Chemical safety obligations – notifications to authorities and the chemical inventory in practice

This article is the fourth in Protect's series on chemical safety, which offers practical perspectives on fulfilling obligations. This time, the topic is notifications to authorities and the chemical inventory. The article reviews the principles of small and large-scale chemical facilities and the contents of the chemical inventory.

The difference between a minor and a major chemical plant is determined by the amount of hazardous chemicals processed and stored at the plant. If the quantities of chemicals remain below the thresholds specified in legislation, the operation is classified as small-scale. When the thresholds are exceeded, the facility is classified as a large-scale chemical plant, which also increases the risks associated with the operation and the requirements imposed by the authorities.

Permit limits are primarily determined based on the hazard class and quantity of chemicals. The more hazardous the chemical, the smaller the quantity that may be considered to constitute large-scale activity. The limits are usually expressed in tons and vary depending on whether the substances are, for example, flammable, toxic, or hazardous to the environment.

If there are several different chemicals at the facility, the scale is not determined solely on the basis of the quantity of a single substance. In such cases, a so-called sum rule is applied, in which the relative proportions of different chemicals are added together. If the result of the calculation exceeds the specified limit, the activity is considered to be large-scale.

The licensing process varies depending on the type of facility. Small chemical plants are usually subject to a notification procedure, and supervision is mainly the responsibility of the rescue authorities. Large-scale chemical plants, on the other hand, require a permit from Tukes before commencing operations. Large-scale operations also require more extensive safety documentation and regular inspections by the authorities.

The operator is responsible for being aware of the scope of the activity and the necessary documentation. The documents must be reviewed regularly and updated in the event of changes. Authorities will check if the activities and documents match. You need to let the authorities know if there are any changes to your activities or if they stop.

In minor chemical operations, the local rescue authority acts as the supervisory authority. The operator must submit a written notification to the rescue authority at least one month before commencing operations and attach the required documents.

However, the notification procedure does not transfer responsibility to the authorities. The operator must ensure the safe handling of chemicals, identify the hazards associated with the activity, prevent accidents in advance, and prepare for incidents and accidents.

Even though the activity is classified as minor, the obligations are not light. The operator must ensure, among other things, appropriate storage arrangements, clear labeling, adequate ventilation, fire safety, and staff training.

In addition, the facility must have a rescue plan. The Government has recently published updated guidelines on the content of rescue plans, and it is important to ensure that the plan is kept up to date.

You can read the updated guidelines issued by the Government here: Rescue plan, general guide.

The operator is always responsible for safety – the authorities monitor compliance with requirements.

The operation of a large-scale chemical plant always requires a permit issued by Tukes before operations can commence. The permit must be applied for in good time, as the target processing time for permits is approximately eight months. The application should be prepared carefully, as an incomplete application may prolong the processing time.

The operator must demonstrate that the safety of the facility has been designed and implemented in such a way that the risk of major accidents is as low as possible. The assessment must also take into account the process safety risks of the facility. Large-scale operations require the preparation of an internal rescue plan (Tukes Guideline: Internal Rescue Plan), more comprehensive safety management, and more detailed documentation.

Large-scale operations are divided into four different categories: permit, liquefied petroleum gas, operating principle document, and safety assessment facility. The latter two must take into account the requirements of the Seveso Directive.

A licensed facility is a large-scale chemical plant where the hazardous properties of the chemicals handled are the least severe of the control categories. However, operations always require a permit from Tukes. Licensed facilities are usually inspected every five years.

An LPG facility is defined as an operation that uses or stores at least five (5) tons of liquefied petroleum gas. The operator may also have small quantities of other hazardous chemicals.

Liquefied petroleum gas facilities are generally inspected every four years. The inspections are carried out by inspection bodies approved by Tukes, and it is the operator's responsibility to order the periodic inspection and submit the inspection report to Tukes.

The policy document falls within the scope of the Seveso legislation. The operator must draw up a written policy document describing the principles and arrangements by which the establishment prevents major accidents and limits their consequences. The document shall include, among other things, the establishment's safety management system, division of responsibilities, principles for risk identification and management, and staff training and guidance.

Although the operating principles document is not as comprehensive as the safety report, it must demonstrate that the prevention of major accidents is planned and implemented systematically. The document must be kept up to date and reviewed at least every five years. Tukes assesses the document during its inspection visits, which are usually carried out every three years.

Tukes has published guidelines on the content, preparation, and public disclosure of policy documents: Tukes Guide: Policy Document

The Safety Analysis Agency falls under the strictest control category of the Seveso legislation, as its activities involve a significant risk of major accidents. Potential accidents could have widespread effects on people, the environment, and property, which is why the safety requirements are particularly comprehensive.

The operator must prepare a safety report describing in detail the operation of the facility, the most significant risks associated with it, and the technical and organizational measures taken to prevent accidents and limit their consequences. The safety report must be updated at least every five years and submitted to Tukes and other authorities.

In addition, the rescue authorities draw up an external rescue plan for the facility's surroundings. Safety assessment facilities regularly organize joint exercises with the rescue authorities, usually every three years, and the facilities are typically inspected annually.

More detailed instructions on the content and preparation of safety reports can be found in the guide published by Tukes: Tukes Guide: Safety Report

The chemical list is a document prepared by the operator that contains information on the hazardous chemicals handled and stored at the facility. The list must include at least the trade name of the chemical, its hazard classification, its location at the facility, and the maximum storage quantity.

In small facilities where there are only a few chemicals (less than 10), the list can be maintained in table format, for example. When the number of chemicals increases, it is usually more practical to manage the list in a dedicated electronic chemical management system.

The chemical inventory is a key tool for managing chemical risks. If harmful chemical agents are present in the workplace, their risks must be assessed and controlled. An up-to-date chemical inventory forms the basis for these statutory risk assessments. Without a clear and up-to-date list, it is practically impossible to assess the risks associated with specific chemicals.

The information in the chemical list ensures that employees have sufficient information about chemical risks, that chemicals are handled safely, and that first aid and emergency situations can be dealt with appropriately. The information in the chemical list also supports the correct storage of chemicals and space solutions.

The operator is always responsible for compiling and maintaining an up-to-date list of chemicals, which must cover all chemicals used at the workplace. The information must be updated whenever there are changes in operations, new chemicals are introduced, or the chemical safety data sheet is updated. Changes in chemical quantities, intended uses, and storage locations must also be updated without delay so that the list always reflects the actual and current situation at the facility.

The comprehensiveness and up-to-date status of the list are checked regularly during occupational safety inspections. An up-to-date and carefully maintained chemical list shows that the organization manages its chemical risks and operates responsibly.

Check out the PRO24 Chemicals module, which helps you manage your chemical inventory, safety data sheets, and chemical information in a centralized manner.

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