Category Archives: Chemicals

When do you need a ADR safety adviser

When you ask yourselve when do I need a ADR safety adviser in Europe? Here is your answer:
Each undertaking, the activities of which include the carriage, or the related packing, loading, filling or unloading, of dangerous goods by road shall appoint one or more safety advisers for the carriage of dangerous goods, responsible for helping to prevent the risks inherent in such activities with regard to persons, property and the environment.
The competent authorities of the Contracting Parties may provide that these requirements shall not apply to undertakings:
(a) The activities of which concern quantities in each transport unit smaller than those referred to in, and in Chapters 3.3, 3.4 and 3.5; or
(b) The main or secondary activities of which are not the carriage or the related packing, filling, oading or unloading of dangerous goods but which occasionally engage in the national carriage or the related packing, filling, loading or unloading of dangerous goods posing little danger or risk of pollution.
We can be your European certified ADR safety Adviser. Contact us.

Storage requirements of dangerous goods in packaged form in the Netherlands

The storage of chemicals is a profession. The companies that fall under this category are required to have a broad knowledge of the facts. From external risk, health and safety policy, training courses for risk management, storage and dangerous goods to fire-resistant buildings and standards for firefighting systems, flooring, ventilation, scaffolding and emergency lighting.

The requirements for the storage of dangerous goods in packaged form in the Netherlands have been established in a clear guideline: the PGS15. This “best practice” was created by representatives of business and government in the Netherlands, and is regularly updated by these same parties. It is used for licensing and is included in national laws and regulations.

The PGS15 is subdivided into several chapters. The most important chapter is chapter 3, which outlines requirements for the storage of dangerous packaged substances up to a weight of 10 tonnes. Chapter 4 of the guideline specifies the requirements for the storage of packages above 10 tonnes.

In chapter 3, the general rules state that the fire resistance between a storage location for dangerous packaged substances and another area needs to be at least 60 minutes in both directions, which can also be achieved through distance. The doors in the fire resistant walls need to be self-closing and close during periodical inspections, to ensure that, in case of an emergency, liquids cannot move from one storage facility to another.

Are you interested in storing your chemical products in the Netherlands and are you seeking for advice? Contact us and we will help you.

REACH and registration

You need to register if you are an:

  1. EU manufacturer or importer of substances on their own or in a mixture
  2. EU producer or importer of articles meeting the criteria explained in the Guidance on requirements for substances in articles
  3. “Only representative” established in the EU and appointed by a manufacturer, formulator or article producer established outside the EU to fulfil the registration obligations of importers

Registration requirements only apply to substances that are manufactured or imported in quantities of 1 tonne or more per year per registrant.  However, if a substance is manufactured or imported at less than 1 tonne per-year-per-registrant, other obligations under REACH may still apply.  These obligations, which may apply irrespectively of the volume, include obligations concerning: a) use of the substance, b) restrictions, c) authorizations and d) communication in the supply chain.

Registration must take place when a person who is the member of the EEA:

  1. manufactures a substance within the EEA in quantities of 1 tonne or more per year
  2. is responsible for import into the EEA of quantities of 1 tonne or more per year or
  3. has been appointed as an only representative according to Article 8 of the REACH Regulation

There is a special transitional regime for substances which were already manufactured or placed on the market before REACH entered into force. Such substances are called phase-in substances.

Substances that fulfil at least one of the following criteria may be considered as phase-in substances in accordance with REACH:

  1. Substances listed in the European Inventory of Existing Commercial Chemical Substances (EINECS)
  2. Substances that have been manufactured in the EU (including the countries that joined on 1 January 2007) but have not been placed on the EU market after 1 June 1992
  3. Substances that qualify as “no-longer polymer”

For these substances, the REACH Regulation sets the following registration deadlines:

30 November 2010

Deadline for registering substances manufactured or imported at 1 000 tonnes or more a year; substances that are carcinogenic, mutagenic or toxic to reproduction above 1 tonne a year; and substances dangerous to aquatic organisms or the environment above 100 tonnes a year.

31 May 2013

Deadline for registering substances manufactured or imported at 100-1 000 tonnes a year.

31 May 2018

Deadline for registering substances manufactured or imported at 1-100 tonnes a year.

 All substances that do not fulfil any of the criteria for phase-in substances are considered as non-phase-in substances. Normally, non-phase-in substances have not been manufactured, placed on the market or used in the EU before 1 June 2008, (unless they were notified under the Dangerous Substances Directive (67/548/EEC)).

Potential manufacturers and importers of non-phase-in substances have to submit an inquiry to ECHA and subsequently register the substance before they can manufacture or import the substance.