TRGS 510 in small businesses: Which storage requirements really apply and from what quantity

The technical rule for hazardous substances TRGS 510 “Storage of hazardous substances in portable containers” specifies the requirements of the Hazardous Substances Ordinance (GefStoffV) and the Occupational Safety and Health Act for the storage of hazardous substances below the quantity thresholds of the Major Accident Ordinance. It applies regardless of the size of the company. Anyone who stores paints, solvents, cleaners, fuels or aerosols in a car workshop, painting, carpentry, cleaning or small production company is the addressee.

This article classifies the requirements from the perspective of a small business with 5 to 50 employees. Which quantity thresholds trigger which obligations, what does a compliant warehouse under 200 kilograms look like, when does a separate storage room have to be set up, which collective storage rules apply and how is the documentation kept in such a way that the professional association auditor accepts the evidence without discussion.

TRGS 510 applies to the storage of hazardous substances in portable containers with a nominal volume of up to 1,000 liters. Larger containers and stationary tanks fall within the scope of TRGS 509 as well as additional regulations such as the AwSV or the BetrSichV. Storage within the meaning of TRGS 510 is the long-term storage of hazardous substances, to be distinguished from “provision for immediate use” at the workplace. A hand-held daily ration in the paint shop is provided, a separate cabinet for reserves is storage.

All substances with hazard classes according to CLP Regulation (EC) No. 1272/2008 are covered, from acutely toxic substances to carcinogenic substances to flammable liquids and aerosols. Outdoor storage (e.g. container storage) follows its own rules in Section 6 of TRGS 510 with additional requirements for distance, weather protection and fire protection. TRGS 510 is maintained by the Committee for Hazardous Substances (AGS) and published by the Federal Ministry of Labour and Social Affairs (BMAS) in the Common Ministerial Gazette (GMBl). Current version: September 2021 edition, GMBl No. 47/48 (p. 989). In small businesses, the role of the hazardous substances officer is often taken on by an expert person; the order is made in writing.

TRGS 510 works with graduated quantity thresholds per hazard class, measured at the storage section and at the storage facility. Three thresholds are particularly relevant in small businesses: 200 kg, 1 ton and 10 tons. Up to 200 kg total quantity of non-flammable hazardous substances, the protective target requirements, a suitable storage facility such as a hazardous substances cabinet, a collecting tray and compliance with the storage rules are generally sufficient.

Between 200 kg and 1 ton, additional requirements apply: fire-resistant separation of the storage facility (F30), ventilation, prohibition signs and, if necessary, early fire detection. From 1 tonne onwards, a separate storage room is usually required; from 10 tonnes onwards, there are more stringent requirements for system size, extinguishing equipment and collection volume. Reduced thresholds apply to flammable liquids in categories 1, 2 and 3 as well as aerosol-producing substances. Separate storage facilities or rooms must be provided for as little as 20 kg of flammable liquids of category 1 or 2 or 100 kg of category 3, combined with an explosion protection assessment in accordance with BetrSichV. The exact values ​​can be found in Table 1 of TRGS 510. Small businesses often underestimate how quickly the thresholds are reached when aerosol cans, paints and solvents are added together. An inventory according to CLP hazard classes is mandatory.

Section 12 of TRGS 510 regulates joint storage. It is not the UN classes for the transport of dangerous goods that are relevant, but rather the CLP hazard classes and the storage classes (LGK) according to Appendix 4 of TRGS 510. A table assigns one of the fields “stored together”, “stored separately” or “stored separately” to each LGK combination. “Separate” means in the same room but with spatial separation; “Separate” means a separate storage section or room.

Examples from practice: Combustible liquids (LGK 3) must not be stored together with oxidizing substances (LGK 5.1). Acids (LGK 8A) and alkalis (LGK 8B) must be separated from each other because reactions with the development of heat and gas are possible. Compressed gas packs and aerosols (LGK 2A) require special care when stored together with flammable liquids. A general solution for small businesses is a cabinet with two separate, sealed compartments. Anyone who stores lithium-ion batteries should also observe DGUV Information 205-038 and the recommendation of VdS 3103. The storage table is part of the operating instructions and should be visibly displayed in the storage facility. Others run compliance like a filing cabinet. We run it like software.

The storage facility must prevent hazardous substances from entering the ground, drains or other areas. For portable containers with liquid hazardous substances, collecting trays are required, the volume of which must at least correspond to the contents of the largest container; for water-polluting substances with classification WGK 3, an additional 10 percent of the total amount. Collection trays must be made of material that is compatible with the stored substance and their durability must be documented.

Fire protection requirements result from the protection objective: Storage facilities with flammable liquids must be designed in such a way that in the event of a fire there is no risk to neighboring areas. Hazardous substance cabinets with F30 or F90 classification according to DIN EN 14470-1 are the standard option in small businesses. When storing larger quantities, an early fire detection system must be checked, combined with fire-fighting equipment (fire extinguishers of the appropriate fire class). Ventilation is mandatory as soon as solvents or explosive atmospheres are expected; The interpretation follows TRBS 2152-2 and DGUV Rule 113-001. Anyone who prepares an explosion protection assessment keeps it in the documentation in accordance with Section 6 GefStoffV and Section 3 BetrSichV. A verifiable file consists of a risk assessment, storage concept, plan, storage table, test reports and maintenance records.

