Warehousing

The Warehousing of Aerosols

A BAMA Guide to Safe Storage

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Contents

Introduction
1. Scope
2. Terms and Definitions
3. General Requirements
4. Regulatory Framework for Storing Aerosols
5. General Safety
6. Control of Hazards in the Storage Area
7. Disposal of Aerosols

Bibliography

Annex A - Design Considerations for Aerosol Storage

Annex B – Framework Risk Assessment for the Warehousing of Aerosols

The information in this document is given in good faith, but does not imply acceptance of any liability or
responsibility by the association for the consequences of its use or misuse in any particular circumstances. The
illustrations given in this Guide are for illustrative purposes only and are not intended to be instructive.

Copyright BAMA 2008 All rights reserved

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Introduction
Storage of filled aerosols requires careful consideration because of the risks associated with
flammable propellants and liquids. Several instances of very destructive warehouse fires have been
reported, and as a result it is important to take safety very seriously. The storage of filled aerosols
has been the subject of much study by BAMA and a detailed discussion of the design of aerosol
warehouses is given in Annex A.
The purpose of this Guide is to help maximise safety levels in aerosol warehouses; it aims to cover
the whole range of aerosol warehousing, both large and small operations, and all types of products.
Therefore, some of the requirements may not be applicable to a particular warehousing operation.
Separate but related advice on retail storage of aerosols is available, free of charge, from BAMA in
the 'Guide to Retail Storage and Display of Aerosols'.
Organisations storing aerosols should establish access (either on site or immediately available off
site) to a source of competent expert advice who can provide training on aerosol safety and advice in
case of an incident. All relevant staff including temporary staff should have induction and follow-up
training about the hazards of the products stored, correct handling techniques, good housekeeping,
emergency procedures and procedures for dealing with damaged or leaking stock. Engineering staff
should also be instructed in the correct maintenance procedures and written permit systems.
Contractors should be informed of the person with accountability for their safety. BAMA also
recommends that suppliers of aerosols ensure that their contractors store aerosols safely.
The philosophy encouraged by BAMA is one of examining an operation to identify any hazards,
assessing the nature of the risk associated with that hazard and then using equipment, practices or
procedures to minimise the risk. The intention when developing this Guide was to prescribe the level
of safety not the means of ensuring that safety and so it is possible that the methods set out in the
requirements are not appropriate for a particular operation.
It is important to be able to demonstrate that you have considered all of the hazards that could arise
from your operations and that you have taken steps to ensure that the risk of those hazards occurring
is reduced to an acceptable level. This Guide is taken from The BAMA Standard for Consumer Safety
and Good Manufacturing Practice which includes a tool to help assess your operation not available in
this Guide. The BAMA Standard is available from BAMA (www.bama.co.uk).

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1. Scope
This Guide presents requirements and guidance for the storage of aerosols. It includes storage of
finished goods at the aerosol factory as well as in a warehouse for the purpose of distribution.

2. Terms and Definitions

Good Practice
Practices in compliance with legal and regulatory requirements plus those that the industry believes
ensure safety of the consumer and/or the workplace. A Good Practice requirement will be specified
using the word 'shall'.
Best Practice
Recommendations that provide enhancements over and above Good Practice. Best Practice will be
specified using the word 'should'.
Guidance
Descriptive information giving background and/or advice on how to meet Good or Best Practice and
on what to look for to assess compliance with the requirements.
Aerosol
A non-reusable container made of metal, glass or plastic and containing a gas compressed, liquefied
or dissolved under pressure, with or without a liquid, paste or powder, and fitted with a release
device allowing the contents to be ejected as solid or liquid particles in suspension in a gas, as foam,
paste or powder or in a liquid state.
Burst
In relation to an aerosol, burst means total failure of the aerosol.
Contract Warehousing
When a supplier of aerosols contracts a third party to store finished aerosols on their behalf.
Fire Compartment
An area which is separate from the rest of the building by construction of fire resisting (rated) walls,
floors etc. A fire separation is positioned in wall openings or between racks to prevent fires from
spreading.
Fire Separation
A fire separation is positioned in the wall openings or between racks to prevent fire from spreading.
Flammable Gas Propelled Aerosol
An aerosol propelled by a gas that is flammable in air at normal pressure.
MAPP
A documented Major Accident Prevention Policy.
Normal Transport Provisions
Aerosols can be transported as ‘dangerous goods in limited quantities’ if they have been tested to
show they do not leak in the approved way and are in boxes or on stretch-wrapped trays marked
‘UN1950’ and secured on a pallet.

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Risk Assessment
A careful examination of what could cause harm to people, to enable a decision to be made on
whether sufficient precautions have been taken or whether more should be done to further reduce
risk.
Supplier
Filler or marketer of aerosols
Vent
In relation to an aerosol, ‘vent’ means the aerosol container maintains its general integrity although
the contents discharge uncontrollably, but usually directionally as a gas, liquid or as both gas and
liquid phases.
Warehousing
The keeping of aerosol stocks in premises for the purpose of distribution.

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3. General Requirements
Guidance to 3

This Section sets out general requirements for management of the storage of aerosols. The philosophy
behind the requirements is to ensure implementation of policies for the safe storage of finished
aerosols along the supply chain.

3.1 Supplier Warehousing

3.1.1 Suppliers of aerosols shall store aerosols in accordance with the requirements set out in
Sections 4 to 7 of this Guide.
Guidance to 3.1.1

Suppliers of aerosols (i.e. fillers and marketers) who have their own finished products’ warehousing
facilities are required to meet all of the relevant requirements if they wish to claim compliance with
this Guide.

3.2 Contract Warehousing

3.2.1 Suppliers of aerosols who ‘contract-out’ storage of finished aerosols shall audit the
warehousing operation.
Guidance to 3.2.1

Suppliers of aerosols who contract out storage of finished products prior to shipment to the
wholesaler/retailer, should use this Guide to ensure that their contractor stores aerosols safely. This
could be achieved by using the requirements of this Guide as a tool to aid in the auditing of suppliers.

Best Practice

3.2.2 Suppliers of aerosols who ‘contract-out’ storage of finished aerosols should require that
contractors comply with the requirements set out in Sections 4 to 7 of this Guide.

3.3 Wholesaler/Retailer Warehousing

3.3.1 Suppliers of aerosols shall make available written advice to wholesalers and retailers that
recommends storage in compliance with the requirements set out in Sections 4 to 7 of this Guide.
Guidance to 3.3.1

Suppliers cannot be expected to require wholesalers/retailers to comply with the requirements of

Sections 4 to 7 of this Guide. However, they are required to demonstrate that they offered detailed
advice on storage to wholesalers/retailers, even if it was not acted upon, if they wish to claim
compliance with this Guide.

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4. The Regulatory Framework for Storing Aerosols

Guidance to 4

The regulations covering the manufacture and transport of aerosols require that after filling every
aerosol is subjected to an integrity test such as the Hot Water Bath or has been made by a
combination of Quality Assurance systems and micro-leak detections that ensures that leaking
aerosols do not leave the filler. Product safety considerations also require the selection of containers
and components that are compatible with the contents under the expected conditions of storage.
These safeguards mean that undamaged aerosols are unlikely to leak if stored in accordance with the
advice set out in this Guide.

However, pierced or damaged aerosols will release their contents and, if these are flammable, there
will be a risk of ignition. For most aerosols the propellants used are extremely flammable liquefied
petroleum gases that vaporise immediately upon release and which can generate an explosive
atmosphere. Many aerosols also contain flammable solvents such as ethanol or paraffins. Therefore
the majority of aerosols can be ignited by a fire and will contribute fuel and thus a fiercer fire may
result. Aerosols will only start fires if the contents are released and, in fact, most fires involving
aerosols are started in other materials within the warehouse.

