Final Report Annex 3: Methods For Assessing Environmental .

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Final report Annex 3: Methods for assessingenvironmental consequences (Task 3)Development of an assessment methodology under Article 4 of Directive2012/18/EU on the control of major-accident hazards involving dangeroussubstances (070307/2013/655473/ENV.C3)Report for the European Commission (DG Environment)AMEC Environment & Infrastructure UK Limitedin association with INERIS and EU-VRiDecember 2014

Copyright and Non-Disclosure NoticeThe contents and layout of this report are subject to copyright owned by AMEC( AMEC Environment & Infrastructure UK Limited 2014). save to the extent thatcopyright has been legally assigned by us to another party or is used by AMEC underlicence. To the extent that we own the copyright in this report, it may not be copiedor used without our prior written agreement for any purpose other than the purposeindicated in this report.The methodology (if any) contained in this report is provided to you in confidenceand must not be disclosed or copied to third parties without the prior writtenagreement of AMEC. Disclosure of that information may constitute an actionablebreach of confidence or may otherwise prejudice our commercial interests. Any thirdparty who obtains access to this report by any means will, in any event, be subject tothe Third Party Disclaimer set out below.Third-Party DisclaimerAny disclosure of this report to a third party is subject to this disclaimer. The reportwas prepared by AMEC at the instruction of, and for use by, our client named on thefront of the report. It does not in any way constitute advice to any third party who isable to access it by any means. AMEC excludes to the fullest extent lawfullypermitted all liability whatsoever for any loss or damage howsoever arising fromreliance on the contents of this report. We do not however exclude our liability (ifany) for personal injury or death resulting from our negligence, for fraud or any othermatter in relation to which we cannot legally exclude liability.Document RevisionsNo.DetailsDate1Preliminary version of intermediatereport chapter for DG ENVcomment27 March 20142Intermediate report12 May 20143Intermediate report (revised)21 July 20144Intermediate report (revised)11 Sept 20145Draft final report18 Nov 20146Final report12 Dec 2014December 2014Doc Reg No. 34075CA013i6

ivList of abbreviationsADAMAccident Damage Assessment ModuleADREuropean Agreement Concerning The International Carriage Of DangerousGoods By RoadALARPAs Low As Reasonably PracticableARIAAnalysis, Research and Information about AccidentsATEXExplosive AtmosphereBLEVEBoiling Liquid Expanding Vapour ExplosionBOD – CODBiochemical Oxygen Demand – Chemical Oxygen DemandCECritical EventCFDComputational Fluid DynamicsCLPClassification Labelling PackagingCOMAHControl Of Major Accident HazardsDADeterministic ApproachECHAEuropean Chemicals Agencye-MARSMajor Accident Reporting SystemEUEuropean UnionEWGLUPEuropean Working Group on Land Use PlanningF&EIFire & Explosion IndexGHSGlobally Harmonised SystemJRCJoint Research CentreLPGLiquefied Petroleum GasLUPLand-Use PlanningMAHBMajor Accident Hazard BureauMATTEMajor Accident To The EnvironmentMFMaterial Factor of the Dow’s Fire & Explosion IndexMIMAHMethodology for Identification of Major Accident HazardsNFPANational Fire Protection AgencyNOECNo Observable Adverse Effects ConcentrationPAProbabilistic ApproachPLGPressurised Liquefied GasDecember 2014Doc Reg No. 34075CA013i6

vRIDEuropean Agreement Concerning the International Carriage of DangerousGoods by RailRMPRisk Management PlanSTOT-SESpecific Target Organ Toxicity (Single Exposure)USEPAUnited States Environmental Protection AgencyUVCEUnconfined Vapour Cloud ExplosionPhysicochemical parametersBCFBioconcentration FactorEC50Median Effective ConcentrationΔHrStandard enthalpy of reactionKst / KgMaximum rate of explosion pressure rise for dust clouds/gasLD50 / LC50Median Lethal Dose / Median Lethal ConcentrationLFL / LELLower Flammability Limit / Lower Explosion LimitLOCLimiting Oxygen ConcentrationMIEMinimum Ignition EnergyMTSRMaximum Temperature of the Reaction SynthesisNOECNo Observed Effect ConcentrationPmaxMaximum explosion pressurePvapVapour pressureΔTadAdiabatic temperature riseTebBoiling pointTMRadTime to maximum rate in adiabatic conditionUFL / UELUpper Flammability Limit / Upper Explosion LimitDecember 2014Doc Reg No. 34075CA013i6

