This regulatory clarification explains which separation distances to protected places apply to Type A-D stores that hold class 3.1C substances.

The Health and Safety at Work (Hazardous Substances) Regulations 2017 (HS Regulations) set minimum separation distances between flammable liquid storage areas (Type A–D stores) and protected places.

Stores holding class 3.1C in containers of any size

Regulations 11.12(external link) (for stores that are not hazardous substance locations (HSLs)) and 11.30(external link) (for stores that are HSLs) apply to Type A-D stores holding class 3.1C substances in containers of any size. The required separation distances are specified in Table 6 of Schedule 12(external link)

Stores holding class 3.1C containers over 60L

Regulations 11.14(external link) (non HSLs) and 11.34(external link) (HSLs) apply where a Type A-D store holds containers with over 60 L of class 3.1A, 3.1B, or 3.1C substances. In these circumstances, the required separation distances are specified in Table 7 of Schedule 12(external link)

When both Table 6 and Table 7 apply

Because regulations 11.12(external link) and 11.30(external link) apply to class 3.1C substances held in containers, regardless of size, any store holding class 3.1C substances in containers larger than 60 L must consider the requirements of both:

Where two applicable requirements differ, the HS Regulations require the more stringent requirement to be met. This means that when both tables apply, the distances specified in Table 7 must be complied with, as these are greater.

Example

A Type A or B store holding drums, of over 60L capacity of class 3.1C substances with an aggregate quantity of 2,000L must maintain:

  • a 3m separation distance to a protected place under reg 11.30 (Table 6), and
  • a 7m separation distance under reg 11.34 (Table 7).

The required separation distance that will apply is 7m.