Fires involving aerosol stocks can develop very rapidly. Safety of people is therefore of prime
importance. The people to be considered will include not only employees, but also contractors,
visitors and local residents. The protection of those fighting the fire and those off-site who may be
downwind of the plume of smoke should not be overlooked. In general, the fire will spread very
rapidly and involve other stored materials. It is the packaging and pallets that contribute most of the
smoke to a fire. As a result, most of the damage to the buildings and infrastructure comes from the
burning of materials other than aerosols.

As with any closed container, when an aerosol is involved in a fire, the pressure inside the container is
greatly increased. One of the following may occur:

• The aerosol fails, usually at the base or the top, and depending upon the contents and size of the
can, may be projected (rocket) a significant distance in any direction. At the same time, burning
liquid may be thrown laterally or burning gas may rise vertically, thus spreading the fire.
• The aerosol fails by venting off a mixture of gas and liquid. The liquid may pool on the floor and if
flammable and ignited spread the fire to the surrounding area depending upon the size of the
pool.
• The aerosol fails but is a product such as shaving gel that contains only small quantities of
flammable material and hardly contributes to the fire.

There are a number of secondary hazards that could also result in injury to persons or damage to
buildings. Rocketing of burst aerosols may cause impact injuries as well as spreading fire. Reduced
visibility and asphyxiation of personnel due to smoke resulting from burning packing material may
hinder exit from the area. The additional hazards of some product types which may be corrosive,
toxic, irritant or harmful should be considered on an individual basis but will obviously also make
continues…

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Guidance to 4 (continued)

any fire-fighting attempts more complicated. All sites having such products should endeavour to have
all information available to the emergency services at all times. Although the freezing hazard of
liquefied and compressed gases is well known, there are no known reports of freeze-burns as a result
of contact with jetting liquefied or compressed gases in aerosol storage. The same is also the case for
asphyxiation of operatives.

The bursting of aerosols involved in a fire is an intermittent occurrence. However, the burst cans may
have razor sharp edges presenting a severe cut hazard, and all persons should be evacuated from any
area of fire that involves aerosols because of the danger of flying container components. Flying parts
of the aerosols are easily stopped by walls, substantial partitions and nearby stocks of goods or, if
present, caging. In the event of a roof collapse, flying parts may be projected into the air and fall into
the surrounding area. In this situation the emergency services will be able to evaluate the problem and
take any necessary precautions.

The regulations covering the storage of flammable propellants are currently:

• Notification of Installations Handling Hazardous Substances (NIHHS) Regulations 1982

• Planning (Control of Major-Accident Hazards) Regulations 1999
• Dangerous Substances and Explosive Atmospheres (DSEAR) Regulations 2002
• Control of Major Accident Hazards (COMAH) Regulations 1999.
• Control of Major Accident Hazards (Amendment) Regulations 2005

4.1 All Warehouses

4.1.1 Keepers of packed aerosol stock containing more than 25 tonnes of LPG (liquefied petroleum
gas) shall notify their Local Authority.
Guidance to 4.1.1

NIHHS requires businesses to notify their Local Authority if they handle or store hazardous substances
over a threshold quantity. In the case of aerosol warehousing, the most appropriate threshold is 25
tonnes of LPG. Warehouse businesses will need to liaise with their suppliers for the information on
the quantity of LPG in each type of aerosol stored so that they can aggregate the total to calculate an
inventory figure. NIHHS requires only notification of premises; there is no permission requirement
within this legislation

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4.1.2 Keepers of packed aerosol stock containing more than 25 tonnes of LPG (liquefied petroleum
gas) shall obtain Planning Consent from their Local Authority.
Guidance to 4.1.2

The Planning (COMAH) Regulations 1999 came into force on 20 April 1999 as a consequence of the
UK implementation of the Seveso Directive (96/82/EC). These regulations amended the Planning
(Hazardous Substances) Regulations 1992 to remove the exemption for most aerosol warehouses
from the requirement for Planning Consent. Therefore, from that date, businesses that store or handle
aerosols have been required to obtain Planning Consent for operations involving quantities in excess of
defined thresholds of hazardous substances. The Regulations require an application for Planning
Consent to be made to the Local Authority before the threshold quantities are exceeded. The Planning
(COMAH) Regulations were updated in 2005 to implement the amended Seveso Directive
(2003/105/EC).

The relevant hazardous substances are named in Schedule 1 of the Planning (COMAH) Regulations,
which amends Schedule 1 of the Planning (Hazardous Substances) Regulations. For aerosols the key
substance is LPG, for which the controlled quantity is an aggregated total of 25 tonnes. However, it is
important to note that the latest amendment aligns the regulations with COMAH (see 4.2) and other
hazardous substances need to be taken into account when carrying out the aggregation calculation.

It was possible to obtain deemed consent for installations existing before 6 April 1999, but this
possibility expired in October 1999.

4.1.3 All keepers of packed aerosol stock shall conduct a DSEAR risk assessment to identify the risk
of fire or explosion.
Guidance to 4.1.3

DSEAR requires employers to identify any areas where flammable gases and liquids are present in the
work place. If any are present, employers must conduct a risk assessment to identify the risk of fire or
explosion. Employers must then provide ‘general safety measures’ to eliminate or control, as far as
reasonable, the risks to workers from fire or explosion. Measures to prevent an explosive atmosphere
forming could include equipment to control or disperse releases (e.g. ventilation), procedures to deal
with accidents and emergencies, and information and training to employees. If, after implementing
these measures, the risk assessment shows that the quantity or duration of the explosive atmosphere
could cause harm to people then the area is a ‘hazardous place’ and further 'special precautions' are
needed to control potential ignition sources in relation to construction, installation and use of
equipment. The area must then be classified into zones in accordance with the expected frequency
and duration of any explosive atmosphere. Zoned areas must be marked with specified 'EX' signs,
workers will need to be provided with appropriate clothing that does not create an electrostatic
discharge, and only equipment certified as suitable for use in the zone may be used.
continues…

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Guidance to 4.1.3 (continued)

Warehouses storing packaged finished aerosols can generally be considered as non-hazardous

provided the operational safety and control measures described in Sections 5 and 6 of this Guide are
implemented effectively. The small quantity and duration of explosive atmospheres generated by the
accidental release of the contents of an aerosol would not normally present a risk to people. However,
special consideration should be given to additional control measures where aerosols are stored in
confined spaces, where escape would be difficult (e.g. man aloft fork lift trucks).

Annex B provides a framework for warehouse operators to use when carrying out their own risk
assessment of the warehousing of filled aerosol products and suggests the types of measures they
should take.

4.1.4 Aerosol warehouses shall have an emergency plan.

Guidance to 4.1.4

This requirement is formalised for COMAH sites as part of a MAPP (see 4.2.2), but a plan of action in
the event of an emergency is good practice for any facility storing aerosols. Guidance on setting up
and managing a Emergency Plan is given in the BAMA guide –Emergency Planning.

4.1.5 Systems and procedures for the management of risk associated with aerosol storage shall be
subject to a regular programme of monitoring and review.
Guidance to 4.1.5

Minimum suggestions for regular inspections are:

• Daily inspection of fork lift trucks.

• Weekly inspection and test of fire sprinkler pumps and hydrants.
• Standards of housekeeping.
• Condition of pallets, pallet racking and shelving.
• Fire exits, signs and emergency lights
• Fire extinguishers
• Safety equipment (e.g. showers, eyewash bottles, spill control).

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4.2 COMAH (Control of Major Accident Hazards) Warehouses

Guidance to 4.2

The COMAH regulations are the UK implementation of the Seveso Directives (96/94/EC and
2003/105/EC), they place duties on employers to prevent major accidents from happening, and to
limit the consequences to human health and the environment for any that do occur. They are
triggered by the presence of defined dangerous substances 1 in excess of threshold quantities. COMAH
is site specific and sets requirements at two levels - lower and upper tier - depending on the quantity
of dangerous substances handled or stored on the site.

