After production Fertilizers are stored either in packed form (50 kg bags, big-bags) or in bulk before they are sent to the customers. Tests are performed to check the quality and safety aspects and the bags are labeled and providing proper information during transport and to the customer. Bulk fertilizers are accompanied with papers providing the necessary information.
Storage of Fertilizers, non-conforming materials, and intermediate storage of raw materials (ammonia, phosphoric acid, sulphuric acid, nitric acids, fillers, additives) is assessed and best practices for loading, filling and storage should be in place.

Batch traceability
Regulation 2003/2003/EC of the European Parliament and of the Council of 13 October 2003 relating to fertilisers.OJ304/1 20-11-2003

Product liability
EU Council Directive 85/374/EEC of 25 July 1985 OJ L 210, 7.8.1985. p.29 on the approximation of the Laws, regulations and administrative provisions of the Member States concerning liability for defective products.

Directive 1999/34/EC of the European Parliament and of the Council amending Council Directive 85/374/EEC on the approximation of the Laws, regulations and administrative provisions of the Member States concerning liability for defective products.

Commission Green Paper Liability for Defective Products 2-07-1999 COM (1999)396 final

Second Report From the Commission on the Application of Directive 85/374 on Liability of Defective Products COM(2000)893 final. 31.1.2001

Third Report from the Commission to the Council, the European Parliament and the European Economic and Social Committee - Third Report on the application of Council Directive on the approximation of laws, regulations and administrative provisions of the Member States concerning liability for defective products (85/374/EEC of 25 July 1985, amended by Directive 1999/34/EC of the European Parliament and of the Council of 10 May 1999) COM/2006/0496 final

General Product Safety

Council Directive 92/59/EEC of 29 June 1992 on general product safety.

Directive 2001/95/EC of the European Parliament and the Council of 3 December 2001 on general product safety. OJ L11 15.1.2001 page 4.

RAPEX
Council Decision 84/133/EEC of 2 March 1984 introducing a Community system for the rapid exchange of information on dangers arising from the use of consumer products.

Council Decision 89/45/EEC of 21 December 1988 on a Community system for the rapid exchange of information on dangers arising from the use of consumer products.

Amendment of Directive 89/45/EC by Council Decision 90/352/EEC of 29 June 1990.

Council Decision 90/651/EEC of 4 December 1990 on the adaptations necessary in the context of German unification to the Community system for the rapid exchange of information on dangers arising from the use of consumer products.

Council Decision 93/580/EEC of 25 October 1993 concerning the institution of a Community system for the exchange of information in respect of certain products which may jeopardize consumers' health or safety.

Waste

European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste. OJ L365, 31-12-1994 p10

Proposal for a Directive of the European Parliament and of the Council, amending Directive 94/62/EC on packaging and packaging waste COM(2001)729 final OJ C103 30-04-2002

Directive 2004/12/EC of the Parliament and of the Council of 11 February 2004 amending Directive 94/62/EC on packaging and packaging waste.OJ L47/26 18.2.2004.

Commission communication in the framework of the implementation of the European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste. OJ C44 19-2-2005 p23 (2005/C44/13)

Directive 2005/20/EC of the European Parliament and the Council of 9 March 2005 amending Directive 94/62/EC on packaging and packaging waste. OJ L70/17 of 16-03-2005 page 17-18.

Commission Decision 2005/270 EC of 22 March 2005 establishing the formats relating to the database system pursuant to Directive 94/62/EC of the European Parliament and of the Council on packaging and packaging waste. OJ L86 of 5 April 2005 p6.

Guidance for Safe Handling and Use of Non-conforming Fertilizers and Related Materials.2003

Guidance for Safe Handling and Utilization of Non-conforming Solid Fertilizers and Related Materials for Fertilizer Importers, Distributors and Merchants.2004

EFMA's Recommendations for Safe Storage and Handling of Wet Process Phosphoric Acid 1990

EFMA issued Guidelines for Transporting Nitric Acid in Tanks.1998

Leaflet Fertilizers and fire

EFMA's leaflet short version Guidance for Handling Non-conforming Ammonium Nitrate Based Fertilizers in Distribution Chain 2005.( In 5 languages).