viContentsList of abbreviationsiv1.Introduction11.1Purpose of this report11.2Scope of task 311.3Structure of this document22.Approach and initial identification of methods32.1Approach32.2Initial identification of relevant methods43.Details of relevant methods selected for further assessment73.1Overview73.2Czech Republic H&V index73.2.1Description of the method73.2.2Evaluation of robustness and sensitivity113.2.3Assessment of use in the context of Seveso Article 4123.2.4References133.3Sweden environment-accident index133.3.1Description of the method133.3.2Evaluation of robustness and sensitivity153.3.3Assessment of use in the context of Seveso Article 4163.3.4References163.4UK environmental risk assessment approach173.4.1Description of the method173.4.2Evaluation of robustness and sensitivity263.4.3Assessment of use in the context of Seveso Article 4263.4.4References273.5Spain environmental risk assessment approach283.5.1Description of the method283.5.2Evaluation of robustness and sensitivity353.5.3Assessment of use in the context of Seveso Article 4353.5.4References36December 2014Doc Reg No. 34075CA013i6

vii3.6Modelling of releases into water363.6.1Description of the method363.6.2Evaluation of robustness and sensitivity403.6.3Assessment of use in the context of Seveso Article 4403.6.4References413.7Proteus model413.7.1Description of the method413.7.2Evaluation of robustness and sensitivity453.7.3Assessment of use in the context of Seveso Article 4463.7.4References473.8Considerations on releases to air474.Conclusions on available methods494.1Types of available assessment methods494.2Use of methods in the context of Article 451Table 2.1Table 3.1Table 3.2Table 3.3Table 3.4Table 3.5Table 3.6Table 3.7Table 3.8Table 3.9Table 3.10Table 3.11Table 3.12Table 3.13Table 3.14Table 3.15Summary of main identified methods for environmental consequence assessmentDefinition of A Code - toxicityDefinition of B Code – physical propertiesDetermination of index of toxic hazardsDetermination of accident severity category for surface waterDetails of parameters used in EAIRisk sources score categories related to the intrinsic properties of the substancesCriteria for toxicity (Dangerous substances with R codes)Criteria for toxicity (Acute toxicity data in the form of LC50 or EC50 available)Criteria for toxicity (Acute toxicity data not available)Criteria for volatilityCriteria for bioaccumulationCriteria for adsorptionCriteria for biodegradationCriteria for the “quantity” componentCriteria for the frequency component4889101429303031313131323233Figure 3.1Figure 3.2Figure 3.3Figure 3.4Figure 3.5Figure 3.6Figure 3.7Figure 3.8Figure 3.9Figure 3.10Figure 3.11Figure 3.12Example of thresholds for level of harm constituting a MATTEExamples of tables to assess MATTE potentialSeverity of harm criteria for consideration as a major accidentHarm duration categoriesMethod for deriving receptor tolerability for MATTEExample of offsite pathway analysisEnvironmental risk tolerabilityDownstream Concentrations of MDI after a 1min spill of 20 tonnes under different flow conditionsCriteria for tolerability of risk implemented in the Proteus modelIllustration of Proteus methodologyProteus main screenExample of output from Proteus model192122232325343942434445December 2014Doc Reg No. 34075CA013i6

11.Introduction1.1Purpose of this reportThis report forms part of the outputs of a contract for the European Commission on ‘development of an assessmentmethodology under Article 4 of Directive 2012/18/EU on the control of major-accident hazards involvingdangerous substances’. The work has been undertaken by AMEC, INERIS and EU-VRi.The present report concerns one of a number of specific tasks under the project. It should not be read in isolation,but in conjunction with the main report and in conjunction with the reports concerning the other project tasks.1.2Scope of task 3Task 3 of the contract concerns ‘identification of specific models or guidance allowing assessment of theenvironmental consequences of accidents’. The aim was to identify suitable and robust models, methods orguidance on the assessment of environmental consequences of accidents, taking into account that these are less welldocumented in literature than health consequences.The work involved gathering information on the basis of literature research, complemented with a survey anddiscussions with relevant institutions and experienced experts in the field, with a view to obtaining a goodunderstanding of the models and methods.The report describes the models and methods, including details of the outputs that they can generate and includinginformation on their sensitivity, as well as clarifying how they could be used in the context of Article 4 of theSeveso Directive.As set out in the terms of reference, it is recognised that assessment of environmental consequences of accidents iscurrently less developed than for health-related consequences. A key aspect of the scope of work under the presenttask was a focus on the water environment, with toxicity to water understood as being an indicator of the overallenvironmental impact of a substance1. The modelling of impacts upon the environment due to atmospheric releasesare also briefly considered (and linked to modelling approaches in Task 2), as estimating actual impacts via thisroute also poses significant challenges.The idea within the assessment methodology is that one would assess what major accident scenarios are possibleinvolving a dangerous substance, before undertaking any detailed consequence assessment (see the Task 4 report).1This is not to say that impacts on the environment via atmosphere (for example) are not important. However, the models and methods usedto assess such impacts are largely the same as those used to assess toxicity impacts on humans, so they are not reviewed in detail here.December 2014Doc Reg No. 34075CA013i6