4.2.1 All keepers of packed aerosol stock shall quantify the likely aggregate mass of hazardous
materials present.
Guidance to 4.2.1

The warehouse operator must identify the maximum quantity of each dangerous substance that will be
on the site at any one time either as a substance, in mixtures or in preparations. Schedule 1 of
COMAH sets specific thresholds for over 50 named dangerous substances and general thresholds for
the two tiers for 10 categories of dangerous substance as classified under the CHIP regulations.

If no dangerous substance is present in a quantity equal to or above one of the relevant thresholds,
then the operator must use the prescribed formula to sum together all of the quantities of the various
dangerous substances present. The calculation should be done for all substances (including the
named ones) in three hazard groups:

• Toxic, very toxic or CMR category 1 or 2.

• Oxidising, explosive, flammable, highly flammable, extremely flammable.
• Dangerous for the environment.

For aerosols the principle hazard is the presence of flammable solvents and propellants, however other
hazards need to be considered both on an individual basis and because their presence may make fire-
fighting more complicated.

From the result of the sum it is possible to determine whether the warehouse will be an upper tier
site, a lower tier site or an exempted (sub-COMAH) site. COMAH 2005 amends Schedule 1 by
extending the list of named dangerous substances, revising some of the thresholds and clarifying the
prescribed calculation. Aerosol propellants such as DME, propane and butane are classed as
‘liquefied extremely flammable gases’ and are a named substance in Part 2 of Schedule 1 of COMAH.
Therefore if the propellants are the only source of flammable substances, then the thresholds of 50
tonnes (lower tier) and 200 tonnes (upper tier) apply to the warehouse. An important point to
remember when determining whether an aerosol warehouse is subject to the COMAH regulations is
that often aerosols are not the only goods containing dangerous substances stored in the warehouse.
continues…

1 The situation is slightly confusing because dangerous substances are known as hazardous substances in the planning
10
regulations.

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Guidance to 4.2.1 (continued)

If the amount of propellant is below the COMAH threshold, hazards from other chemicals used in the
product formulation will also need to be considered and the prescribed calculation performed. For
example ethanol, a solvent used in many aerosols, is flammable but has thresholds of 5,000 tonnes
(lower tier) and 50,000 tonnes (upper tier). Information from suppliers (e.g. product safety data
sheets) should be used in order to identify the amount of hazardous materials present in each aerosol.
The warehouse operator can then use this information to calculate the total quantity of hazardous
materials likely to be present on the site at any one time.

The liquefied extremely flammable gas content of aerosols varies from less than 5% to over 95% and
the liquid contents of an aerosol can be up to 750 ml. It is therefore difficult to give precise guidance
on how many pallet loads of aerosols are needed for a warehouse to become a COMAH site.
However, as a rough guide, for an aerosol with contents >50% of liquefied extremely flammable gas,
a warehouse storing 200 pallets of aerosols might be a lower tier COMAH site and 800 pallets might
be a top tier COMAH site. It is therefore essential to obtain reliable information from suppliers (e.g.
product safety data sheets) in order to quantify the dangerous substances present in each aerosol type
stored. It should also be noted that planning consent might be needed for storing about 100 pallets of
aerosols.

4.2.2 Keepers of aerosols shall document, in a MAPP, the policies implemented to comply with
their obligations under COMAH.
Guidance to 4.2.2

For a lower tier COMAH site, the operator is required to:

• Notify the competent authorities that dangerous substances are handled or stored.
• Prepare, document and implement a major accident prevention policy (MAPP).
• Demonstrate to the Competent Authorities that all measures have been implemented.
• Provide Competent Authorities with specified information upon request.

In addition top tier COMAH site operators are required to:

• Prepare, test and review on- and off-site emergency plans.

• Submit, and keep up to date, a safety report covering the major hazards on the site, the
implementation of the MAPP and the emergency plans.
• Send specified information about the operation and safety measures to people in the local area
and also make it available to the general public.

4.2.3 In the case of retail warehouses the supplier shall be responsible for providing information to
enable the warehouse operator to comply with the provisions of requirements 4.2.1 and 4.2.2.

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5. General Safety
Guidance to 5

The regulations covering the manufacture and transport of aerosols require that every aerosol is
subjected to an integrity test. This can be the Hot Water Bath test after filling or, a combination of
Quality Assurance systems and micro-leak detections that ensures that leaking aerosols do not leave
the filler. Product safety considerations also require the selection of containers and components that
are compatible with the contents under the expected conditions of storage. These safeguards mean
that undamaged aerosols are unlikely to leak and cause a fire if stored in accordance with the
requirements set out in this Guide. However, because of their contents, if pierced or damaged,
aerosols will release their contents and, if these are flammable, there will be a risk of ignition.
Because aerosols containing flammable material may produce a fierce fire, care is needed in the
design of warehouses to install measures to prevent and control fire. A detailed discussion of the
design of aerosol warehouses is presented in Annex A of this Guide.

Regulations, such as Management of Health and Safety at Work (MHSW), Control of Substances
Hazardous to Health (COSHH), Control of Major Accident Hazards (COMAH) and the Dangerous
Substances and Explosive Atmospheres (DSEAR), mean that it is important to be able to demonstrate
that all of the hazards that could arise from a warehousing operation have been considered and that
all steps have been taken to ensure that the risk of those hazards occurring is reduced to an
acceptable level. This Guide provides information about the specific hazards of storing aerosols to be
considered when carrying out the risk assessment of the operation as required by DSEAR and suggests
suitable controls that could be used.

The central activity for achieving this is the Risk Assessment. Whilst risk assessments are required for
all work activities, the storage of aerosols introduces special hazards that require specific actions. A
good risk assessment will enable the warehouse to be designed effectively and for controls to address
any risks of storing aerosols to be defined, documented, resourced and communicated to staff. The
documentation of the risk assessment should identify the individual roles, responsibilities and
authorities needed for the implementation of the health and safety management system.

The risk assessment should be reviewed periodically to ensure that it remains valid and the
appropriate risk controls are identified. Systems and procedures for the management of risk
associated with aerosol storage should be subject to a regular programme of monitoring and review.
Relevant additional risk management advice may be obtained from fire insurers, fire safety
professionals, health & safety practitioners, HSE, trade associations and aerosol suppliers. A list of
such publications is included in the Bibliography.

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5.1 Security
5.1.1 The warehouse shall have security (e.g. fencing) that is adequate to guard against intruders
on to the site to prevent the threat of malicious fire raising (i.e. arson).
Guidance to 5.1.1

Fencing should be sufficiently high as to guard against missiles being thrown onto the site. Access to
the site should be via a security checkpoint or some other form of access control. Ideally the site
should have routine security patrols or closed circuit television surveillance operating outside of
operating hours.

5.2 No Smoking Policy

Guidance to 5.2

Smoking in warehouses gives rise to major fire hazards.

5.2.1 Smoking shall be strictly prohibited at all times with

enforcement notices displayed to remind staff and visitors.

Best Practice

5.2.2 Receptacles should be placed at all entrances to the warehouse for the disposal or storage of
smoking materials.

5.2.3 An external smoking area should be designated where staff and visitors may smoke without
creating a fire hazard.

5.3 Fire detection

5.3.1 Measures shall be provided for detecting a fire.
5.3.2 Measures shall be provided for raising an alarm in the event that fire is detected.
Guidance to 5.3.2

The alarm should alert all persons, including disabled or sensory impaired persons, to the danger.

5.3.3 Fire detection and alarm systems shall be subject to a specified regular test and maintenance
programme.

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5.4 Means of Escape

5.4.1 Measures shall be provided for the safe evacuation of all
buildings in the event of fire.
5.4.2 Emergency and fire exit routes shall be clearly signed.
5.4.3 Clear access to, from and along emergency and fire exit routes
shall be maintained at all times.
5.4.4 No emergency door shall be locked in a way which prevents
immediate exit from the hazardous side.
5.4.5 Pedestrian evacuation routes shall be given priority over vehicle routes and storage of
materials and finished goods.
5.5 Fire Fighting
Guidance to 5.5

In-house fire fighting teams should not be encouraged to fight aerosol fires. Instead attention should
be given to protecting exit routes for personnel and providing facilities for the fire brigade to use in the
event of an aerosol fire. However, in order to reduce losses in the event of a fire many insurers require
that equipment and measures be provided for fighting fires in warehouses.

