Warehouse Discipline for Packaged Refrigerants: Separation Rules, Stacking and the Records That Trace a Cylinder Back to Its Lot (GB 15603)
· QUZHOU HUAFU NEW REFRIGERATION MATERIAL CO., LTD.
An auditor judges a refrigerant warehouse on three separate layers — separation, stacking and records. A strong answer on one does not cover the others, and the third is the layer most sites cannot put together on the day.
1. Three layers, not one
A bay full of cylinders is assessed on three questions that are decided by different rules:
| Layer | Question | Instrument (China) |
|---|---|---|
| Separation | What may not share space with what | GB 15603-2022 §5 storage requirements, and its normative compatibility annex |
| Stacking and handling | What may be obstructed, and how the cylinder may be moved | GB 15603-2022 §6; GB/T 34525-2017 |
| Records | Can a cylinder in the bay be traced to a lot, and a lot to a certificate? | GB 15603-2022 §7 incoming, §8 in-store, §9 outbound |
GB 15603-2022 (General rules for the hazardous chemicals warehouse storage) has been in force since 1 July 2023 and replaced GB 15603-1995.
⇒ The rules for the cylinders themselves — what may be stored next to what, how hot it may get, and how full cylinders are treated against empty ones — are set out in cylinder storage and segregation. This article is about the management layer that sits around them, which those rules assume but do not create.
2. Layer one — separation, in two directions
Chemical-to-chemical separation is driven by the dangerous-goods class of the gas, not by the product name. That is the part most storage specifications get right, because the class is stated on the cylinder.
The direction that gets missed is chemical-to-non-chemical: a store holding dangerous chemicals is not a store for food, feed or medicines. The reason is not paperwork. Refrigerant vapours are heavier than air, so a leak settles rather than disperses, and the common grades carry little or no odour — none of it reliable. A small, continuous leak is not something smell will reveal; the safety data sheets describe the odour as slight, and one honest consequence follows: detection has to rest on instruments, inspection and records, not on the nose. A leak that reaches a food or feed store is a contamination event that cannot be repaired by relabelling anything.
Food as an exclusion class is not a transport rule carried across into the warehouse: it is stated directly for storage in the Food Safety Law (《食品安全法》). Article 33, paragraph 1, item (6) requires that the containers, tools and equipment used to store, transport and handle food be safe, harmless, clean and protective against contamination, and that food is not stored or transported together with toxic or harmful substances. The second paragraph of the same article extends that requirement to businesses that are not food businesses, wherever such a business stores, transports or handles food — which is the position of a warehouse that holds a food or feed consignment under the same roof as hazardous chemicals. The road-transport rule points the same way and supports the same conclusion: a dedicated dangerous-goods vehicle may not carry food, daily necessities, medicines or medical devices.
⇒ The practical test: can you name every category of goods stored under the same roof as the cylinders — including bagged feed, packaging materials, cleaning chemicals and anything held for a third party? A “corner” of non-chemical goods inside a dangerous-goods store is a finding, not a detail.
3. Layer two — stacking and handling
| Requirement | Why it exists |
|---|---|
| Relief device not obstructed by stacking, pallets or debris | A blocked relief device removes the last pressure safeguard — see filling ratios and temperature compensation |
| Stacking height limited by the container, not by what the pallet will take | A cylinder is a pressure vessel, and it is the vessel that carries the load when stacked |
| Packaging raised off the floor — except for steel drums of 200 L and above and for gas cylinders, packaging may not rest directly on the ground; the dunnage is not less than 10 cm (GB 15603-2022 §6.2.2) | Moisture and corrosion at the base, and the base is where a cylinder wall is thinnest |
| Stack height follows the packaging mark — where the packaging carries no stacking mark, the stack is not more than 3 m high, excluding pallets (GB 15603-2022 §6.2.3) | The mark states the load the packaging is designed to carry |
| Clearances maintained — main aisle, from walls, from columns, between stacks, and clear of lighting | Inspection access, so a leak can be found, and distance from heat and ignition sources |
| No rolling, dragging, dropping or impact; correct lifting points | GB 15603-2022 §6 requires handling methods that do not damage the goods; §6.1.4 requires gas cylinders to be loaded, unloaded and handled in line with GB/T 34525 |
| Out-of-test cylinders kept out of the storage bay | A cylinder past its requalification date must not be filled; mixed into the bay, that fact becomes invisible — see retest and requalification |
| Full and empty kept apart, and marked as such | Residual vapour means an “empty” cylinder is still a cylinder of that class |
The clearances are not left to site judgement. GB 15603-2022 §6.2.5 fixes them, and GB 15603-2022 is a mandatory national standard — so the clause is not a recommendation:
| Clearance | Minimum |
|---|---|
| Main aisle (主通道) | ≥ 200 cm |
| Wall distance (墙距) | ≥ 50 cm |
| Column distance (柱距) | ≥ 30 cm |
| Stack distance (垛距) | ≥ 100 cm, with the footprint of any one stack not more than 150 m² |
| Lamp distance (灯距) | ≥ 50 cm |
⇒ A number beats the word “sufficient”. Where a storage specification leaves these to site judgement, the auditor has nothing to measure; where it states them, each value is a line that can be checked with a tape.
