PGS 15 explained: requirements for storing hazardous substances in industry
The safe storage of hazardous substances in industrial environments demands strict compliance with regulations. PGS 15, part of the Publicatiereeks Gevaarlijke Stoffen (Hazardous Substances Publication Series), forms the basis for these safety requirements in the Netherlands. This guideline specifically governs the storage of packaged hazardous substances and sets clear requirements for ventilation, detection systems and fire prevention. For companies in the manufacturing industry, knowledge of PGS 15 is essential for compliance and the safety of employees.
What is PGS 15 and why is it important?
PGS 15 is the fifteenth publication in the Hazardous Substances series and specifically governs the storage of packaged hazardous substances in industrial facilities. This guideline was developed by the Ministry of Infrastructure and Water Management in collaboration with industrial safety experts and forms an essential part of Dutch safety regulations.
The guideline focuses on the storage of hazardous substances that are packaged in containers, drums, jerry cans and other forms of packaging. This distinguishes PGS 15 from other publications in the series that focus on bulk storage or specific substance categories. For companies in the chemical industry in the Netherlands, compliance with this guideline is mandatory once certain threshold values are exceeded.
The main objectives of PGS 15 are to prevent accidents, minimise risks to employees and local residents, and safeguard environmental safety. The guideline sets specific requirements for storage facilities, detection systems, ventilation provisions and emergency procedures.
Threshold values and permit obligations
The threshold value for an environmental permit is set at 10 tonnes for ADR class 3 substances. This limit determines when companies are required to apply for an environmental permit for the storage of hazardous substances. Exceeding this threshold means that the facility falls under the PGS 15 regime and must meet all the requirements set out.
Different threshold values apply to different categories of hazardous substances. ADR class 3 substances (flammable liquids) have a relatively low threshold of 10 tonnes, while higher thresholds may apply to other classes. Companies must keep precise records of what quantities of which substances they store in order to determine whether they are subject to the permit obligation.
The consequences of exceeding threshold values are far-reaching. In addition to the obligation to apply for an environmental permit, companies must meet all the technical and organisational requirements of PGS 15. This may require considerable investment in safety provisions, detection systems and ventilation installations.
| ADR Class | Substance category | Threshold value | Permit obligation |
|---|---|---|---|
| 3 | Flammable liquids | 10 tonnes | Yes, above threshold |
| 4.1 | Flammable solids | 25 tonnes | Yes, above threshold |
| 6.1 | Toxic substances | 5 tonnes | Yes, above threshold |
| 8 | Corrosive substances | 25 tonnes | Yes, above threshold |
Ventilation requirements under PGS 15
Ventilation must take place at least once per hour in storage areas for hazardous substances. This requirement is fundamental to preventing dangerous concentrations of vapours and gases. The ventilation air must be discharged to a safe location where no danger arises to people or the environment.
Ventilation requirements vary depending on the type of hazardous substance and storage conditions. For flammable liquids, mechanical ventilation is often mandatory, while for certain other substances natural ventilation may suffice, provided it meets the minimum air change of once per hour.
Detection systems play a crucial role in combination with ventilation systems. When gas detection detects an elevated concentration, ventilation must be automatically increased or alarm systems must be activated. This integration of systems is essential for effective risk management, comparable to the integrated systems in industrial automation and safety.
Ventilation systems must be tested and maintained regularly. PGS 15 stipulates that ventilation performance must be verified annually and that all components must be inspected for proper functioning. Documentation of maintenance and testing is mandatory and must be available for regulators.
ATEX requirements above the threshold value
ATEX classification becomes mandatory when the threshold value is exceeded. ATEX (ATmosphères EXplosibles) governs safety in environments where explosive atmospheres may occur. This European directive is fully integrated into Dutch legislation via PGS 15.
ATEX classification requires a thorough analysis of all locations where explosive atmospheres may occur. These zones are divided into different categories (Zone 0, 1 and 2 for gases and Zone 20, 21 and 22 for dust) depending on the likelihood and duration of explosive atmospheres.
Electrical equipment in ATEX zones must comply with specific safety standards. This means that standard electrical installations often have to be replaced by ATEX-certified alternatives. This equipment is designed not to create ignition sources, even under normal wear or foreseeable defects.