EU Best Available Technique Reference Document on Emissions for storage (Final Bref August 2007 ).

EFMA's Guidance For The Storage of Hot Ammonium Nitrate Solutions, 2005

Guidance for Transporting Ammonia by Rail (2007) English

Richtlinien Für Den Schienentransport von Ammoniak (2007) German

Guidance for the Storage, Handling and Transportation of Solid Mineral Fertilizers (2007)

EFMA' s Guidance for Inspection of Atmospheric, Refrigerated Ammonia Storage Tanks, 2008

Loading and filling of solid fertilizers/ additives

• Warehouses
• Ships and barges
• Road Trucks
• Rail wagons

There are no EU regulations concerning loading and filling of warehouses/barges road trucks and rail wagons with solid fertilizers. Guidance for the Storage, Handling and Transportation of Solid Mineral Fertilizers (2007)gives information on storage (compatibility with other materials, stack height etc.).

The Guidance Relating to Sea Transport of Ammonium Nitrate Based fertilizers, 2003 gives information on loading and transport of AN based fertilizers by sea.

Further reference is made to the relevant chapter 7 in ADR, RID, IMDG and ARDN regarding provisions concerning loading, unloading, handling and transport.

Loading and filling of storage tanks

• Phoshoric Acid
• Nitric Acid
• Sulphuric acid
• Ammonia
• Ammonium nitrate

Recommendations for Safe Storage and Handling of Wet Process Phosphoric Acid are given in EFMA's booklet from 1990

In 2002 EFMA issued the Recommendations for safe and reliable inspection of atmospheric, refrigerated ammonia storage tanks. This booklet contains information on the commissioning, decommissioning and recommissioning of ammonia storage tanks. The booklet has been revised in 2008. Guidance For Inspection of Atmospheric, Refrigerated Ammonia Storage Tanks.

Do you want to evaluate your own ammonia storage tank?

Appendix 2:Risk Based Inspection Evaluation ExcelSheet

Guidance for the storage of hot ammonium nitrate solutions was issued in 2005

Loading and filling of Rail Tank Wagons

• Ammonia
  Guidelines for the transport of ammonia by rail see 3.1.6.10 EFMA's Guidance for Ammonia Transport by Rail,2007

• Nitric Acid

          In 1998 EFMA issued Guidelines for Transporting Nitric Acid in Tanks. The booklet contains information on loading and unloading operations.

Loading and filling of Road trucks.

• Ammonia
• Nitric acid

  In 1998 EFMA issued Guidelines for Transporting Nitric Acid in Tanks. The booklet contains information on loading and unloading operations.

Batch traceability

Batch traceability is necessary in order to trace back the material in all stages of the product life chain for reasons of :

Documented procedures should be implemented for identification and documentation of the materials that are used for manufacturing of a fertilizer. The quality of the fertilizers being manufactured should be confirmed. The identification of products stored on the site should be laid down in a procedure. There should be a procedure for book-keeping of the amount of fertilizers in store and a log is kept customers and destination of shipments form the site.

EU Legislation on batch traceability

The existing EU fertilizer legislation has been revised: Regulation of the European Parliament and of the Council relating to fertilizers" mentions in Article 8 :Traceability
" Without prejudice to Article 26 (3), the manufacturer shall, to ensure traceability of EC fertilizers, maintain records of the origin of the fertilizers. These records shall be available for inspection by Member States for as long as the fertilizer is being supplied to the market and for a further period of 2 years after the manufacturer stopped supplying it".

In addition this regulation gives provisions for batch identification (markings Article 9, labeling arcticle 10 and languages (article 11))

• ISO 9000; detonation certificate; analytical tests
• Responsible care
  

Guidance on how to implement

• Batch process versus batch definition in continuous process
• Correct batch definition reference to correct batch
• Batch identification system: date of manufacture, production unit, order numbers, delivery date etc.
• Adequate records product and non-conform

Product liability

Product Safety and Liability in Europe
The European Commission has taken steps to reform the product safety and product liability regimes as part of its wider program of enhancing consumer protection.

