Hello

How to interpret bulk storage as per regulations:

 SECTION 4.8

The storage of chemicals in bulk

Part B

(a) The storage in tanks, other than in tanks for the time being forming part of a powered

vehicle, of any of the substances listed below, except where the total storage capacity of

the tanks installed at the location in question in which the relevant substance may be

            stored is less than the figure specified below in relation to that substance

Any ideas?

How you classify 200 kg drum and 1 tonne IBC? Packaging or bulk storage?

I see!  I for one would normally consider both these as packed goods.  Drums are not tanks and I've always thought of IBCs (also known as semi-bulks) as not tanks and not quite bulk.  But unhelpfully, the legislation doesn't define the term 'tank' so I suppose there is scope for argument over the IBC.

The size of individual storages can be environmentally relevant as well as the total quantity because of the worse consequences if a single large container is breached than a small one.

I will be interested to hear a definitive answer!

I am thinking in lines that IBC is not bulk storage. If single IBC will leak / damage it will be very easy to contain any spillage, so it is little danger to environment. Also it is very unlikely that all IBC's will leak on this same time in storage area.

However when tank (e.g. 10-20 tonnes) will leak, it will be very hard to contain spillage and it is very likely to damage environment.

Bulk is the term used for unpackaged goods in ADR (think shipped by tanker / container and discharged in to a storage tank or silo at the customer)

Despite its name an IBC is considered a large packaging

Originally Posted by: artur.kidacki@gmail.com

I am thinking in lines that IBC is not bulk storage. If single IBC will leak / damage it will be very easy to contain any spillage, so it is little danger to environment. Also it is very unlikely that all IBC's will leak on this same time in storage area.

However when tank (e.g. 10-20 tonnes) will leak, it will be very hard to contain spillage and it is very likely to damage environment.

http://www.hse.gov.uk/comah/sragtech/techmeascontain.htm

It should not be hard to contain a spillage - there are requirements for secondary containment see link above

Except that this section is specifically and explicitly about storage 'in tanks' - if the things the stuff is stored in are not tanks, then it doesn't apply. 

The ADR definition - Bulk container - means a containment system(including any linder or coating) intended for the carriage of solid substances whihc are in direct contact with the containment system.  Packagings including IBCs, large packagings and tanks are not included"

A bulk container also will have a capacity of not less than 1.0m3

That is fair enough Kate I could be wrong, we are not disagreeing on anything much, there is as you say is no definition of tank. I think if I had enough of a listed chemical in whatever vessel to exceed the quantity listed, I would for peace of mind just check with the EA. Some the chemicals listed they are talking of significant quantities, which is why they use the word tank because who would store say 100 tonnes of anhydrous ammonia in 200L drums. So, I thought the OP’s quantity may not meet the threshold and then the definition of tank becomes mute anyway. I have to admit as the OP has another post about ammonia mixed with water that they didn’t have the chemical listed, as anhydrous means no water. Of course, they may have more than one chemical. Hope the OP has been helped anyway a little, even if it is to confirm no definition of tank. 

The EA use odd terms for things. ie as part of our Part B permit we had to ensure that the paint noted above was taken to the point of use in a “sealed transport vessel” where you and I would call it the tin it came in :o) they knew full well that is what we did, but hay sealed transport vessel sounds better. This was a specific clause, great fun.