Seveso II Directive
Major accidents in the chemical industry have occurred worldwide. The Seveso accident in 1976 prompted the adoption of legislation within the European Union.
The aim of the Seveso II Directive 96/82/EC is two-fold. Firstly, the directive aims to prevent major-accident hazards involving dangerous substances. Secondly, the directive aims to limit the consequences of such accidents for mankind but also for the environment.
The scope of the Seveso II Directive deals solely with the presence of dangerous substances in establishments. It covers both manufacturing plants as well as the storage of dangerous chemicals.
Today manufacturing plants and warehouses where aerosol products containing flammable propellants and/or liquids are present may fall under scope of the Directive depending on their respective tonnages and the presence of other dangerous chemicals.
Seveso II Directive revision
A review of the Seveso II Directive was primarily triggered by the adoption of the UN GHS in the EU 'Acquis Communautaire', because classification criteria have changed and downstream legislation needs to be adapted.
In 2008, a Technical Working Group "Seveso and GHS" was established by the European Commission. FEA participated in this group and provided its expertise to translate one-on-one current provisions into two new 'flammable aerosols' entries.
FEA also participated in the Stakeholder Consultation meeting on 10 November 2009.
In the event of an accident, flammable aerosols (small sealed containers of maximum 1 litre capacity) will clearly have a lower impact than LPG in bulk tanks. This lower hazard is widely recognised, however the current aggregation method assigns the same hazard level to LPG whether in bulk or in small containers.
However assessing this difference quantitatively is not an easy task. FEA commissioned the independent consultant known as ATKINS in order to evaluate this difference and to propose appropriate and adequate threshold quantities for flammable aerosols.
The key conclusions of the ATKINS report are as follows:
- Flammable aerosols do not pose a substantial major accident hazard (i.e. flammable aerosols are not considered to produce consequences comparable with a major hazard accident as defined in Seveso II Directive)
- Flammable aerosol hazards are already well managed by an industry sector with decades of experience that has produced comprehensive guidance on the management of their hazards/risks
- Generally, applying the qualifying quantities used for LPG is very strict and provides no justification on the basis of the current state of knowledge, nor it is necessary due to the existence of a separate category for these items
- Increasing the qualifying quantities of flammable aerosols by a factor of at least 10 seems appropriate when considering the factors outlined above. This would give qualifying quantities of 500/2000 tonnes of the LPG content in flammable aerosols
- Reflecting the findings of the FEA study based on the proportion of propellants in flammable aerosols would permit the qualifying quantities to be further increased by a factor of 2.6 if the average value found was adopted. This would give qualifying quantities of 1300/5200 tonnes of the total content of flammable aerosols