Legalisation of chemical products storage (APQ)

A chemical products store needs a project that sets out its safety measures to prevent harm to people, property and the environment. We draft it and prepare the responsible declaration.

Royal Decree 656/2017MIE APQ 0 to 10

In brief

  • Legalisation is based on a project setting out the safety measures of the installation.
  • It is governed by the Chemical Products Storage Regulation (APQ regulation, Royal Decree 656/2017) and its technical instructions ITC MIE APQ 0 to 10.
  • The project stays with the company; a responsible declaration is submitted to the Generalitat (Catalan Government).
  • This is followed by a verification visit, an inspection by an authorised control body (OCA) after 5 years and annual reviews.

What does legalisation involve?

A technical report is drawn up establishing the safety measures required at the installation, with the overriding aim of preventing harm to people, property and the environment. The procedures are set by Royal Decree 656/2017, of 23 June, approving the Chemical Products Storage Regulation (APQ) and its Complementary Technical Instructions MIE APQ 0 to 10.

What does the APQ project contain?

  • Identification of the hazardous chemical products to be stored.
  • Joint storage.
  • Description of the installation according to the products stored: fixed and mobile containers, supporting elements, leak and spill containment systems (bunds, retention basins, etc.), fire protection means, product handling, transfer elements and equipment for moving and positioning mobile containers, with their characteristics and sizing.
  • List of applicable Complementary Technical Instructions.
  • Justification of compliance with the safety requirements.
  • Instructions for the use, maintenance and safety of the installation.
  • Drawings.

The responsible declaration

Once the project has been prepared and the safety measures implemented, the project is not submitted to the authorities: it stays with the company. What is submitted to the Generalitat is a responsible declaration (declaración responsable) by the owner of the installation, stating that the store complies with the applicable requirements.

Once this step is complete, the store is legalised pending verification by the authorities.

How we do it

  1. Site visit
    We gather the data on the store and the products.
  2. Project
    We prepare the technical documentation, draft the project and produce the drawings.
  3. Responsible declaration
    We prepare and submit the responsible declaration to the Generalitat.
  4. Follow-up
    We prepare any additional documentation requested by the authorities during the procedure.

Periodic inspections

  • Verification visit: the Generalitat schedules a first visit to verify that the installation matches the project.
  • 5-year inspection: 5 years after commissioning, an authorised control body (Organismo de Control Autorizado, OCA) must be engaged to carry out a periodic inspection.
  • Annual review: visual inspection of the condition of the installations and technical checks. It may be carried out by the company itself or entrusted to an OCA.

Frequently asked questions

Do I have to submit the APQ project to the authorities?

No. The project stays with the company. A responsible declaration by the owner is submitted to the Generalitat.

When is the store legalised?

Once the responsible declaration has been submitted, pending the verification visit by the authorities.

Who carries out the annual review?

The company itself or an OCA, as you prefer. The 5-year inspection, however, must be carried out by an OCA.