5.5.1 Priority routes shall be maintained through the site for access by the emergency services.
5.5.2 Measures shall be provided for fighting fires.
Guidance to 5.5.2

It is important to install the appropriate type of fire fighting equipment (e.g. sprinklers, extinguishers,
etc.) for the products stored (for more information on fire fighting equipment see Annex A.2).

5.5.3 All fire fighting equipment (including sprinklers, extinguishers, etc.) shall be tested and
maintained according to a specified regular test programme.
Best Practice

5.5.4 A sprinkler system should be installed in the storage area.

5.5.5 Any sprinkler system should be designed in accordance with locally recognised codes of
practice and in conjunction with the local fire prevention officer and building insurers.

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Best Practice

5.5.6 Two independent water sources should be provided which are capable of delivering the
maximum fire water demand for a minimum of about 2 hours.

Guidance to 5.5.6

The water sources should be independent at time of need, therefore a suitably sized storage tank filled
from the mains and the mains supply would be acceptable as long as the storage tank is kept full. An
alternative is to have permission to use an adjacent canal or river as a back-up in case the mains
supply fails.

5.5.7 Water used in the event of a fire shall be retained so that it does not constitute a threat to the
environment.
Guidance to 5.5.7

Care should be taken when designing the warehouse to ensure that water used to control a fire
emergency does not turn into an environmental disaster (see also Annex A.4). This requirement is
particularly important for upper tier COMAH sites (see 4.2) where the regulations specifically require
containment systems to be employed.

5.5.8 Where a trained fire fighting team exists, they shall have equipment, protective clothing and
training to keep themselves safe whilst engaged in an emergency response.
Guidance to 5.5.8

The primary function of a fire fighting team should always be the preservation of life – especially their
own. There should be a procedure in place to ensure that either the fire fighting team is fully manned
at all times or are trained for operating with depleted numbers. In the event of a fire involving
aerosols, in-house fire fighting teams should not fight the fire; instead they should focus on protecting
exit routes for personnel and providing facilities for the fire brigade to use.

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5.6 Contact with the Fire Services

Guidance to 5.6

Emergency plans should be drawn up in consultation with the local community, local authority and
local fire service. For some warehouses this is a legal requirement under COMAH (see Section 4.2).
The plan should also cover press management, contacts with next of kin and business recovery.

The information provided should include:

• Layout of premises e.g. a site map or building plan

• Type, quantity and hazards of material stored
• Location and type of fire fighting equipment
• Whom to contact in an emergency.

This plan needs to be readily accessible at all times and the fire service should be informed of any
significant changes to the building, its contents or its use. This is particularly important if the
warehouse has a fire certificate.

BAMA recommends emergency planning for all warehouses storing aerosols. Further details on
developing an emergency plan for a site handling aerosols see the BAMA guide – Emergency
Planning..

5.6.1 In the event of fire, procedures for contacting the local fire service shall be implemented
immediately.
5.6.2 All the information necessary to react to an emergency situation shall be provided to the fire
service.
5.6.3 The fire service shall be notified of any significant change to the building, its contents or its
use.
Guidance to 5.6.3

This is particularly important if the warehouse is covered by the Planning Consent Regulations (see
4.1.2).

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6. Control of Hazards in the Storage Area

Guidance to 6

As described previously (Guidance to 5), controls in the manufacturing process reduce the risk of
aerosols spontaneously bursting in storage. However, since the majority of aerosols contain extremely
flammable gas propellants and flammable liquids (some of which may not be miscible with water).
DSEAR requires that a risk assessment is carried out to identify measures that must be implemented
to minimise the risk of fire or explosion.

The primary basis of safety in the warehouse should be prevention to avoid the development of a
flammable atmosphere. Precautions should be taken by screening pallets on entry into the warehouse
to ensure that aerosols are not leaking. This could be achieved using portable gas detectors whilst the
pallets are confined in a transit vehicle en-route to the warehouse.

The secondary basis for safety is ensuring the storage area is sufficiently well-ventilated to prevent a
flammable atmosphere developing if there is seepage over time. This is relatively easy to achieve in
large well-ventilated warehouses but not in small confined areas where forced ventilation will be
required to reduce the potential for the build-up of vapours.

General good ventilation can deal with seepage, but not incidents such as burst aerosols. In such
cases the tertiary basis for safety is the elimination of ignition sources. Sensible precautions should
therefore be taken for situations where a risk assessment identifies that such incidents could occur.

6.1 Design of Storage Area

Guidance to 6.1

Consideration should be given to whether it is necessary to separate flammable products from other
hazardous products such as oxidising agents. A detailed discussion of the design of aerosol
warehouses is given in Annex A.

6.1.1 Aerosols shall be stored in dry, well-ventilated

warehouses and not in basements.

6.1.2 Localised heating of aerosols shall be avoided.

Guidance to 6.1.2

Aerosols should not be stored in direct sunlight or in localised hot spots, (as in a window, for
example), near heaters, hot air vents or hot pipes.

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6.1.3 Racking shall be safe, stable, secure and designed to avoid accidental actuation of aerosols.
Guidance to 6.1.3

Consideration should be given to the racking including support bars to prevent pallets from 'spilling'.
Accidental actuation can occur if aerosols are stacked so that pressure is applied to the top of aerosol
resulting in activation of the valve.

Best Practice

6.1.4 If the warehouse is a large open plan building, the aerosol storage area should have wire mesh
caging as a means to control rocketing aerosols from spreading the fire to stock in other parts of the
warehouse.

Guidance to 6.1.4

Manual fire fighting for loss prevention purposes is made almost impossible if caging is not fitted, as
the physical threat to fire fighters can be an unacceptable risk. Design advice for caging is given in
Annex A.1.3.

6.1.5 Connecting doors in fire compartment walls shall be of a self-closing type held open with a
fusible link or other ‘fail safe’ device which can operate in the absence of external power supplies and
have a minimum fire resistance of 2 hours.
6.2 Ventilation
Guidance to 6.2

As described in the Guidance to 5 controls in the manufacturing process will eliminate the risk of
aerosols that are leaking or likely to spontaneously burst whilst in storage. However there is the
possibility of slow seepage over time, and to prevent an explosive atmosphere developing, it is
important to ensure that the storage area is sufficiently well-ventilated.

6.2.1 The ventilation in the warehouse shall be sufficient to prevent any build up of flammable gas
due to slow seepage from stored aerosols.
Guidance to 6.2.1

This is relatively easy to achieve in large open warehouses with normal stock movements, however, in
small confined areas, forced ventilation may be required to reduce the potential for the build-up of
vapours.

Best Practice

6.2.2 If mechanical ventilation is used, e.g. long-term storage in enclosed premises, then devices
warning of fan failure should be installed.

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6.3 Sources of Ignition

Guidance to 6.

Although the manufacturing process will eliminate the risk of aerosols bursting in storage, it cannot
prevent incidents occurring during handling that damage the aerosols causing them to leak. In such
cases, the basis for safety is the elimination of ignition sources. Sensible precautions should therefore
be taken for situations where a risk assessment identifies that such incidents could occur. In a
warehouse, the main causes of such aerosol failures are:

• Puncture by truck forks or sharp objects.

• Being run over when loose on the floor.
• Falling from a height, e.g. high racking.
• Bursting as a result of heating.

The risk of aerosols being punctured and releasing

flammable gases and/or vapours is greatest when manipulating packs outside their transport unit, i.e.
a fully wrapped pallet. DSEAR (see 4.1.3) requires that if accidental release of significant quantities
of a flammable gas/vapour is likely, procedures should be implemented or equipment installed that
will eliminate the risk of ignition.