2Whether modelling of consequences should be undertaken will depend on factors such as: Whether there are identified major accident scenarios that cannot be ruled out based only on factorssuch as physicochemical properties. Whether modelling will add value to understanding the potential for a major accident. In particular,since exclusion under Article 4 should not take into account site-specific considerations, anymodelling will need to take into account the worst-case conditions across the EU in terms of potentialfor a major accident. This could involve, for example, undertaking many different modellingscenarios.It is important to note that all of the material presented in this report is considered only in the context of theSeveso Article 4 assessment methodology and is not prescriptive. The conclusions drawn do not necessarilyapply in any other contexts. The approaches to consequence and risk assessment considered in this reportare not the only approaches available, and those persons undertaking an assessment under Article 4 coulddecide to adopt alternative approaches where they are better suited to the particular case or substanceunder consideration.1.3Structure of this documentFollowing this introduction, Section 2 provides a brief overview of the approach undertaken to Task 3 of theproject. Section 3 provides details of some of the most relevant methods identified for assessing environmentalconsequences of accidents. Finally, Section 4 draws together some relevant conclusions on the use of thesemethods in the context of Article 4 of the Seveso Directive.December 2014Doc Reg No. 34075CA013i6

32.Approach and initial identification of methods2.1ApproachIn the context of the current task, a distinction is made between assessments that aim to understand the directeffects of accidents on people (not covered by the current task) and effects upon the wider environment i.e. floraand fauna.In order to identify relevant methods for assessment of the environmental consequences of accidents, the followinginformation has been sought/ reviewed: As part of the survey undertaken for the current contract, relevant organisations and individuals wereasked to identify available methods for the assessment of environmental consequences of accidents. A number of existing reviews which each mention several such approaches were considered, such as:- A report comprising one of the outputs of the SHAPE-RISK project2 on ‘management ofenvironmental risks generated by accidents’.- A Portuguese paper3 covering a number of the commonly-applied approaches in Europe.- A document from the European Commission’s Joint Research Centre4 on land use planningguidelines, which also covers a number of methods for environmental consequence assessment. A separate review of relevant literature to identify relevant assessment methods.In general, while there are a number of available techniques for conducting an environmental consequence/ riskassessment, there is often a lack of good quality data on the environment. Furthermore, the environment varieshugely across Europe, with some Seveso establishments being present within internationally protected areas withmany sensitive environmental receptors and multiple pathways for released substances to affect flora and fauna(e.g. freshwater, aquifers); other Seveso establishments are located in much less vulnerable environments.Moreover, the actual environmental characteristics vary substantially, for example in terms of the number, densityand sensitivity of different animal and plant species, meaning that it is challenging to identify a method that cancover all of the potential environmental consequences of an accident involving the many substances subject to theSeveso Directive based on their environmental hazardous properties.2Danielka P (2006): SHAPE-RISK: sharing experience on risk management (health, safety and environment) to design future industrialsystems), synthesis document on WP5 (“Management of environmental risks generated by accidents”),3Velosa JC, Palma MC and Ventura J (2007): Definition of an environmental risk assessment methodology, within the framework of SevesoII directive - application on a case study.4JRC (2006): Land use planning guidelines in the context of Article 12 of the Seveso II Directive 96/82/EC as amended by Directive105/2003/EC, European Joint Research Centre Institute for the Protection and Security of the Citizen.December 2014Doc Reg No. 34075CA013i6

