The introduction of „Technical Rules for Hazardous Substances 529 (TRGS 529)“ in Germany earlier this year lead to several new provisions for operators of biogas plants. Besides instructions in the technical field the handling of additives is addressed in detail. In the surroundings of additives the depth of regulations was rather low until now, so that legal issues were kept in a manageable scope. In the current situation the timely consideration of the provisions, valid for micronutrient products, often saves expenses and costs.
Storage and Handling
The instruction of the staff based on the relevant operating instructions is stated as a basic condition for storage and handling with additives. As soon as a chemical is classified as acutely toxic, mutagenic to germ cells, toxic to reproduction or sensitizing for the respiratory tract in specific categories, things are considerably more complex. Then only competent respectively specially instructed persons are allowed to handle the relevant chemical.
With regard to the storage, the classification stated for the handling – excluding the respiratory sensitisation – leads to the compulsory storage under lock. Additionally a 1000 kg limit is added – as of this quantity, in which all hazardous substances present on the company site have to be taken into account, independent of their individual classification, the stock has to meet the more detailed requirements of the TRGS 510 (Nr 4.3), as for example the obligation to document the inspections of the storage facilities.
Closed dosing system
In respect of the compulsory examination of possible substitutes and the duty to use a closed dosing system dependent on the classification according the hazardous substances law, a careful selection of the additives used in the biogas plant is recommendable. For micronutrient products with a lower hazard potential the dosing method can be freely chosen further on. This means significant financial and organizational benefits.
The look at the labelling of a product shall therefore count to the decisive criteria when selecting a product. Not least working on operation instruction and hazard assessment is for a lower classified micronutrient product much more easier. For Acinor 1000 customers can refer to a prepared operating instruction, which only has to be adjusted to the own operation. The limitations for handling as well as storage under lock and the compulsory use of a closed dosing system are not applicable for Acinor 1000.
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