Existing program.
The EU General Product Safety (GPS) Directive (92/59/EEC) aims to prevent unsafe products from reaching the market. It ensures EU member states to prevent that producers and distributors place only safe products on the market.

The EU Product Liability (PL) Directive (85/374/EEC) confers legal rights on consumers, allowing them to sue producers of defective products which cased them injury or loss. Producers include manufacturers of the product in question or of the raw materials from which it is manufactured, own branders, and anyone who imports the product into the EU.

The reform program
On 3 December 2001, a new EU GPS Directive (2001/95) became law. Implementation by Member States has to be done until 15 January, 2004, from which date the old 1992 GPS Directive will be repealed.

Major differences with the old Directive are:
- Notification by all parties in the supply chain to regulators if a product becomes unsafe
- Increased monitoring obligation (effective product tracking systems, investigation of complaints, maintaining adequate record).
- New product packaging requirements (product references/ batch numbers, other information allowing identification)
- Adequate systems allowing warning customers of product risks (withdrawal form the market)
- Positive obligation on producers and distributors to co-operate with the regulators
- Extension of the earlier Directive to cover the provision of services
- Increased effectiveness of the Rapex system. Creation of a new product safety network of regulators.
- New powers for regulators to order or to arrange for the mandatory recall of products from consumers.
- Power to the Commission to ban exports from the EU of products deemed to be dangerous.
The reform process in relation to the PL Directive, kicked off by the Commission's 1999 Green Paper (COM(1999)396), is making slow progress. The Commission has decided to obtain further information on the operation of the current regime, before pressing forward with its reform program, and has commissioned external research to that effect.

EU Legislation on Liability

EU Council Directive 85/374/EEC of 25 July 1985 OJ L 210, 7.8.1985. p.29on the approximation of the Laws, regulations and administrative provisions of the Member States concerning liability for defective products.

Directive 1999/34/EC Of the European Parliament and of the Council amending Council Directive 85/374/EEC on the approximation of the Laws, regulations and administrative provisions of the Member States concerning liability for defective products.

Commission Green Paper Liability for Defective Products 2-07-1999 COM (1999)396 final

General Product Safety

Council Directive 92/59/EEC of 29 June 1992 on general product safety.

Directive 2001/95/EC of the European Parliament and the Council of 3 December 2001 on general product safety. OJ L11 15.1.2001 page 4.

RAPEX

Contribute to consumer safety and consumer health protection by putting in place an information system on dangerous products.

Council Decision 84/133/EEC of 2 March 1984 introducing a Community system for the rapid exchange of information on dangers arising from the use of consumer products.

Council Decision 89/45/EEC of 21 December 1988 on a Community system for the rapid exchange of information on dangers arising from the use of consumer products.

Amended by Council Decision 90/352/EEC of 29 June 1990.

Council Decision 90/651/EEC of 4 December 1990 on the adaptations necessary in the context of German unification to the Community system for the rapid exchange of information on dangers arising from the use of consumer products

Council Decision 93/580/EEC of 25 October 1993 concerning the institution of a Community system for the exchange of information in respect of certain products which may jeopardize consumers' health or safety.

Risks in storage and handling should be assessed. Proper instructions for operators (own employees and contractors ) should be in place. Personnel should be trained and practices should be checked on a regular basis.
There are no legal requirements related to assessing risk in storage and managing storage operators.

In 2007 EFMA has revised the 1992 Handbook on Safe Storage of Ammonium Nitrate based Fertilizers. The revision is the Guidance for the Storage, Handling and Transportation of Solid Mineral Fertilizers/. .

Guidance for the Storage, Handling and Transportation of Solid Mineral Fertilizers

/

In addition EFMA has drafted the Guidance for Safe Handling and Use of Non-conforming Fertilizers and Related Materials (Producers). This document became available in 2003. In December 2004 a similar document : Guidance for Safe Handling and Utilization of Non-conforming Solid Fertilizers and Related Materials for Fertilizer Importers, Distributors and Merchants has been issued..

