
Why storage matters legally
- Soil: the Implementing Regulation for Preventing and Treating Soil Pollution requires everyone to take appropriate measures to prevent soil contamination or its likelihood, and prohibits failing to notify NCEC immediately when soil contamination is detected within their activities.
- Emergencies: the regulations define an environmental emergency as any operational incident that threatens habitats or harms the environment; a major spill is a direct example.
- The permit: adding hazardous materials that were not part of the activity is a change in the type of activity, and the Environmental Permits Regulation requires a new operating permit before any change to the type or size of the activity.
- Waste: the Waste Management Law defines hazardous waste as including toxic, flammable, reactive or corrosive materials, solvents, degreasers, oils, acids and alkalis. Expired or damaged materials in your store become hazardous waste with their own path.
Basic rules for a hazardous materials store
- An up-to-date inventory of all materials, quantities and locations, with a safety data sheet for each.
- Segregation by compatibility: acids away from bases, oxidizers away from flammables, as stated in the safety data sheets.
- Containment and impermeable floors that hold any leak, and no storage on bare soil.
- Clear labels on every container and storage area.
- Adequate ventilation and distance from heat sources and direct sun.
- Spill kits nearby, and staff who know how to use them.
- Disposal of damaged materials and contaminated containers through a carrier licensed by the National Center for Waste Management (MWAN), with a transport document for every shipment.
Solvents and volatile organic compounds: specific requirements
If your facility stores solvents or volatile organic compounds, the Air Quality Regulation sets specific requirements, including:
- Aluminum and magnesium alloys may not be used to store solvents; carbon steel, stainless steel and zinc-galvanized steel are acceptable.
- Plastic containers may be used when they are resistant to their contents.
- Tanks larger than 5 cubic meters must have protective valves and installed vapor recovery systems.
- Tanks should be shaded where possible and painted in light colors to reduce solar heating.
- A preventive maintenance schedule for tanks and pipework, applied and documented on site.
- Records of the chemical name of stored compounds, tank capacity and true vapor pressure.
Refrigerants and fire suppression agents
Some facilities store refrigerant gases or halons for fire suppression systems. These are regulated by the Implementing Regulation for Ozone-Depleting Substances and Hydrofluorocarbons, which prohibits using or storing controlled substances without an NCEC permit, prohibits disposing of them without NCEC approval, and requires anyone repairing or servicing equipment containing them to hold a license or permit and use recovery equipment instead of venting to the environment.
The warehouse that changes what it stores
A common case: a warehouse permitted for general goods starts storing chemicals for a new client. That is a change in the type of activity requiring a new operating permit before it happens; doing it without approval allows NCEC to suspend the permit until corrected, with penalties.
When a spill happens
- Stop the source and contain the spill with the ready equipment.
- Keep it away from drains and soil.
- Notify NCEC immediately if soil contamination is detected, as the soil regulation requires.
- Collect contaminated materials and hand them to a licensed carrier as hazardous waste.
- Record the incident and the response; a remediation plan for the contaminated site may be required under the Rehabilitation Regulation.
Frequently Asked Questions about Hazardous Materials Storage
What is a safety data sheet?
A supplier document describing a material's properties, hazards, storage and spill response; one must be available for every material in the store.
What does segregation by compatibility mean?
Not storing materials that may react with each other in the same place, such as acids with bases or oxidizers with flammables.
Do I need containment for every drum?
Ideally the whole liquid hazardous storage area sits on containment or an impermeable floor that holds any leak.
How do I dispose of an expired material?
Treat it as hazardous waste and hand it to an MWAN-licensed carrier with a transport document. Handing it to an unlicensed party makes you jointly liable for damages under the Waste Management Law.
How Abak Green helps
We visit your stores, review them against these requirements, prepare a hazardous materials and emergency response plan as part of your environmental management plan, set up records, and verify your carriers' licenses. Contact us to review your stores.