42.2Initial identification of relevant methodsThere are a large number of different methods available and in use for the assessment of environmentalconsequences of accidents. Many of these share very similar characteristics and approaches, but there are distincttypes of methods available. These range from qualitative approaches based mainly on expert judgement, throughvarious approaches based on indexes of environmental consequences, models to predict environmentalbehaviour/ dispersion following accidents, and approaches to assess the environmental risks of accidents.There is no consensus as to which type of approach is most suitable in terms of environmental consequenceassessment, and approaches vary significantly amongst member states, and also amongst individualestablishments/ operators within member states.The table below provides a summary of the main assessment methods identified in the current contract. This is notan exhaustive list but does give a good overview of the main types of approaches adopted.Within the table, a note is made of whether a more detailed analysis has been undertaken (in Section 3 of thisreport).Table 2.1Summary of main identified methods for environmental consequence assessmentMethodWhere mentionedDetailed analysisH&V index (Czech Republic)SurveyYes – Example of an index-basedapproach referred to by severalorganisations (e.g. responses tosurvey).Environmental risk assessment approach (United Kingdom)SurveyYes – Example of a recent (2013)approach to environmental riskassessment.KONTIĆ, Branko, GERBEC, Marko. The role of environmentalaccidental risk assessment in the process of granting developmentconsent. Risk anal., 2009, vol. 29, no. 11, 1601-1614SurveyYes – As an example of generalapproaches to water dispersionmodelling.Schadensbegrenzung bei Dennoch-Störfällen Empfehlungen für Kriterienzur Abgrenzung von Dennoch-Störfällen und für Vorkehrungen zurBegrenzung ihrer Auswirkungen (Germany)SurveyNo – Does not appear to bespecific to environment.Guide for conducting environmental risk analysis peta02/carpeta22/g rarm presen.htm)SurveyYes – Another example of a riskassessment approach, alsoreferred to by respondents fromother member states.N.B. Uses risk*assistant model. Note EA EP154 document.December 2014Doc Reg No. 34075CA013i6

5MethodWhere mentionedDetailed analysisTechnical and operational criteria and guidelines for the assessment ofmajor accidents with environmental consequences ze-per-lambiente)Project workshop (October2014)No – Only identified late in theprojectRapporto conclusivo dei lavori svolti dal Gruppo mistoAPAT/ARPA/CNVVF per l'individuazione di una metodologia speditivaper la valutazione del rischio pe rl'ambiente da incidenti rilevanti indepositi di idrocarburi liquidi. See above for more recent publication.Survey [N.B. a briefdescription in JRC 2006(LUP)]No – Relates to hydrocarbonemissions specifically so unlikelyto be generally applicable.Proteus model es – Example of approach beingapplied widely across a memberstate. Also referred to byrespondents from other memberstates.Reference Manual Bevi Risk Assessments (Netherlands)SurveyNo – Not specific to environmentalconsequencesORDER/FROST software packages for natural gas (mainly) and otherhydrocarbon releases;SurveyNo – Relates mainly to natural gas– not expected to be directlyrelevant to Article 4.DBAM (Danube basin alarm model) limited for the tributaries until the firstreservoir (ICPDR)SurveyNo – Relates to a specificgeographical locationFEAT (Flash Environmental Assessment Tool)SurveyNo – Relates to post-accidentinvestigation.Reban (RIVM, Netherlands)SurveyNo – Understood to have beensuperseded.Swedish FOI simplified hazard indexJRC 2006 (LUP)No – Another example of hazardindex and others alreadyreviewed.Preliminary methodology for the assessment of the global impact of aproduction site, Roberto BubbicoInternal literature reviewNo – Site specific approach, butdoes provide useful examples.Environmental Accident Index (Sweden)Literature review. Alsomentioned f/12sand.pdfYesFrench guideline for pipeline safety report (2012), GESIP (French Oil andChemical Industry Safety Group)http://www.gesip.comNo - Estimation of environmentalimpact is estimated, using a multicriteria approach but is forpipelines, not fixed installations.The purpose of this report, in continuity with previous work (technicalreport APAT / CNVVF no. 57/2005) relating to accidental releases ofliquid hydrocarbons on the ground, is to provide agency systemtechnicians, involved in the checks provided by Legislative Decree no.334/99, as amended (Italian implementation of the "Seveso II" directive)with technical and operational criteria and guidelines to support theanalysis of accidents of possible relevance to the environment and, inparticular, those arising from the uncontrolled release of eco-toxicsubstances in surface water, such as rivers, lakes, coastal waters andmarine waters. For such situations, the document includes technicalelements to address actions applicable in the first phase of emergencymanagement (first 24 hours) to mitigate consequences.Note: Others that were e.g. mentioned in the survey responses but which did not appear to be specifically relevant toenvironmental consequences are not mentioned here. The list does not purport to be a comprehensive list of available methodsfor assessing environmental consequences of accidents.December 2014Doc Reg No. 34075CA013i6