The explosion protection document (EPD) is a mandatory part of ATEX compliance. This document must identify all explosion risks, describe control measures and establish procedures for working safely in explosive atmospheres. The EPD must be updated whenever processes or storage quantities change.
Storage cabinets and notification obligations
Storage cabinets under 50 litres are exempt from the permit obligation, but above 50 litres a notification obligation applies. This arrangement offers flexibility for small quantities of hazardous substances, while larger storage capacities remain subject to supervision.
The specifications for storage cabinets are strictly defined in PGS 15. Cabinets must meet fire resistance classes, corrosion resistance and ventilation requirements. Spill trays are mandatory to catch spillage or leaks, and the capacity of these spill trays must be at least 110% of the largest container.
Storage cabinets subject to notification require documentation of contents, location and safety measures. This information must be shared with local safety services so that they can respond adequately in emergencies. For companies in metalworking and occupational safety, these requirements are particularly relevant for the storage of solvents and coatings.
| Storage capacity | Permit obligation | Notification obligation | Technical requirements |
|---|---|---|---|
| < 50 litres | No | No | Basic fire safety |
| 50-200 litres | No | Yes | Spill tray + ventilation |
| 200-1000 litres | Possibly | Yes | Fire resistant + detection |
| > 1000 litres | Yes | Yes | Full PGS 15 compliance |
Fire prevention and detection systems
Fire prevention forms a core element of PGS 15, with specific requirements for detection, extinguishing systems and evacuation procedures. These systems must be tailored to the specific properties of the stored hazardous substances and the storage conditions.
Smoke detection systems are often insufficient for storage areas of hazardous substances. PGS 15 often requires advanced detection systems such as flame detection, heat detection or gas detection, depending on the nature of the stored substances. These systems must be linked to automatic alerting and can be linked to automatic extinguishing systems.
Extinguishing systems must be compatible with the stored substances. Water, for example, may be unsuitable for certain chemicals and can even cause dangerous reactions. Foam extinguishing systems, CO2 systems or dry extinguishing agents may be more suitable alternatives, depending on the substance class.
Evacuation procedures must take into account the specific hazards of stored substances. Toxic vapours can block evacuation routes, making alternative routes necessary. Training of staff in emergency procedures is mandatory and must be repeated regularly with scenario-based exercises.
Implementation and compliance
Successful implementation of PGS 15 requires a systematic approach involving risk analysis, technical measures and organisational procedures. Companies must start with a thorough inventory of all stored hazardous substances and their quantities in order to determine which requirements apply.
The first step is to carry out a quantitative risk analysis (QRA) for all storage activities. This analysis identifies potential accident scenarios, calculates risks to people and the environment, and determines which control measures are necessary. The QRA forms the basis for the design of safety measures and must be carried out by qualified safety experts.
Technical implementation often involves considerable investment in new storage facilities, ventilation systems, detection equipment and extinguishing systems. These investments must be weighed against the risks of non-compliance, including fines, production stoppages and liability for accidents.
Organisational measures are just as important as technical provisions. This includes developing working procedures, training staff, setting up inspection schedules and establishing a safety management system. Documentation of all procedures and training is mandatory for compliance audits.
Changes and future developments
PGS 15 is regularly updated to incorporate new safety insights and technological developments. Companies must stay informed of changes in regulations and adapt their systems when new versions of the guideline are published.
The transition towards more sustainable industrial processes also affects the storage of hazardous substances. New materials and processes may carry other safety risks, requiring PGS 15 to be adapted to these developments. Digitalisation and the Internet of Things (IoT) offer new possibilities for monitoring and risk management.
Climate change also places new demands on storage systems. Extreme weather conditions can affect the effectiveness of ventilation systems and require more robust designs. Flood risks and heatwaves must be included in risk analyses and emergency plans.
The 2026 deadline for full compliance with the latest version of PGS 15 is approaching quickly. Companies that are not yet fully compliant must accelerate their implementation plans to meet all requirements in time. Delay can lead to penalty payments and forced business closures.
Frequently asked questions about PGS 15
What is the difference between PGS 15 and other PGS guidelines?