6.3.1 All potential sources of ignition shall be eliminated or strictly controlled.

Guidance to 6.3.1

Sources of ignition include, but are not restricted to:

• Hot surfaces or radiant heat.

• Smoking materials (e.g. cigarettes, matches, lighters, etc.).
• Sources of static electricity (e.g. flooring, clothes, mobile phones, etc.)
• Faulty electrical installations.
• Hot works, e.g. open flame cutting or welding.
• Faulty mechanical handling equipment.
• Friction caused by careless handling

Engineering work should be assessed for ignition risk, appropriate controls include written permits to
work, limiting the extent of authorised work in scope, time and location, and specifying precautions to
be observed by engineers and contractors and communicated to warehouse staff. Aerosols should be
temporarily relocated or covered with fire-resistant material. Work on fire protection systems such as
fire alarms and sprinklers, etc. should be notified to the insurers prior to commencement.

6.3.2 Electrical socket outlets and switches should be installed above 1m from the floor.
Guidance to 6.3.2

This is to prevent accidental damage by mechanical handling devices (e.g. fork lift trucks).

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6.4 Aerosol Storage Protocol

6.4.1 Aerosols shall be stacked in racks or block stacked.
Guidance to 6.4.1

Pallets and packs of aerosols should not be stored in aisles even on a temporary basis.

6.4.2 Pallets of stacked aerosols shall not be interleaved.

Guidance to 6.4.2

Interleaving of pallets in warehouses can result in collapse of the stack if a pallet is inadvertently
moved from the storage in the wrong order. However it should be noted that interleaving collations on
a pallet is recommended for maximum stability of the pallet.

6.4.3 The maximum height of block stacks of aerosols shall be 3 m.

Guidance to 6.4.3

Exceeding the maximum safe top-loading value for the bottom pallet in a stack may lead to collapse,
distortion and/or accidental actuation of aerosols and a release of large quantities of flammable
material.

The maximum stack height for storage purposes should

always be calculated for each and every product and product
variable. Parameters to take into account include cap
strength and the type of packaging material used. For
contract warehouse operations the supplier should provide
advice on the maximum stack height for each product type.

The overall stacking height should also take account of the height, positioning and operation of the
sprinkler system.

6.4.4 Block stacks of aerosols should not exceed 3 m in width and 10 m in length.
6.4.5 There shall be a minimum separation distance of 2 m between areas of block stacked
aerosols.
Guidance to 6.4.5

This distance is the recommended minimum and insurance companies may require greater distances.

6.4.6 Empty pallets and other combustible materials

shall be stored in an area separate from aerosols or other
flammable products, preferably in another building.

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6.5 Goods In
Guidance to 6.5

It is recommended that where the warehouse operator receives deliveries or collections from foreign
drivers, signs and notices that depict hazardous operations or control of risks should be multi-lingual
and meet the current Health and Safety (Safety Signs and Signals) Regulations and the EC Directive
on Safety Signs (92/58/EEC). To prevent breakdown in communications, key staff, including security,
should hold certain documents that are written in the languages of the nationals employed. Examples
include: No Smoking, No Naked Lights, Switch off Engine, Reversing not allowed, Emergency
Procedures, etc.

6.5.1 Aerosols shall be examined for damage upon receipt.

Guidance to 6.5.1

Since the majority of aerosols contain extremely flammable gas

propellants and flammable liquids (some of which may not be
miscible with water), pallet loads should be visually inspected
on entry into the warehouse to ensure that aerosols are not
damaged. Signs to look for include cloudy wrapping, wet
packs or strong smells of perfume.

Best Practice

6.5.2 Portable gas detectors should be used to inspect the aerosols on arrival at the warehouse
whilst the pallets are confined in the transport vehicle.

6.5.3 Leaking or suspected leaking aerosols shall be dealt with according to the requirements of the
Section 7.
Best Practice

6.5.4 Records of unsatisfactory deliveries should be made and the matter reported to the supplier for
investigation.

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6.6 Internal Transport

6.6.1 Aerosols shall be stretch-wrapped securely onto pallets to minimise handling and to avoid falls
of loose containers.
Guidance to 6.6.1

If stretch-wrapping is being undertaken within the

aerosol warehouse, the machines should be firmly
secured and maintained. Particular attention should
be taken to ensure that all static electricity is
eliminated and that control integrity is maintained
and regularly checked.

6.6.2 The supplier shall be consulted about appropriate methods for distribution and suitable
packaging for onward delivery into the supply chain.
Guidance to 6.6.2

Where pallets of aerosols are broken down at the warehouse into packages for onward delivery into
the supply chain, the supplier should be consulted about the gauge of shrink-wrap and quality of trays
used, and the protection of spray through caps from accidental actuation. Where pallet loads of
aerosols are fully encapsulated in plastic stretch-wrap, it is possible that any propellant released if
aerosols are damaged or accidentally actuated during transport could be trapped within the pallet
load.

6.6.3 Before any pallet is broken down it shall be inspected for signs of damaged aerosols as
described in 6.5.
6.6.4 The appropriate forklift and powered pallet trucks for use in the storage area shall be
determined by the DSEAR risk assessment (4.1.3).
Guidance to 6.6.4

Fork tips should be rounded rather than sharp to minimise piercing of aerosols and clad in stainless
steel to reduce the risk of sparks caused by friction between rust on the forks and aluminium can
(thermite reaction).

6.6.5 Fork lift and pallet truck drivers shall be licensed to operate their trucks.
6.6.6 Staff using mechanical handling devices shall be trained to avoid damaging aerosols.
Guidance to 6.6.6

In particular, care should be exercised when locating forks in pallets. It is advisable that trucks should
only carry one pallet at a time.

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6.6.7 Pallet conveyors (roller beds) used to transport pallets of aerosols shall have devices to
prevent misaligned pallets falling off the rollers.
Guidance to 6.6.7

These may be in the form of raised flanges at the edges of rollers, or detection devices such as trip
wires or beams to photoelectric cells (magic eyes). All automatic pallet handling machines should be
risk assessed for possible causes of pack/aerosol damage.

6.6.8 Battery chargers used for forklift and pallet trucks shall be located and used in an area ruled
safe by the DEASR risk assessment (4.1.3).
Guidance to 6.6.8

Battery-operated truck charging can give rise to incendiary sparks and hydrogen. Therefore truck
charging points should be in an area remote from the aerosol storage area and assessed as safe.

Best Practice

6.6.9 Battery charging should occur in a separate building or in compartmentalised areas that are
contained by 2-hour fire rated walls and doors activated by smoke detectors.

6.7 Housekeeping
6.7.1 Good standards of housekeeping shall be maintained at all times.
Guidance to 6.7.1

Minimum suggestions for regular inspections are:

• Daily inspection of fork lift trucks.

• Weekly inspection and test of fire sprinkler pumps and hydrants.
• Standards of housekeeping.
• Condition of pallets, pallet racking and shelving.
• Fire exits, signs and emergency lights.
• Fire extinguishers.
• Safety equipment (e.g. showers, eyewash bottles, spill control).

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6.7.2 All staff involved in the movement and storage of aerosols shall be trained about aerosol
hazards.
Guidance to 6.7.2

All relevant staff including temporary staff should be trained in the correct handling techniques,
emergency procedures and procedures for dealing with damaged or leaking stock. Engineering staff
should also be instructed in the correct maintenance procedures and written permit systems.
Contractors should be informed of the person with accountability for their safety.

6.7.3 Any aerosols loose on the floor shall be picked up immediately.

Guidance to 6.7.3

Any aerosols loose on the floor should be collected, inspected and if not
damaged re-secured in storage. Damaged or leaking aerosols should be
removed immediately to a safe, secure, well-ventilated place (preferably
outdoors) for disposal as described in Section 7.

6.7.4 Empty pallets shall be stored in an area separate from the aerosols.
6.7.5 Combustible waste shall be removed without undue delay.
Best Practice

6.7.6 If long-term storage is necessary, especially for slow moving lines, stock should be inspected
regularly for deterioration or leakage.