6The methods that were taken forward for more detailed analysis were selected because they were consideredpotentially relevant in the context of Seveso Article 4. However, as shown from the analysis below, it seemsdifficult to specifically recommend any particular method for use in the context of Seveso Article 4. The methodsdiscussed below have been selected because they are considered to give an overview of the different types ofapproaches in use.December 2014Doc Reg No. 34075CA013i6

73.3.1Details of relevant methods selected for furtherassessmentOverviewThe following sections provide an overview of the methods identified in the previous section that were takenforward for more detailed description. As mentioned above, the aim was to provide an overview of the main typesof approaches in use, but inclusion in this section does not constitute a recommendation for the use of theapproaches in the context of Article 4, nor does it imply that these are the most robust or widely used methodsavailable for this type of analysis. The variety of different substances that might be considered under Article 4, aswell as their associated properties, their potential dispersion/ pathways through the environment and effects uponthe range of different ecosystems means that no single method or model available will cover the most appropriateway to assess consequences in all cases.For each of the methods, an overview of the approach is provided based on relevant literature sources describingthe methods. Some conclusions are drawn regarding the robustness and sensitivity of methods and commentary isgiven on the potential use of each method in the context of Article 4 of the Seveso Directive. References used foreach method are included at the end of each subsection.3.2Czech Republic H&V index3.2.1Description of the methodOverviewThe Czech Hazard and Vulnerability Index (H&V Index) is used in the context of Seveso in the Czech Republicand some other member states. It can be used for the assessment and prioritisation of risks in specificcircumstances.Use of the index involves the following key steps: Determining an ‘index of toxic hazard’; Determining and ‘environmental vulnerability index’; Determining the severity of an accident on the environment; and Determining the acceptability of an accident.December 2014Doc Reg No. 34075CA013i6

8Index of toxic hazardThe index of toxic hazard is defined according to four different categories: Index of hazard to biota (TB). Index of hazard to the soil environment (TS). Index of hazard to the water environment (TW). Index of flammability affecting biota (FR).The approach for the water environment is described below. The source documents should be consulted for furtherinformation on the other indices and approaches. Index of hazard to the water environment is defined according totwo parameters: Code A (toxicity) and Code B (physical properties), which are defined in the tables below:Table 3.1Definition of A Code - toxicityLC50 fish (96h)“A” code 0.1 mg/l5Highly toxic0.1 – 1 mg/l4Toxic1 – 10 mg/l310 – 100 mg/l2 100 mg/l1CategoryExtremely toxicModerately toxicSlightly toxicTable 3.2Definition of B Code – physical propertiesCategory“B” codeSolubility 100 mg/l4Liquid4Vapour pressure 0.3 bar at 20ºC2Other1December 2014Doc Reg No. 34075CA013i6

9The index of toxic hazard is then defined by the sum of the A and B codes, as illustrated below.Table 3.3Determination of index of toxic hazardsSum of A B codesToxicity classIndex (TW) 7Extremely high57Very high46High35Medium2 5Low1Vulnerability indexThe next step is the determination of the index of the vulnerability of the environment for a specific situation. Thefollowing parameters are derived: Index of vulnerability of surface water (ISW). Index of vulnerability of groundwater (IUW). Index of vulnerability of soil environment (IS). Index of vulnerability of the biotic environmental compartment (IB).Again taking surface water, the index of vulnerability is defined, using hydrogeological maps (including maps ofvulnerable water bodies), with different scores assigned according to the type of water body of relevance for thespecific site in question, for example: Separate categories are defined for flowing water and standing water. A score of 5 is assigned to standing drinking water. A score of 4 is assigned to peat bogs and wetlands. A score of 3 is assigned to sewage draining to WWTP. A score of 1 is assigned to tailing ponds. Various other categories of watercourse are defined.December 2014Doc Reg No. 34075CA013i6

