TRGS 510 Storage of hazardous substances: obligations, quantities and evidence

The Technical Rule for Hazardous Substances TRGS 510 in the updated version of February 2021 specifies the requirements of the Hazardous Substances Ordinance for the storage of hazardous substances in portable containers. It supplements Sections 8 and 9 GefStoffV and, according to Section 19 Paragraph 3 GefStoffV, must be complied with when storing quantities of 1,500 kilograms or more in gross weight or for particularly dangerous substances such as carcinogenic substances in categories 1A and 1B at significantly lower thresholds. According to Section 22 GefStoffV, violations are punishable as administrative offenses with fines of up to 50,000 euros, and in serious cases they are also criminally relevant under the Chemicals Act. The supervisory authorities are the state occupational safety authorities, in federal states such as Bavaria the trade inspection offices, in others the district governments or the responsible occupational safety offices.

This article explains which quantity thresholds, collective storage rules and structural requirements are specified by TRGS 510, how storage concepts can be documented in an audit-proof manner and what role the hazardous substances officer plays. As a compliance platform and officer-as-a-service, CIVAC supports hazardous substances officers in chemistry, pharmaceuticals, coatings, cleaning services, automotive workshops and research institutions with storage concept templates, safety data sheet management and audit trails. Licence the workspace for your internal representatives or have our representatives order it. Audit-proof, documented, § 19 GefStoffV-proof. The article provides the quantity matrix, the joint storage table and the gap list with which you can systematically check the warehouse.

TRGS 510 regulates the storage of hazardous substances in portable containers, i.e. in containers, barrels, canisters, IBC containers and comparable packaging with an individual volume of up to 3,000 liters. It applies to storage in storage rooms, warehouses, hazardous materials cabinets and outdoors if portable containers are used. Tank systems and stationary containers over 3,000 liters are not subject to TRGS 510, but are subject to the Industrial Safety Ordinance and the TRwS series of regulations for substances hazardous to water. The transport of dangerous goods is also limited and is subject to the ADR and the supplementary regulations of the Dangerous Goods Ordinance on Roads, Railways and Inland Waterways.

The scope of application begins with the provision of dangerous goods for storage. According to TRGS 510, provision is not storage, but rather an activity for immediate consumption within a work shift. This distinction is often controversial in audits because workshops and production companies keep containers near the workplace that are formally considered storage. When storing hazardous substances in excess of the available quantity, TRGS 510 applies with its obligations regarding protective measures and documentation. The quantity provided is based on daily consumption and must be explicitly defined in the storage concept so that the dividing line between provision and storage in the audit is not interpreted to the detriment of the company.

In conjunction with Section 6 GefStoffV, TRGS 510 requires a written risk assessment, which is managed as a central task under Hazardous Substances Officer. This assessment is not a one-off, but must be adjusted whenever there is a significant change in the range, quantities or structural conditions. CIVAC carries out the risk assessment in the workspace with the version status and event documentation, so that it remains traceable in the audit which version was valid when and which events led to the update. This turns the assessment from a static document into a living compliance trace that contributes to the supervisory audit.

TRGS 510 classifies the requirements according to quantity thresholds, which are based on the gross weight of all stored hazardous substances. Up to 200 kilograms of gross weight, general protective measures apply, such as proper storage in suitable containers, appropriate labelling and protection against unauthorized access. Between 200 and 1,500 kilograms, additional measures are required, such as setting up defined storage locations, limiting storage and training employees. From 1,500 kilograms, the full requirements of TRGS 510 apply with storage concept, structural fire protection, ventilation, collecting trays and written operating instructions in accordance with Section 14 GefStoffV. This gradation must be expressly reflected in the storage concept.

Lower thresholds apply to certain material groups. In the case of carcinogenic, germ cell mutagenic or reproductively toxic substances in categories 1A and 1B (KMR substances), the full requirements must be met from significantly smaller quantities, in many cases from 100 kilograms. Stricter thresholds also apply to acutely toxic substances in categories 1 and 2. For flammable liquids of categories 1 and 2 according to the CLP regulation, the requirements of TRGS 509 for stationary containers and TRBS 1112 for potentially explosive areas also come into consideration. The water hazard class system according to AwSV also sets its own thresholds.