EFMA's Guidance for Safe Handling and Use of Non-conforming Fertilizers and Related Materials (Producers).	EFMA's Guidance for Safe Handling and Utilization of Non-conforming Solid Fertilizers and Related Materials for Fertilizer Importers, Distributors and Merchants

A short version of the EFMA's Guidance for Safe Handling and Utilization of Non-conforming Solid Fertilizers and Related Materials for Fertilizer Importers, Distributors and Merchants, covering the main points of the booklet, can be displayed against the wall of a distributor warehouse. This leaflet has been issued in several of the major languages.

An easy to read leaflet on how to act in case of a fire involving Fertilizers in warehouses has been developed by EFMA for storage operators.

EFMA's Leaflet Fertilizer and Fire

A draft final document EU Best Available Technique Reference Document on Emissions for storage(Final January 2005 ) has been made publicly available.

In the production of ammonium nitrate, hot AN melt is stored intermediatetely. In 1985 EFMA issued the Safety Recommendations for the Storage of Hot Concentrated Ammonium Nitrate Solutions, However, based on new insights EFMA has drafted the Guidance for the Storage of Hot Ammonium Nitrate Solutions, 2005 which replaces the first document.

EFMA's Guidance for the Storage of Hot Ammonium Nitrate Solutions. 2005

Selecting packaging to assess hazards and risks and meet legal requirements.

• Dangerous classification for transport
• UN Tests
• Check correct packaging group
• Avoid contamination of products during packaging
• Compatible packaging material fit for purpose
• Ensure that printing on all packaging is correct with respect to
  o Product name
  o Nutrient content
  o Manufacturer identification
  o Storage recommendations
  o Legally required SHE information on labels.
• Filling, closure and inspection before sending
• Receptacles open/close; reuse (check for integrity)

For classification labeling and packaging for marketing and supply see chapter 3.1.5.1.
For classification labeling and packaging for transport see chapter chapter 3.1.6.1.

When packaging is carried out by other operators in the supply chain ensure that correct packaging materials being used and care is taken that printing materials is done in a correct way.

Guidance on how to implement

• Correct classification based on the risk
• Packing group
• Materials of construction (compatibility)
• Design and construction (resistance when dropped from height; safe lifting, way of expected stacking, weather, temperature
• Closures of receptacles repeatable use (prevention of loss of containment)
• Re-use criteria

Guidance for Safe Handling and Use of Non-conforming Fertilizers and Related Materials ( Producers) 2003.

Guidance for Safe Handling and Utilization of Non-conforming Solid Fertilizers and Related Materials for Fertilizer Importers, Distributors and Merchants 2004.

EFMA's leaflet short version Guidance for Handling Non-conforming Ammonium Nitrate Based Fertilizers in Distribution Chain 2005.

Leaflets Fertilizer and Fire

Guidance for the Storage, Handling and Transportation of Solid Mineral Fertilizer (2007) .

INTRODUCTION

Re-use and recycling of primary and secondary packaging should be assessed for two reasons:

• Business requirements for re-use and recycling of packaging material
• Legislative demands which are placed on the industry to increase recovery and recycling rates
  

Legal requirements are in fist instance addressed to the Member States to introduce systems and targets for the return and/or collection of used packaging both producers as well as users are involved. Companies should provide guidance on the re-use, recycling, recovery of waste disposal of packaging material.

Packaging and packaging waste

The packaging and packaging waste directive 94/62/EC repeals the first Council Directive 85/339/EEC of 27 June 1985 on containers of liquids for human consumption since it covers all types of packaging placed on the market and all packaging waste. The objective of the directive is to harmonize measures concerning the management of packaging and packaging waste to provide a high level of environmental protection and to ensure the functioning of the internal market. Though in fist instance addressed to the Member States to introduce systems and targets for the return and/or collection of used packaging both producers as well as users are involved.
An overview is given in the summary document Packaging and packaging waste

European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste. OJ L365, 31-12-1994 p10
On 7 December 2001, the Commission presented a proposal for a directive of the European Parliament and of the Council, amending Directive 94/62/EC on packaging and packaging waste [COM (2001) 729 final - Official Journal C 103, 30.04.2002].