PGS 15 focuses specifically on the storage of packaged hazardous substances, while other PGS guidelines address different aspects of hazardous substances. PGS 29, for example, covers tank storage of flammable liquids, and PGS 35 focuses on the storage of gases. PGS 15 is unique because it concentrates on smaller packaging units such as drums, jerry cans and containers rather than bulk storage. This focus makes it particularly relevant for companies that store various hazardous substances in limited quantities, such as many companies in the processing industry.
How do I determine whether my company falls under PGS 15?
Whether your company falls under PGS 15 depends on the quantities and types of hazardous substances you store. For ADR class 3 substances (flammable liquids) a threshold value of 10 tonnes applies. You must inventory all stored hazardous substances, including paint, solvents, adhesives and other chemicals. Add up the quantities per ADR class and compare them with the threshold values. Note that temporary storage during transport or production also counts. If in doubt, it is advisable to engage a specialised consultancy for a compliance audit.
What costs are associated with implementing PGS 15?
The costs of PGS 15 implementation vary greatly depending on the current situation and the adjustments required. A risk analysis can cost €5,000-€15,000, while technical adjustments such as ventilation systems, detection equipment and fire-resistant storage cabinets can amount to €50,000-€200,000 or more. ATEX certification of electrical installations can cost an additional €10,000-€50,000. In addition, there are costs for permit applications, staff training and periodic inspections. Although the initial investment can be considerable, the costs of non-compliance are often much higher due to fines, production stoppages and liability risks.
How often should I inspect my PGS 15 systems?
PGS 15 requires different inspection frequencies for different systems. Ventilation systems must be tested annually for capacity and operation. Detection systems require monthly function tests and annual calibration. Storage cabinets must be inspected visually every day for damage or leaks. Spill trays must be checked weekly for contamination or damage. Fire extinguishing systems follow their own inspection regime according to NEN standards. All inspections must be documented and the results must be available for regulators. It is advisable to keep a digital inspection schedule to ensure compliance.
What happens if I do not comply with PGS 15?
Non-compliance with PGS 15 can have serious consequences. Regulators can impose penalty payments that can run into thousands of euros per day until the violations are remedied. In serious cases, an order subject to a penalty can be imposed that halts business operations. Criminal prosecution is possible in cases of gross violations or when accidents arise due to non-compliance. In addition, non-compliance can lead to higher insurance premiums or even refusal of cover. In the event of an accident, non-compliance can lead to personal liability of directors and considerable compensation payments.
Can I carry out a risk analysis for PGS 15 myself?
Although small companies can carry out certain parts of the risk analysis themselves, PGS 15 compliance often requires specialised knowledge. A full quantitative risk analysis (QRA) must be carried out by qualified experts who are familiar with modelling software and risk calculation methods. Self-analysis is possible for the inventory of substances and identifying basic risks, but the calculation of individual and group risks requires specialist expertise. Many insurers and regulators only accept risk analyses that have been carried out by certified advisers. It is advisable to at least have the final conclusions and recommendations validated by experts.
How does PGS 15 relate to REACH and CLP regulations?
PGS 15, REACH and CLP regulations are complementary regulations that address different aspects of chemical safety. REACH governs the registration and authorisation of chemical substances, while CLP governs classification and labelling. PGS 15 builds on these classifications and specifically governs safe storage. A substance registered under REACH and classified as hazardous under CLP may fall under PGS 15 if it is stored in certain quantities. The safety data sheets (SDS) that are mandatory under REACH contain essential information for PGS 15 compliance, such as storage requirements and emergency measures. Companies must integrate all three regulatory frameworks into their chemical safety strategy.
What training is required for employees under PGS 15?
PGS 15 requires extensive training for all employees who work with or around hazardous substances. Basic training must cover: recognition of hazardous substances, understanding labelling and pictograms, correct handling and storage procedures, emergency procedures and evacuation procedures. Specialised employees such as warehouse managers and safety coordinators need more extensive training in risk analysis, inspection procedures and incident management. Training must be documented and repeated regularly, usually annually. New employees must receive training before they may work independently with hazardous substances. Scenario-based exercises are required to test practical skills and practise emergency procedures.
The implementation of PGS 15 requires a thorough approach and continuous attention to safety. For companies that are not yet fully compliant, it is important to take swift action given the approaching 2026 deadline. Investing in proper safety measures not only protects employees and the environment, but also prevents costly fines and business disruptions.
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