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7. Disposal of Aerosols
Guidance to 7

This Section provides some Requirements for the disposal of aerosols from warehouses; The BAMA
Guide to the Disposal of Full and Part Full Aerosols should be consulted for more details on the
disposal methods. BAMA recommends that suppliers provide a written procedure for the safe
handling and disposal of aerosols from warehouse.

Damaged or leaking aerosols should be removed immediately to a safe

secure well-ventilated place (in the open air preferably). In all cases, it will
be necessary for a risk assessment of the nature of the hazard (i.e.
flammable, toxic, harmful, corrosive, Dangerous to the Environment, etc.)
and the quantity of aerosols involved to be performed by a competent
person.

It is important to remember that under the ‘duty of care’ imposed by the

waste regulations, the company producing the waste has the responsibility to check that any company
or haulage contractor used to dispose of the waste has the appropriate waste handling licences. It is
recommended that aerosol suppliers provide warehouse operators with a list of waste management
companies that will dispose of full or part-full aerosols.

7.1 Leaking Aerosols

7.1.1 All leaking aerosols shall be placed in a well-ventilated area until all leakage has ceased and
then disposed of appropriately.
Guidance to 7.1.1

For single leaking aerosols, one way of ascertaining that leakage has ceased is to measure the weight
of the aerosol; if there is no change after 24 hours, then it is safe to assume that the aerosol has
stopped leaking. Another possible method (depending upon the contents of the aerosol) is to immerse
the aerosol in cold water and look for bubbles (wear rubber gloves).
If the aerosol still contains product after leakage has ceased it should be disposed
of through a licensed waste management company.
If the aerosol is completely empty then the container should be sent for recycling.
If the manufacturer/marketer wants to retrieve the empty aerosol for further
investigation, then a suitable company representative who can carry out a risk
assessment to establish the best means of carrying the aerosol will collect it.

If it is not possible to deal with the leaking aerosol on site, then measures need to be taken to ensure
that any risk associated with transporting leaking aerosols is controlled prior to carriage

continues…

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Guidance to 7.1.1 (continued)

If aerosols within a pallet are found to be leaking then the following guidance should be followed:

• If the aerosols were damaged by a fork lift truck, the truck could be a source of ignition. The
driver should immediately leave the truck for a safe place, assess
the situation and act accordingly, if necessary activating an alarm.
• If it is safe to leave the pallet where it is, suspend normal working
for a distance at floor level of 5 metres either side of the pallet.
Using a portable gas detector frequently check the atmosphere
around the pallet until the atmosphere is safe (i.e. the propellant
gas concentration is less than 5% of the lower explosive limit).
Move the pallet to a well-ventilated area for further inspection and
appropriate disposal in appropriately.
• If it is not safe to leave the pallet where it is, then it must be moved to a well-ventilated area. It is
important to move the pallet using a mechanical handling device that is not a potential source of
ignition, for example, a non-powered hand pallet truck or hazard certified forklift truck. The route
taken to remove the pallet must be checked to ensure that the leaking pallet will not pass any
potential sources of ignition.
• If it is not possible to deal with the leaking aerosols on site, then they should be disposed of via a
Waste Management Company licensed to accept Hazardous Waste.

7.2 Damaged – Not Leaking

7.2.1 Aerosols that are damaged but are not leaking shall be assessed for appropriate disposal.
Guidance to 7.2.1

Aerosols that have suffered minor damage and are not leaking could be repacked and
sent back to the aerosol filler as ‘stock returned for examination’ under the normal
transport provisions. Alternatively, they could be disposed of as hazardous waste.
Waste aerosols should only be returned to suppliers who hold an appropriate waste
handling licence.

7.3 Product Recall

7.3.1 Procedures shall be in place to deal with aerosols subjected to a product recall, product
withdrawal or returned as out of date stock from the retailer.
Guidance to 7.3.1

If aerosols are subjected to a product recall, product withdrawal or

returned as out of date stock from the retailer, the warehouse is likely
to be involved in some way. BAMA recommends that, as part of the
business contract between the companies, suppliers of aerosols agree
written procedures with the warehouse for the packaging and return of
aerosols for ‘examination’ or for disposal as waste aerosols . Further
advice is given in the BAMA Guide –Product Recalls and Consumer
returns.

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Bibliography
Chemical Agents Directive - CAD (98/24/EC)
Explosive Atmospheres Directive - ATEX 95 (94/9/EC)
Explosive Atmospheres Directive - ATEX 137 (99/92/EC)
Control of Major-accident Hazards Directive -Seveso II (96/82/EC)
Control of Major-accident Hazards Directive -Seveso III (2003/105/EC
Safety Signs Directive (92/58/EEC)

Environmental Protection Act 1990

Environment Act 1995
Fire Precautions Act 1971
Health and Safety at Work (HSWA) Act 1974
Town and Country Planning Act 1990

Carriage of Dangerous Goods and Use of Transportable Pressure Receptacles Regulations 2007
(SI 2007 No 1573)
Control of Major Accident Hazards Regulations 1999 (SI 1999 No 743)
Control of Major Accident Hazards (Amendment) Regulations 2005 (SI 2005 No 1088)
Control of Substances Hazardous to Health (COSHH) Regulations 2002 (SI 2002 No 2677)
Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) (SI 2002 No. 2776)
Hazardous Waste (England) Regulations 2005 (SI 2005 No.814)
Management of Health & Safety at Work Regulations 1999 (SI 1999 No 3242)
Notification of Installations Handling Hazardous Substances Regulations 1982 (SI 1982 No. 1357)
Planning (Control of Major-Accident Hazards) Regulations 1999 (SI 1999 No981)
Planning (Hazardous Substances) Regulation 1992 (SI 1992 No 656)
Regulatory Reform (Fire Safety) Order 2005 (SI 2005 No 1541)
The Health and Safety (Safety Signs and Signals) Regulations 1996 (SI 1996 No. 341)
National Fire Protection Association Code (NFPA) 30B
Factory Mutual Global Operating Standards 7-31: Storage of Aerosols

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The following are available from The Fire Protection Association, London Road, Morton in Marsh,
Glos., GL56 0RH – www.thefpa.co.uk
Recommendations for Fire Safety in Warehouses. RC18 LPC 1999
Recommendations for the Storage of Aerosol Products. RC19: FPA 2004
LPC Rules for Automatic Sprinkler Installations: Technical Bulletin 216:2003: Sprinkler Protection of
Aerosols

The following relevant publications are available from BAMA:

BAMA Guide: The Disposal of Full or Part Full Aerosols
BAMA Guide to Retail Storage and Display of Aerosols
BAMA Product Recall Guide
The BAMA Standard for Consumer Safety and Good Manufacturing Practice

The following publications are available from HSE Books, PO Box 1999, Sudbury, Suffolk, CO10
2WA, tel: 01787 881165 or from www.hsebooks.com/Books :
HS(G) 65 Successful Health and Safety Management (Revised 1997)
HS(G) 71 Chemical Warehousing – The Storage of Packaged Dangerous Goods (Revised 2008)
L134 Design of plant, equipment and workplaces ISBN 0 7176 2199 5
L135 Storage of Dangerous Substances ISBN 0 7176 2200 2
L136 Control and mitigation measures ISBN 0 7176 2201 0
L137 Safe maintenance, repair and cleaning procedures ISBN 0 7176 2202 9
L138 Dangerous Substance and Explosive Atmospheres Approved Code of Practice and Guidance
ISBN 7 7176 2203 7
Fire and Explosion – how safe is your workplace? INDG 370. Single copies are free.

The European Commission has a guidance document for implementing ATEX 137. The reference
number is COM (2003) 515 final. It can be obtained from the Europa web site at:
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2003:0515:FIN:EN:PDF.

