The Regulatory Reform (Fire Safety) Order 2005 (RRO) is the primary piece of fire safety legislation for non-domestic premises in England and Wales. For any business that stores chemicals — whether solvents, acids, flammable liquids, or oxidising agents — understanding what the RRO requires is not optional. Non-compliance can lead to prohibition notices, unlimited fines, and in serious cases, imprisonment for up to two years.
This article explains how the RRO interacts with chemical storage and the practical steps responsible persons must take to remain compliant.
Who Does the RRO Apply To?
The RRO applies to virtually all non-domestic premises in England and Wales, including:
- Factories, warehouses, and industrial units
- Offices, retail premises, and hospitality venues
- Educational and healthcare establishments
- Construction sites and temporary structures
- Vehicles used as workplaces (in some circumstances)
The responsible person — typically the employer, building owner, or occupier — has a legal duty to carry out a fire risk assessment and implement appropriate fire precautions. This duty cannot be delegated away; if you are in control of a premises, you are legally responsible.
Fire Risk Assessment: The Foundation of Compliance
Under Article 9 of the RRO, the responsible person must carry out and regularly review a suitable and sufficient fire risk assessment. Where chemicals are stored, this assessment must specifically consider:
- The identity and quantity of chemicals stored on site
- The fire and explosion hazards each chemical presents (consult Safety Data Sheets)
- The location of chemical stores relative to ignition sources, escape routes, and occupied areas
- The adequacy of ventilation, fire detection, and suppression systems
- The emergency response arrangements for a chemical fire or explosion
Where five or more people are employed, or where a licence is held, the significant findings of the fire risk assessment must be recorded in writing.
Chemical Storage Requirements Under the RRO
The RRO does not prescribe specific storage standards for chemicals — instead, it requires that all reasonably practicable measures are taken to prevent fires and limit their spread. In practice, this is interpreted by reference to HSE guidance, British Standards, and sector-specific codes of practice.
| Chemical Type | Key Hazard | Primary Storage Requirement |
|---|---|---|
| Flammable liquids (Class I-III) | Fire and explosion | Flammable storage cabinet, bunded area, away from ignition sources |
| Oxidising agents | Accelerate fires | Segregated from flammable materials, cool and dry location |
| Corrosive acids and alkalis | Container integrity failure | Bunded storage, secondary containment, compatible materials |
| Aerosols (flammable propellant) | BLEVE (boiling liquid expanding vapour explosion) | Metal cage, away from heat, limited quantities on shelving |
| Compressed gas cylinders | Explosion, fire acceleration | Chained upright, segregated by type, outdoors or ventilated store |
Segregation and Containment
A fundamental principle of safe chemical storage is segregation — keeping incompatible chemicals physically apart so that if one is involved in a spill or fire, it cannot react with another to create a greater hazard. Mixing oxidising acids with flammable solvents, or chlorine-based products with ammonia compounds, can produce toxic gases or trigger violent reactions.
Segregation should be achieved through physical separation (separate rooms, buildings, or bays), the use of secondary containment, and clear labelling and signage. A chemical spill tray beneath each storage location is a minimum precaution; for larger volumes, a fully bunded chemical store is the appropriate solution.
Emergency Arrangements and Spill Response
Article 15 of the RRO requires the responsible person to establish and maintain emergency procedures. Where chemicals are stored, this must include procedures for:
- Immediate response to a chemical spill or fire
- Evacuation of the premises, including assembly points
- Contacting emergency services and providing them with hazard information (e.g. HAZCHEM cards, Safety Data Sheets)
- Containing and cleaning up spills to prevent fire ignition
Having the correct chemical spill kits positioned near storage areas is a critical part of your emergency arrangements. Staff must be trained in their use and the kits must be inspected regularly to ensure they are fully stocked and accessible.
Interaction with DSEAR and COSHH
The RRO does not operate in isolation. Where chemicals stored on site are also flammable or explosive, the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) will also apply. Where they present health hazards, COSHH must be addressed. A thorough compliance programme integrates all three — the fire risk assessment, the DSEAR risk assessment, and the COSHH assessment — into a single coherent document.
HSE guidance on chemical storage and fire safety is freely available and should be consulted when drafting or reviewing your risk assessments.
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