§ 6 GefStoffV requires a risk assessment before starting any activity with hazardous substances. It must be created or checked by a qualified person, documented and updated at least every 12 months and as required. According to TRGS 400 and TRGS 555, a competent person is someone with appropriate training, professional experience and current work experience. In small businesses, this role is taken on by either the managing director with further training, a specially appointed hazardous substances officer or an external service provider.

The operating instructions in accordance with Section 14 GefStoffV supplement the assessment. It must be kept in writing in understandable language, in the language of the employees, and posted in a place accessible to the employees. Contents include substance name, properties, protective measures, what to do in case of danger, first aid and proper disposal. Annual training in accordance with Section 14 Paragraph 2 GefStoffV is mandatory; it must be documented with the date, content and signature. CIVAC provides templates for risk assessments, operating instructions, instruction protocols and inventory lists, with resubmission 11 months after creation. The auditor calls, the evidence is ready.

Anyone who stores hazardous substances regularly touches on three additional legal strands. The Ordinance on Facilities for Handling Substances Hazardous to Water (AwSV) applies to facilities with substances that are classified in a water hazard class (WGK 1, 2, 3), regardless of the quantity. The systems must be reported to the district office or the water authority and, above certain quantities, inspected by experts. The Circular Economy Ordinance and the Evidence Ordinance (NachwV) require the documentation of waste that is created as hazardous substances, including electronic accompanying notes for hazardous waste.

TRGS 510 applies further when transporting within the company premises; As soon as public roads are used, the ADR and Section 8 of the Transport of Dangerous Goods Act apply. A company that sends or receives more than 1 ton of dangerous goods by road requires a dangerous goods representative in accordance with Section 1 GbV. The storage logic is not identical to the transport logic; The storage classes of TRGS 510 differ from the UN classes of ADR. Anyone who runs warehouse and logistics in parallel documents both worlds separately. When storing across multiple locations, the CIVAC workspace should maintain a location register in which quantities, storage classes, collection volumes, WGK classification and resubmissions are visible.

Recurring findings arise from inspections by the professional associations and the trade inspectorate. First: missing or incomplete risk assessment that is not substance-specific or is older than 12 months. Secondly: no operating instructions posted or outdated versions that do not correspond to the current safety data sheets. Third: inadequate collection trays, often too small or without proof of materials. Fourth: Storing prohibited combinations together, such as acids and alkalis in the same cabinet.

Other findings include: Aerosol cans stored in quantities over 20 kg in a normal workshop environment, without taking the increased risk potential into account; Lithium-ion batteries stored without a separate warehouse or fire protection facility; missing or illegible labelling of the containers (original label stuck over, own labelling without CLP conformity); no electrical testing of the hazardous substances cabinets; no documentation of annual instruction. According to Section 22 GefStoffV, the fine ranges up to 50,000 euros per violation; The professional association can also increase contributions or impose conditions. Anyone who carries out a quarterly warehouse inventory and a follow-up for operating instructions and instructions in a workspace usually closes these findings preventively. Audit-proof, documented, § ...-proof.

Step 1: Inventory and classification. Record each hazardous substance with name, manufacturer, safety data sheet, CLP hazard class, WGK, storage class and maximum storage quantity. A table with 20 to 60 rows is realistic in a small business. Compare the total for each storage class against the thresholds in Table 1 TRGS 510.

Step 2: Storage concept. Determine which materials stay in which closet or storage room. Check containment volume, material compatibility, ventilation, fire protection and access. If you have multiple locations, create a warehouse map for each location. Document the decision and the underlying consolidation table. Step 3: Documentation and resubmission routine. Combine risk assessment, operating instructions, instruction, collection pan inspection and inventory in one inventory. Adhere to the frequency: assessment annually and on an event-related basis, instruction annually, cabinet inspection according to the manufacturer's instructions, inventory quarterly. CIVAC maps this routine in the workspace, with templates for every step and automatic resubmission. If you fill the role entirely externally, have the hazardous substances officer appointed, with an appointment certificate, reporting line and 2 working days SLA until the first inventory is taken.

CIVAC is a compliance platform and officer-as-a-service. Licence the workspace for your internal hazardous materials officer and keep inventory, storage matrix, risk assessment, operating instructions and follow-ups in one inventory. Or have our representatives order, with an appointment certificate, signed, filed and verifiable. The EU data residency, the ISO 27001:2022 basis and the 490 audit templates underlie every solution, whether you are coordinating a small workshop or several production sites.

In small businesses, TRGS 510 compliance rarely fails due to good will, often due to lost data points: What substance is currently in the cupboard, who last gave instructions, when was the cupboard last checked, which variant of the safety data sheet is on the notice board. The workspace brings all the points together and reports when something is due. Write to info@civac.de or use the contact form on civac.de. We check your storage situation, suggest the necessary templates and set up the workspace. Turn reading into an assignment.