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Annex A
Design Considerations for Aerosol Storage
This Annex aims to give the principles on which warehouses containing aerosols should be designed.
It does not aim to be prescriptive but to give general points to consider.
A.1 Protection of Stock
In practice, the protection of stock in a warehouse will involve a combination of the methods
described. The protection measures should take account of all the hazards, not just those relating to
aerosols which are present on the site.
A.1.1 Segregation
This is where a clear space in all directions segregates aerosols from other products and packaging,
empty pallets, etc. by a clear space in all directions. The distance from the other products will
depend on the nature of those products. For example, the storage of flammable aerosols near
oxidising substances is particularly hazardous and adequate separation needs to be provided. The
factors that need to be considered are:

• Radiant heating - Burning empty pallets will produce intense heat, which will cause exposed
aerosols to burst.
• Flammable liquids - will flow taking the fire with them. The segregation distance will depend on
the number and quantity of flammable liquids stored.
• Fragile products - Those products that could be damaged by rocketing or bursting aerosols
should be relocated so that they are not in the direct line of sight of stored aerosols.
A.1.2 Fire Separation and Compartmentation
Fire walls and separations have a specific fire rating, e.g. 2 or 4 hours. The rating used will depend
on how easy and how quick it would be to extinguish a fire. It is important to ensure that fire doors
and shutters used are the same rating as the rest of the wall because the structure will fail at its
weakest point. Prolonged exposure to rocketing aerosols may cause fire shutters to become distorted
and damaged leading to early failure. The size of any compartment will depend on the value of the
compartment's contents and its rebuild cost. Most insurance companies have a limit on this
combined value.
A.1.3 Wire Mesh (Caging)
Where aerosols cannot be segregated from other stock, wire mesh caging is recommended around
aerosol storage, so far as is practical, to limit rocketing aerosols in a fire. Open mesh caging should
be used, as it will allow water to be directed through the mesh at the fire. Manual fire fighting for
loss prevention purposes is made almost impossible if caging is not fitted, as the physical threat to
fire fighters can be an unacceptable risk. The wire used should be at least 2 mm thick and the mesh
size should not exceed 25 mm by 25 mm. Small numbers of aerosols could be stored in meshed
bins of similar construction. When designing mesh cages all sides should be covered, so far as is
practical with doors that are kept shut when the storage area is not being accessed. Consideration
should also be given to installing devices to shut the cage doors automatically in case of a fire
anywhere in the warehouse. Fire barriers within racks will also help to prevent rocketing aerosols.

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A.2 Methods for Controlling Fire

A2.1 Hose Pipes
Provision should be made to provide adequate fire water for the local fire brigade or in-house fire
fighting team (if one exists). Water for fire fighting should be supplied by two independent water
sources and should be capable of delivering the maximum water needed to fight the ‘worse-case’ fire
determined by a risk assessment for a minimum of about 2 hours. It is recommended that water is
supplied by either a hydrant, ideally forming part of a ring main system, or by a static or natural
water supply capable of delivering as a minimum 67,500 litres. Hydrant outlets should be situated
no more than 70 m and no less than 6 m from the site of the risk; they should be outside the
warehousing and adjacent to roadways or hard standing for fire appliances.
The water sources should be independent at time of need, therefore a suitably sized storage tank
filled from the mains and the mains supply would be acceptable as long as the storage tank is kept
full. An alternative is to have permission to use an adjacent canal or river as a back-up in case the
mains supply fails.
Installed hose reels are not recommended because of difficulties with ensuring the correct water
pressure and potential health problems; cases have also been reported of the Legionella bacteria
being found in the water in the hose.
A.2.2 Sprinklers
Sprinklers are best suited for fire suppression rather than fire fighting. If sprinklers are to be used,
their design will depend on the following questions:

• Does the aerosol tend to burst or vent in a fire situation?

• Is the product miscible with water?
• How is the aerosol packaged - cartons or shrink-wrap?
• What types of pallets are used - wooden or plastic?
• Rack or palletised (block stack) storage?
• What are the structures inside the racks - are there solid shelves or fire barriers?
Sprinklers fall into two broad categories; ceiling sprinklers and in-rack sprinklers. Each of these can
be subdivided into different types, in brief:

• Ceiling Sprinklers fall into many categories; different orifice of sprinkler head, early suppression
fast response (ESFR); large drop sprinklers and fast response. All of these types give different
water spray patterns and coverage areas (per sprinkler head).
• In-Rack Sprinklers have various arrangements of the sprinkler heads; in the flue space, on the
face of the pallets, distance between heads and whether sprinklers will be positioned on every
tier or not.
All sprinklers can be fitted with heads that operate at different temperatures, e.g. 65°C and 140°C or
above. Specialist advice can be obtained from the Association of British Insurers, the Fire Protection
Association, NFPA 30B or insurance companies.
Water supplies are critical to sprinklers working and need to be separate to water supplied for fire
fighting. The water demand for different sprinklers varies widely, as does the pressure required at
the sprinkler head. Another determining factor will be the design area and number of sprinklers
assumed to be involved in the fire. In most cases, town mains water will not have enough pressure
to supply sprinklers which means that fire pumps and other water sources will be required and
consideration needs to be given to how the supply will be ensured for the duration of an incident.
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A.3 Smoke Vents

Smoke venting systems help prevent smoke build up and can be installed in warehouses for both life
and property protection purposes. The local fire brigade sometimes requires them. However, for
sprinkler protected warehouses, smoke vents can interfere with the operation of the sprinklers and so
it is important to get expert advice if both systems are present.
A.4 Environmental Issues
Water used to fight or suppress a fire should be retained so that it does not constitute a threat to the
environment. Care should be taken when designing the warehouse to consider the use of bunds and
interceptor drains to ensure that water used to control a fire emergency does not in turn create an
environmental problem. This is particularly important for upper tier COMAH sites where the
regulations specifically require containment systems to be employed.
Sites storing aerosols containing ingredients which could significantly damage the environment
should consider total firewater retention. For example substances which are labelled: R50 - ‘Very
toxic to aquatic organisms’; R51 - ‘Toxic to aquatic organisms’; R53 - ‘May cause long term adverse
effects in the aquatic environment; R58 - ‘May cause long term adverse effects in the environment’.
Warehouse operators should note it is not only substances in their pure form which will give concern
but also the products which are formed when the pure substance is subjected to fire.

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Annex B
Framework Risk Assessment for the Warehousing of Aerosols

RISK ASSESSMENT CONTROL MEASURES

Step Hazard or Problem Cause of Hazard Consequences of No Action General Safety Measures Additional Notes

RECEIPT OF DELIVERY

1 Unloading Leaking aerosols in the Aerosols damaged in Accumulation of flammable Staff training. Check the load, Quality controls at
product from truck. transit. gases/vapours in truck. do not offload if any damage or dispatch and in
delivery vehicle. product leakage evident. manufacturing will
Procedures to dispose of prevent leaking
damaged or leaking aerosols. aerosols being loaded
into the truck by the
consignor.

2 Unloading Aerosols punctured by Poor driving of FLT Temporary cloud of flammable Driver trained to recognise Friction between
product from Fork Lift Truck (FLT) or difficult operating gas/vapour around damaged aerosols. hazard and drive carefully. aluminium and other
delivery vehicle. forks. conditions, e.g. Ensure suitable material for metals may generate
sloping dock forks if aluminium aerosols localised high
levellers, badly transported, to prevent temperatures
stacked pallets, or thermite reaction. sufficient to ignite
movement during aerosol contents.
transport.

3 Unloading Crushing of loose Damage to pallets Aerosols run over and crushed by FLT Driver trained to recognise Consignors must
product from aerosols on floor of during transit. resulting the release of flammable hazard and to pick up any ensure that the
delivery vehicle. truck. gas/vapour. loose aerosols. product transport
packs are robust.