10Evaluation of toxicity indicesBased on the index of toxic hazard and the vulnerability index, an overall toxicity index is defined for surfacewater, groundwater, soil, the biotic environment, and leakage of flammable substance for the bioticenvironment. Again taking surface water, the index is defined as:3𝐼𝑇𝑆𝑊 𝑚𝑎𝑥 𝐼𝑆𝑊 𝑇𝑊 ; (𝑇𝑊 𝐼𝑆𝑊 𝐼𝑆 )So, for example, a substance with an index of toxic hazard for water (TW) of 3 and a location with an index ofvulnerability for surface water (ISW) of 3 and for the soil environment (IS) of 2, the toxicity index (ITSW) would beeither 3 or 2.62, with the maximum value taken i.e. 3.Determination of accident severity categoryThe toxicity index is combined with the potential amount of the toxic substance that could be released to eachenvironmental compartment to give an accident severity category. By way of example, for surface water, thecategories are defined as follows:Table 3.4Determination of accident severity category for surface waterITSW valueAmount of substance released to surface waters (t) 11-1010-5050-200 2001AABBC2ABCCD3BCCDE4BCDEE5CDEEESo, for a substance with an ITSW value of 3 which could be released in a quantity of 80 tonnes (e.g. the capacity of arelevant vessel), the accident severity category would be ‘D’. The five categories are defined as follows:A negligible impactB low impactC considerable impactD very marked impactE maximum impactDecember 2014Doc Reg No. 34075CA013i6

113.2.2Evaluation of robustness and sensitivityThe H&V index approach seems to provide a useful method for screening of substances (toxicity andphysicochemical properties likely to lead to notable concentrations in the environment), as well as establishmentlocations (in terms of vulnerability) and the potential significance of an accident taking into account the quantity ofinventory released. In the context of Seveso implementation in general, it therefore provides a useful tool to assistwith prioritisation of substances and establishments. It takes into account a variety of environments includingsurface water, groundwater, soil and the biotic environment, and takes into account impacts of leakage offlammable substances upon the biotic environment, as well as toxic effects.However, the method itself does not give any indication of the potential consequences of an accident involving thesubstance under investigation, in terms of the receptors that may be affected and the degree to which they may beharmed. (For example, it does not indicate the spatial spread of adverse effects or the extent to which differenttypes of organisms would be harmed as a result of a release, or duration of effects.) As recognised by the authorsof the method, it is therefore to be seen as a first step, leading to further investigation of those situations that haverelatively higher potential for significant consequences.The index calculated is reliant upon information on the specific environment around a Seveso establishment. In thecontext of Article 4 (aimed at EU wide situations), a more generic approach would be required in order to cover therange of different establishments in which a substance could potentially be used. One option, therefore, would beto assume the worst case vulnerability situation (i.e. that the 'vulnerability index' for each environmental medium is5) and then calculate the index for the substance of interest.Taking into account the types of substances relevant in the context of Seveso (Annex I Part 1), the toxicity indexcould be calculated as follows, in order to estimate the lowest potential value of the index for an accident involvinga Seveso-relevant substance with the aforementioned worst-case assumptions on vulnerability: Toxicity category A code 3 based on LC50 of 1-10 mg/l (e.g. aquatic chronic toxic category 2substance5). Toxicity category B code 1 (e.g. a solid with low solubility and low vapour pressure would have thelowest score here). This gives an overall index of toxic hazard (TW) of 1, which is the lowest category based on Table3.3. Assuming vulnerability index (e.g. ISW and IS) of 5 to represent the most vulnerable EUenvironments, the minimum overall toxicity index (ITSW) is 3 based on the equation above.Substances in Category E2 of Seveso (aquatic chronic toxic category 2) could be assumed to have an “A code” of 3 (i.e. LC 50 fish (96h) of1-10 mg/l in the table above) as this corresponds with the CLP Regulation for classification as Chronic 2 in cases where adequate chronictoxicity data are not available (Annex I, Table 4.10, part iii). Other Seveso-relevant substances would have higher aquatic toxicity and sowould have a higher “A code”.5December 2014Doc Reg No. 34075CA013i6

12 However, with a maximum inventory releas

F&EI Fire & Explosion Index GHS Globally Harmonised System JRC Joint Research Centre LPG Liquefied Petroleum Gas LUP Land-Use Planning MAHB Major Accident Hazard Bureau MATTE Major Accident To The Environment M F Material Factor of the Dow’s Fire & Explosion Index MIMAH Methodology for Identification of Major Accident Hazards

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