The quantities are calculated summarily across all storage locations in a company. Individual cabinets, workshop storage and central hazardous materials storage are added together. A division to circumvent the thresholds can be seen in the audit and leads to complaints. CIVAC maintains the quantity structure in the workspace and alerts when the threshold values ​​are approached, so that procurement and storage are prepared for the next stage at an early stage. The auditor calls, the evidence is ready. Retroactive volume reduction during a crisis is usually more complex and expensive than proactive planning with clear thresholds because returns and disposal cause logistics and waste costs.

The TRGS 510 classifies hazardous substances into 13 storage classes, which result from the requirements of the Ordinance on Flammable Liquids and the hazard classes of the CLP Ordinance. Storage class 1 includes explosive substances, storage class 2A and 2B compressed gases, storage class 3 flammable liquids, storage class 4.1A and 4.1B flammable solids and self-reactive substances, storage class 4.2 self-igniting substances, storage class 4.3 substances that develop flammable gases in contact with water, storage class 5.1A and 5.1B igniting substances, storage class 5.2 organic peroxides, storage class 6.1A to 6.1D toxic substances in different acute toxicity levels, storage class 6.2 infectious substances, storage class 7 radioactive substances, storage class 8A and 8B corrosive substances and storage class 10 to 13 other liquid and solid substances.

The storage group table in Appendix 5 of TRGS 510 shows for each Pair of storage classes, whether joint storage is permitted without restrictions, only permitted with additional protective measures, or prohibited. For example, storing acids in storage class 8A together with alkalis is prohibited because mixing can produce heat and splashes. Storing oxidizing agents of storage class 5.1 together with flammable liquids of storage class 3 is also prohibited because there is a risk of fire acceleration.

Separation is carried out either by spatial separation with defined minimum distances, by structural separation with fire-resistant walls or by storage in separate cupboards. Which method is permitted depends on the quantity and the hazard class. CIVAC provides an interactive storage matrix in the workspace that compares the company's current product range with the separation requirements. If new substances are stored, the matrix is ​​automatically updated and the hazardous substances officer receives an indication of where the separation needs to be adjusted. Others run compliance like a filing cabinet. We run it like software.

TRGS 510 places structural requirements on hazardous substance storage facilities that increase with the quantity and danger of the substances. Collection trays are mandatory for liquid hazardous substances and must contain the volume of the largest individual container or 10 percent of the total storage quantity, whichever is higher. For substances that are hazardous to water, the requirements of the AwSV extend the collection volume to 100 percent of the storage quantity if the storage takes place in water protection areas or the potential for damage is particularly high. Plastic collection trays may be suitable for acids and alkalis; metal trays with an appropriate internal coating are required for solvents.

Ventilation systems are mandatory in warehouses with flammable or health-endangering substances as soon as there is a risk of a dangerous, explosive atmosphere or of workplace limit values ​​being exceeded. TRGS 510 refers here to TRGS 900 for air limit values ​​and TRBS 1112 for explosion protection. The ventilation must be designed with a minimum change rate depending on the type of storage and product range, usually between two and ten times the air change per hour. A maintenance obligation is associated with annual functional tests, which must be carried out in the maintenance plan and presented as maintenance receipt in the audit.

Fire protection is based on the model building regulations, the industrial building guidelines and TRGS 509 for stationary systems. Fire compartments with fire-resistant walls are required for defined quantities, fire alarm systems are required for larger quantities and are connected to fire brigade control centres. CIVAC bundles the structural requirements in the workspace as a checklist-based warehouse inspection and links them with maintenance dates, test reports and list of defects. The appointment certificate, signed, filed, verifiable. When the product range changes, the structural requirements are checked again and the hazardous materials officer receives the task list with delivery dates. This means that construction and product range remain in harmony.

