What does RD 840/2015 cover?
Royal Decree 840/2015 implements Spain’s framework for preventing major accidents involving dangerous substances and limiting their consequences. The European Commission’s Seveso overview explains the EU context: prevention, preparedness, inspections and public information form part of the industrial safety framework.
Assess the establishment against Annex I, including hazard categories, named substances, quantities present or likely to be present and the applicable summation rules. A single product below its individual threshold does not, by itself, settle the assessment.
Lower-tier and upper-tier establishments
Article 3 distinguishes lower-tier and upper-tier establishments by reference to Annex I. Obligations include notification, prevention policy and internal emergency planning. Upper-tier establishments also require a safety report; regional authorities prepare external emergency plans subject to the decree’s provisions.
The Commission’s guidance and linked resources provide a useful English-language starting point. For a Spanish site, confirm the procedure and competent authority in the autonomous community where it is located.
The boundary with dangerous goods transport
Article 2.2(c) excludes transport and directly related intermediate temporary storage, including specified loading, unloading and transfer activities outside establishments covered by the decree. It does not establish a blanket exemption for every warehouse described as a logistics facility.
Document where the activity occurs, who controls it and whether storage is directly connected to transport. Review the site assessment and the road operation separately; see our RD 97/2014 road transport guide. An ADR transport classification or exemption alone does not determine the establishment’s Seveso status.
Prepare a useful site and transport brief
For an initial discussion, assemble:
- The Spanish site address, operator and a plan showing storage and loading areas.
- A substance and mixture inventory, current safety data sheets, hazard classifications and maximum expected quantities.
- The purpose and duration of storage, transfer arrangements and the parties responsible for each activity.
- Existing notifications, safety reports and emergency plans, where available.
Explain planned changes as well as current operations: a new product, larger inventory or altered loading arrangement can change the questions that need assessment.
Contact DGSA to discuss the dangerous goods transport interface in English. This allows the transport work to be scoped alongside the establishment operator’s industrial safety assessment and the competent authority’s requirements.
Discuss your operation in Spain
Tell us which goods, activities and transport stages are involved. We will discuss the scope of the advice or training you need.