Rank: Forum user 
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Hi all,
I hope you can help me... I currently work as a Health, safety and Environment officer at a large pharmaceutical distributor. One of our sites used to fall into COMAH from LPG so we had a purpose built cage within the warehouse to keep aerosols with control measures surrounding it, no MHE inside etc We have been asked by a client to now store some gift sets, for example a 250 ml shampoo with a 150ml aerosol in the same packaging. The boxes all have UN1950 on but I am questioning if the same control measures as the standard 'packaged aerosols must apply?
Currently the aerosols in the cage are usually in a pack 4 or 6 with a thin film around them stacked on a pallet, but due to the extra packaging of the gift sets would I still need to store them in a controlled cage or would standard storage be appropriate?
It is all a temp controlled site so heat is not an issue Many Thanks In Advance
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Rank: Super forum user
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Is the warehouse sprinkler protected? Pallet cages are a common control method for preventing aerosol containers launching out of the racking in a fire situation, resulting in multiple seats of fire. This has a serious potential to overwhelm the sprinkler system - too many sprinkler heads opening up, resulting in loss of water pressure as the pumps fail to keep up. Whenever I've seen large pharma warehouses in the past, the values stored are usually very high and your insurers will have a keen interest in the aerosol storage arrangements. Last one I saw was in Bedford, just in case that happens to be yours, drop me a PM.
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Rank: Super forum user
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You need to complete a DSEAR risk assessment.
Acop L138 from the HSE covers DSEAR, guidance on warehouses etc in that guidance.
Even when wrapped on pallets you will have a small Zone 2 area around the pallets/aerosols.
Publication IP15 Hazardous area classification refers.
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Rank: Forum user
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Hi Stevie40, No this w/house isnt sprinkled for that particular reason. I say fell out of COMAH because the tonnages went up in the new regs and we slipped out of the threshold. It doesn't mean our other sites haven't fell back into for other various ingredients though! We arent based in Bedford, but we do have regular visits from the HSE to check we are adhering to COMAH and DSEAR, but this is new ground for me regarding the gift sets and I wanted clarification before I went back to the client
Ian Bell2, thank you for that. I shall look at the guidance listed in your post and see what I can come up with
Many thanks
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Rank: Forum user
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We have ours stored in an aerosol cage about 450 pallets with a foam suppresion system. I would suggest that a lot will depend on the amount of stock that you will hold, comah changed last year or the year before and you may now store an incrsed amount .
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Rank: Forum user
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Hi Thanks for that
Im just confused if Gift Sets need to also be in a cage? Just becasue they are surrounded by so much packaging, do they fall until the same regs?
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Rank: Super forum user 
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Nicole, the aerosols will have a flammable compressed gas propellant and the contents may or may not be flammable. Regardless of the packaging, ask yourself what would occur if a fire was to involve these items. Probably just the same as your "normal" aerosol stocks. Many years ago I was mightily entertained from my bedroom window watching the spectacular firework show when a car aerosol paint warehouse was ablaze. Your response to Stevie40 re sprinklers confuses me. You imply you don't have sprinklers because your insurers would insist on a cage? If I was advising you on this matter I would be strongly suggesting that this is a very flimsy reason and to reconsider the risk reduction to be achieved by installing a properly designed sprinkler system.
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Rank: Forum user
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I would suggest that your DSEAR Assessment would highlight the corresponding measures that are required. If the area is classed as an ex zone then limited/controlled ignition sources along with other controls would prevent such an explosion or fire.
Its important to remember that without knowing the storage area, building, current controlls and the full product details that it's not possible to provide comprehensive advice but reference to the COMAH regs and DSEAR would be my main consideration (as you have already mentioned you have considered)
Hope this helps.
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Rank: Super forum user
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#1 I would assume the shampoo is water based/not relvant to DSEAR
For the aerosols what is flammable ? Just the propellant gas or is it alcohol based perfumes?
Also a bit unclear about #4 you say 'fell out of COMAH ' then later you say 'HSE check you are adhering to Comah'
If the HSE have confirmed that Comah no longer applies to your site, then they won't enforce the regulations on you.
If you need to double check what is in the gift sets to decide if DSEAR applies.
Are the gift packs finished items, ready to go to the shops etc? Any open containers/manufacture done on site?
As previous you will probably have a small Zone 2 around stored pallets if you exceed the stored limits given in IP15 publication. The zone 2 area will probably be about a 1m radius or so. So #8 is probably being over imaginative to claim a fire/explosion. ATEX rated electrical equipment etc probably won't be required as the zone 2 hazardous area is small. Just apply common sense and maintain an adequate separation between the stored goods and electrical equipment.
If the gift sets are finished products, spillage probably isn't a major concern as you would be very unlucky if more than 1 gift set leaked randomly. The most likely reason for a leak is spearing a pallet load with the forks of a forklift truck or dropping a pallet etc. In which case the driver should clear up the spillage.
If you are now well below the Comah limits you are going to need a lot of gift sets at 150ml to get you into Comah territory.
As you probably know Comah is about writing safety cases, so won't give you much specific guidance about storage, #8 is incorrect.
Try reading/downloading HSG76 Warehousing guidance from the HSE website and HSG140 Safe use and handling of flammable liquids. Might be some hints and tips in there that are useful.
By the sound of it, you need a good fire risk assessment, which also considers DSEAR and associated good fire safety practice and warehouse/flammable liquid practice as mentioned.
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