Every hazardous substance in the warehouse must be labelled in accordance with Article 17 of the CLP Regulation. The labelling includes product identifiers, hazard pictograms, signal words, hazard and safety instructions as well as the name of the person placing the product on the market. Transfers into other containers must be labelled identically, otherwise there is a risk of complaints and, in the event of damage, personal liability for those responsible. The labelling in the warehouse is supplemented by storage location signage that indicates the substances contained and the associated protective measures. In ATEX areas there is also labelling according to Directive 2014/34/EU, and in areas with fire protection requirements there is signage according to ASR A1.3.

Safety data sheets according to Article 31 of the REACH Regulation must be kept for each hazardous substance and must be up to date. Publication of the safety data sheet older than three years is critical in the audit; failure to update it after a change in classification is a breach of duty. Safety data sheets must be available in the language of the employee, in Germany usually in German. An English-language version alone is not enough if German-speaking employees work with the material. The safety data sheets must be kept readily available in the warehouse, for example as a digital solution with tablet access or as a well-maintained folder. The supplier request for an update is part of the procurement routine.

The training of employees in accordance with Section 14 GefStoffV must be carried out at least annually and documented in writing. It covers the hazards, protective measures, behaviour in the event of damage and the use of personal protective equipment. Participation is recorded in the training register with date, content and signature. CIVAC integrates the instruction in the workspace with a template, comprehension test and audit-proof receipt. The auditor calls, the evidence is ready. Safety data sheets are maintained centrally, warehouse management accesses the current status without employees using old versions with outdated protective measures.

The appointment of a hazardous substances officer is not formally required in all industries, but in practice it is enforced by the GefStoffV and TRGS 510 because the expert person is responsible for the risk assessment, the storage concept and the instruction. According to Section 6 GefStoffV, the appointment certificate is not required by name, but is standard in audit practice due to the obligation to transfer responsibility. A missing or incomplete order is regularly criticized in the audits of the professional association and the supervisory authorities and can lead to personal liability of the management according to Section 130 OWiG.

The list of tasks of the hazardous substances officer covers ten areas. Firstly, the risk assessment according to Section 6 GefStoffV. Secondly, the storage concept according to TRGS 510. Thirdly, the management of the safety data sheets. Fourth, the creation of operating instructions in accordance with Section 14 GefStoffV. Fifth, the annual training of employees. Sixth, the labelling of storage locations and containers. Seventh, monitoring protective measures and personal protective equipment. Eighth, incident and emergency management. Ninth, the interface to the occupational safety specialist, the company doctor and the fire protection officer. Tenthly, participation in audits and official examinations.

The function requires professional competence, which is acquired through courses according to DGUV or professional association. CIVAC bundles the tasks at civac.de/roles/ Hazardous Materials Officer in the workspace with an appointment certificate, catalogue of tasks, deadlines and templates. Licence the workspace for your internal representatives or have our representatives order it. For vacancies or multi-location structures, CIVAC takes on the function of officer-as-a-service with a response window of 2 working days. Deadline begins as soon as we become aware of it. This means that the management's duty of supervision remains fully documented even during periods of vacancy.

The supervisory authorities regularly check hazardous material storage facilities on a random basis and on an ad hoc basis. Random checks are carried out as part of the annual supervisory routine, event-related checks after incidents, complaints from neighbors or during industry campaigns by the state supervisory authorities. A typical on-site inspection lasts between two and six hours and follows a standardised inspection grid. The appointment of the hazardous substances officer, risk assessment, storage concept, safety data sheets, labelling, collection trays, ventilation, proof of instruction, operating instructions, personal protective equipment as well as incident and emergency management with emergency showers and eye washes are checked.

Frequent complaints include outdated safety data sheets, lack of collection volumes for water-polluting substances, inadmissible storage, missing Evidence of training, missing operating instructions in the language of the employees, missing maintenance documents for the ventilation and incomplete storage concepts. A complaint leads to a period for rectification, often between four and twelve weeks, depending on the severity. If there is imminent danger, the supervisory authority can order a temporary shutdown of the warehouse, which has significant consequences for production operations. Fines according to Section 22 GefStoffV range up to 50,000 euros per violation, and violations quickly add up to six-figure amounts.