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RISK ASSESSMENT CONTROL MEASURES

Step Hazard or Problem Cause of Hazard Consequences of No Action General Safety Measures Additional Notes
4 Unloading Aerosols fall off the pallet Movement of Aerosols fall to the floor and are Driver trained to recognise
product from whilst it is being moved. insufficiently secured damaged either by impact with hazard. Check pallet, pick up
delivery load. floor or by pallet disintegrating and loose aerosol and, if necessary,
vehicle. loose aerosols being run over by re-secure aerosols on the pallet
vehicles. Both cases resulting in before moving it.
the release of flammable
gas/vapour.

5 Check for Leaking aerosols. Faulty stock delivered. Accumulation of flammable Staff training. Check the stock Quality controls at
damaged gas/vapour. for evidence of any damage or dispatch and in
stock. product leakage evident. manufacturing will
Procedures to dispose of prevent leaking
damaged or leaking aerosols. aerosols being sent
by the consignor.

STORAGE
6 Putting pallet Aerosols fall off pallet Jerky movement of Aerosols on the floor being run Driver trained to recognise
away in block whilst it is being moved. insufficiently secured over and crushed by vehicles hazard. Check pallet, pick up
stack. load. resulting in the release of loose aerosol and if necessary
flammable gas/vapour. re-secure aerosols on the pallet
before moving it.

7 Putting pallet Collapse of stack. Stacking too high. Aerosols fall to the floor and are Limit to single stacking unless
away in block Unstable stacking. damaged either by impact with specified by supplier.
stack. the floor or by pallet disintegrating
and loose aerosols being run over
by vehicles. Both cases resulting
in the release of flammable
gas/vapour.

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 Warehousing

RISK ASSESSMENT CONTROL MEASURES

Step Hazard or Problem Cause of Hazard Consequences of No Action General Safety Measures Additional Notes
8 Putting pallet Collapse of rack beam. Racking insecure. Aerosols fall to the floor and are Maintenance of safe racking.
away in damaged either by impact with the
racking. floor or by pallet disintegrating and
loose aerosols being run over by
vehicles. Both cases resulting in
the release of flammable
gas/vapour.

9 Putting pallet Collapse of pallet. Pallet not placed Aerosols fall to the floor and are Safe system of racking. FLT
away in securely in racking. damaged either by impact with the driver training and licensing
racking. floor or by pallet disintegrating and and eyesight checks for
loose aerosols being run over by drivers.
vehicles. Both cases resulting in
the release of flammable
gas/vapour.

10 Storage in Collapse of stack. Stacking too high. Aerosols fall to the floor and are Limit to single stacking unless
block stack. Collapse of aerosol damaged either by impact with the specified by supplier.
package. floor or by pallet disintegrating and
loose aerosols being run over by
vehicles. Both cases resulting in
the release of flammable
gas/vapour.

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 Warehousing

RISK ASSESSMENT CONTROL MEASURES

Step Hazard or Problem Cause of Hazard Consequences of No Action General Safety Measures Additional Notes
11 Storage. Leaking Aerosols. Faulty stock delivered. Accumulation of flammable Good natural ventilation, no Manufacturers test all
gas/vapour. basements. Mechanical aerosols for leakage
ventilation if required. before dispatch. Air
changes provided for
operator comfort will
be adequate to
dissipate gas from
slowly leaking
aerosols.

12 Storage. Leaking Aerosols. Internal corrosion. Accumulation of flammable Staff trained to recognise
gas/vapour. signs of can corrosion hazard.
Housekeeping checks.
Regular checks and disposal
of products at or beyond shelf
life.
Manufacturers design
and manufacture
products to a
specified shelf life.

13 Storage. Leaking Aerosols. Accidental actuation due Accumulation of flammable Limit to single stacking unless Design and
to weight of pallets gas/vapour. specified by supplier. manufacturing quality
above. controls ensure that
aerosols are safely
stacked.

14 Storage. Leaking Aerosols. Aerosols damaged by Accumulation of flammable Safe system of handling. FLT
handling equipment. gas/vapour. driver training and eyesight
checks for drivers.

15 Storage. Leaking Aerosols. Aerosols bursting due to Accumulation of flammable Store aerosols away from
exposure to temperatures gas/vapour. heaters and direct sunlight.
>55°C.

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 Warehousing

RISK ASSESSMENT CONTROL MEASURES

Step Hazard or Problem Cause of Hazard Consequences of No Action General Safety Measures Additional Notes

RETRIEVAL
16 Removal from Aerosols punctured by Inaccurate placing of Temporary cloud of flammable Driver trained to recognise Friction between
storage Fork Lift Truck forks. forks stabbing aerosols. gas/vapour around damaged hazard. Ensure suitable aluminium and other
location. aerosols. material for forks if aluminium metals may generate
cans transported, to prevent localised high
thermite reaction. temperatures
sufficient to ignite
aerosol contents.

17 Removal from Pallet dropped. Pallet not picked up Pallet disintegrates and loose Safe system of racking. FLT
racking. properly. aerosols are run over by vehicles or driver training and eyesight
aerosols are damaged by impact checks for drivers.
with floor, etc. Both cases
resulting in the release of
flammable gas/vapour.

18 Order Picking. Loose aerosols on floor. Pack dropped. Aerosols on the floor being run over
and crushed by vehicles resulting in
the release of flammable
gas/vapour.
Picker trained to recognise
hazard. Pick up loose aerosols
immediately. Behaviour
reinforced by housekeeping
checks.
Aerosols in closed
transit packs should
not easily escape and
roll across the floor.

19 Palletisation Leaking Aerosols. Aerosols damaged by Accumulation of flammable Maintenance of equipment.

of picked faulty handling gas/vapour. Training of operators.
loads. equipment.

20 Palletisation Loose aerosols on floor. Packs damaged by faulty Aerosols on the floor being run over Picker trained to recognise
of picked handling equipment and and crushed by vehicles resulting in hazard. Pick up loose aerosols
loads. aerosols fall to the floor. the release of flammable immediately. Behaviour
gas/vapour. reinforced by housekeeping
checks.

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 Warehousing

RISK ASSESSMENT CONTROL MEASURES

Step Hazard or Problem Cause of Hazard Consequences of No Action General Safety Measures Additional Notes
21 Loading of Aerosols fall off pallet Jerky movement of Aerosols on the floor being run over Driver trained to recognise
transport whilst it is being moved. insufficiently secured and crushed by vehicles resulting in hazard and pick up loose
vehicle. load. the release of flammable cans. Load securely
gas/vapour. palletised.

22 Returned or Leaking Aerosols. Faulty aerosols in Accumulation of flammable Staff training. Check the load, Inform customers
faulty stock. returned stock. gas/vapour. not off-load if any damage or they must not return
product leakage evident. leaking aerosols.
Procedures to dispose of
damaged or leaking aerosols.

DESIGN AND MANAGEMENT OF WAREHOUSE

23 Storage. Deliberate fire. Arson. Personal Injury or Property Security of the site. Alarm
Damage. system linked to emergency
services.

24 Storage. Fuel available to fire. Storage of empty pallets Spread of fire to aerosols. Store empty pallets and
and packaging. packaging away from other
goods.

25 Battery Generation of Hydrogen Battery charging. Source of Ignition. Battery charging to be kept
charging. and Oxygen. away from storage or done in
a well ventilated area.

26 Storage. Movement of fire between Openings in building. Spread of fire. Openings fitted with self
building compartments. closing fire doors.

27 Storage. Uncontrolled spread. Fire. Loss of complete facility and stock. Alarm system linked to
emergency services. Tested
regularly.

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RISK ASSESSMENT CONTROL MEASURES

Step Hazard or Problem Cause of Hazard Consequences of No Action General Safety Measures Additional Notes
28 Storage. People in the vicinity of Fire. Injury of people. Identified Fire Exits,
fire. Evacuation Plan, Practise
Evacuations.

29 Storage. Uncontrolled growth of Management, people Major disaster. Have an agreed Emergency
incident and subsequent and local services Plan and ensure
impact on business, unprepared for incident. management, staff and local
people and neighbours. services understand their part.
Carry out fire risk assessment.

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