Proposal for a Directive of the European Parliament and of the Council, amending Directive 94/62/EC on packaging and packaging waste COM(2001)729 final OJ C103 30-04-2002

This proposal was finally adapted by Council and Parliament and resulted.in Directive 2004/12/EC of the Parliament and of the Council of 11 February 2004 amending Directive 94/62/EC on packaging and packaging waste.OJ L47/26 18.2.2004.

Key elements of the Directive are:

1. Definition of packaging is given (illustrative examples are given in the annex of the Directive)
2. Prevention is the main goal.
3. Member States: the producer is responsible to minimize packaging
4. Commission should develope suitable EU standards
5. Commission: only new packaging is allowed if the impact on the environment is minimum.
6. Recovery and recycle targets are set:
   

   Recovery or incineration with energy recovery
   <30-06-2001	>50% and <60%wt of packaging waste
   <31-12-2008	>60%
   Recycling
   <30-06-2001	>25% and <45% wt totality packaging waste, min. 15% wt each material
   <32-12-2008	>55% and <80%
   Minimum targets
   Glass	60%
   Paper and Board	60%
   Metals	50%
   Plastic (recycle)	22,5%
   Wood	15%

7. Progress of Implementation monitored by the Commisison on:

• Evaluation effectiveness, implementation and enforcement
• Additional prevention measures and waste prevention plans
• Development of a packaging environment indicator (prevention)
• Encouragement of reuse (reuse versus recycling)
• Producer responsibility
• Phasing out of heavy metals / hazardous substances in packaging by 2010
  

8. Commisison has to make a proposal for the third 5-year phase 2009-2014
9. Commission proposal not later than 31 December 2007

How to implement:

• Review primary and secondary packaging
• Review need for packaging (wrapping materials, pallets etc.)
• Use of recycled material?
• Consider fate of packaging (return, recovery, recycling, incineration, landfill)
• Environmental impact of packaging (heavy metals)
• Reduce quantity
• Change type
• Returnable containers
• Set up recovery schemes (FMA brochure)
• Effect of product residues/ safety aspects.

Publication of titles and references of harmonised standards (CEN) under the directive can be found in:

Commission communication in the framework of the implementation of the European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste. OJ C44 19-2-2005 p23 (2005/C44/13)

In view of the further enlargement of the EU, due attention also needs to be paid to the specific situation in countries for which accession is planned at a later stage. Derogation to the attainment of the targets as refered to in paragraph 1b,1d and 1e are granted to most new accession candidates to 31-12-2012, to 31-12-2013 for Malta, 31-12-2014 for Poland and 31-12-2015 for Latvia. The Directive 94/62/EC has been amended accordingly:

Directive 2005/20/EC of the European Parliament and the Council of 9 March 2005 amending Directive 94/62/EC on packaging and packaging waste. OJ L70/17 of 16-03-2005 page 17-18.

Member States shall provide data using the formats set out in the annex of Directive 2005/270/EC.

Commission Decision 2005/270 EC of 22 March 2005 establishing the formats relating to the database system pursuant to Directive 94/62/EC of the European Parliament and of the Council on packaging and packaging waste. OJ L86 of 5 April 2005 p6.

Training is given and documented for company employees and contractors whenever relevant on:

In response to the increased concern related to terrorism and misuse of fertilizers, EFMA recognises the need for addressing security in production, storage, transportation and sales of fertilizers. Hence, EFMA has updated its Product Stewardship program to cover this important topic in more depth and in accordance with recently expressed demands by the authorities. EFMA's recommendations for security measures are not made available in this description of EFMA's Product Stewardship program. It is available for EFMA members only and is part of the EFMA auditing system for evaluating the adherence to the recommendations amongst the members.

EFMA's recommendations for security measures.

Members Only

Click on logo to access