CIVAC prepares structural audits in the workspace. The 490 audit templates contain the regulatory authorities' standardised test grid, so that the hazardous substances officer can carry out a complete internal control before the test. Gaps are provided with delivery dates and closed before the audit. During the audit itself, the documents are exported from the workspace without delay. The auditor calls, the evidence is ready. This structural audit preparation is often the difference between an inspection without any problems and a period of improvement with tied-up resources. A prepared audit folder usually saves several man-days per appointment and significantly reduces the follow-up costs of repairs because the defects are processed without pressure and outside of the supervisory context.

Three gaps occur particularly frequently in German hazardous materials storage facilities. Firstly, the impermissible storage of substances from different storage classes together. The table in Appendix 5 of TRGS 510 is complex and in practice is often not present in the warehouse employee's mind. Procurement is assortment-driven, storage locations are created historically and are not systematically checked. The audit detects acids next to alkalis, oxidizing agents next to flammable liquids or food substitutes in hazardous materials cabinets. A systematic assortment check with assignment to the storage class table solves this problem structurally and removes the repetition dynamic.

Secondly, the omitted instruction. The annual instruction according to Section 14 GefStoffV is often formally checked off, without a comprehension test and without language adjustment. In multilingual workforces, instruction is given in English or German, even though employees speak Polish, Turkish or Romanian. The language of the instruction is documented in the audit and the gap in understanding becomes immediately visible. Thirdly, the lack of maintenance records. Ventilation systems, drip trays, fire alarm systems and emergency showers require regular maintenance. In practice, the receipts are often in different folders, at facility management, at the external maintenance company or in the mailbox of a single person who cannot be reached on vacation.

CIVAC closes these gaps in the workspace structurally. The range is automatically assigned to the storage class matrix, instructions are carried out with a comprehension test and language version, maintenance records are stored centrally and linked to the associated systems. If there are reminders 60 days before a maintenance expiry, the task is automatically stopped and its completion is documented in the receipt track. Audit-proof, documented, § 14 GefStoffV-proof. This creates a consistent warehouse management that does not depend on a single person, but is structurally supported even if the core staff changes or a replacement steps in.

A TRGS 510-compliant hazardous materials warehouse is not the result of a one-off project, but of an ongoing organisation. Product ranges change, quantities fluctuate, employees change, ventilation systems age and safety data sheets are updated. Anyone who does not manage this movement in one platform loses the overview and audit security. Regulators do not examine the individual tub, but rather the maturity of the organisation behind the warehouse. A platform alone, without an appointed hazardous materials officer and without a reporting line, provides no more protection than an order without tools or a storage concept from the previous year that does not reflect today's reality.

CIVAC is a compliance platform and officer-as-a-service with workspace, audit templates, appointment certificate, reporting line and EU data residence. Licence the workspace for your internal representatives or have our representatives order it. The workspace manages the product range, the storage class assignment, the safety data sheets, the operating instructions, the instructions and the maintenance documents in a searchable structure. The auditor calls, the evidence is ready. The CIVAC SLA of 2 business days replaces the usual response window of 2 to 6 weeks when unannounced audits, incidents or product changes catch the organisation off guard. The interfaces to the occupational safety specialist and the company doctor are structurally included in the workspace.

If you want to have your hazardous materials warehouse checked for TRGS 510 conformity for the first time or want to fill the position of hazardous materials officer, we will clarify this in a structured initial discussion. Turn reading into an assignment. Write to info@civac.de or use the contact form to arrange an initial assessment of your current warehouse organisation. You will receive a concrete list of gaps with delivery dates and priorities so that the warehouse does not show cracks until the next regulatory inspection, but remains structurally aligned with the requirements of TRGS 510. Deadline expires as soon as we become aware of it.