⇒ Nothing is opened, split or repacked in the store. GB 15603-2022 §11.3.3 prohibits opening drums, splitting (decanting) and repackaging inside a storage warehouse. That is a boundary worth stating explicitly: splitting a drum or decanting a cylinder belongs to the filling stage, run as a separate operation under GB/T 27550-2011, and not to the warehouse. A warehouse under this framework stores, stacks and records — it does not split product into smaller packages.
⇒ The distinction worth keeping: stacking rules protect the vessel and the people who have to inspect it. They are not primarily about floor-area efficiency, and a site that treats them as a space-planning question is optimising the wrong variable.
4. Layer three — the records
This is the layer that separates a warehouse that can answer a question from one that cannot.
| Moment | Requirement | What it produces |
|---|---|---|
| Incoming | Verify the name, specification and quantity of incoming dangerous chemicals against the documents before they are taken into store (GB 15603-2022 §7) | Goods accepted against a description, not against a note that says “refrigerants” |
| Incoming — packaging and labels | Packaging intact, with its marks and safety labels legible, and a Chinese-language SDS and safety label attached to the goods (GB 15603-2022 §7.4, §7.5) | The goods themselves carry their identity, not only the register does |
| In store | In-store management, with stock records kept current and storage requirements maintained (GB 15603-2022 §8) | A record that describes what is actually in the bay |
| In store — scheduled inspection | Stacking, packaging and the warehouse itself inspected on a schedule, with the result recorded (GB 15603-2022 §8) | A drift in stacking or in packaging is found on a schedule, not after an incident |
| In store — temperature and humidity | Temperature and humidity observed each day, at a frequency set by the properties of the chemicals held and by the local climate, and recorded (GB 15603-2022 §8) | The temperature ceiling is evidenced by readings rather than assumed |
| Outbound | Check the records against the goods before release (GB 15603-2022 §9) | The lot shipped is the lot recorded |
| Batch identity | The lot number carried from the fill record to the COA | A certificate traceable to a cylinder, not to a year |
First-in-first-out by batch, and certificates that carry a lot number, are the practical form of this. ⇒ The test question is not “do you keep records” but “show me the record for these three cylinders” — cylinder number, fill record, lot number, certificate. Those are the same links the receiver works through at delivery (receiving checks), and the entry point is the fill record itself (filling records and lot traceability).
5. What a buyer’s auditor should ask for
| Ask for | What it establishes |
|---|---|
| The licence under which the site may hold stock, and the business mode it names | That the operator stores rather than only transacts |
| A bay plan by class | That separation is designed, not accidental |
| The temperature monitoring arrangement | That the temperature ceiling is managed rather than assumed |
| An extract of the incoming/outgoing register covering the lot supplied | That the lot can be followed through the warehouse |
| Confirmation of what else is stored in the same building | That non-chemical goods, particularly food or feed, are not sharing the store |
| The interval between housekeeping inspections | That the site is inspected on a schedule rather than after an incident |
What we can provide
Our operations run under a hazardous chemicals business licence with storage — the business mode that permits holding stock, as distinct from trading without storage. What we can put into your compliance file is the lot-linked document set: the fill record and lot number for the cylinders shipped, the certificate of analysis issued for that lot, and a packing list stating the UN number, class and net mass per cylinder group, with the classes stowed separately on request.
On the site’s own side of these rules — temperature control, ventilation, inspection schedule and housekeeping — your site’s procedures govern. Where a document is not held, we will say so plainly rather than hand over something adjacent to it.
Contact us with: the products, the package format and the destination, and whether your compliance team needs the records listed in §5 for the lot supplied.
Sources
- GB 15603-2022 — 《危险化学品仓库储存通则》 / General rules for the hazardous chemicals warehouse storage (SAMR/SAC, China) — a mandatory standard, in force 1 July 2023, replacing GB 15603-1995: §5 storage requirements and the compatibility annex; §6 handling and stacking (§6.1.4 cylinder handling under GB/T 34525, §6.2.2 packaging off the floor, §6.2.3 stack height, §6.2.5 clearances); §7 incoming (§7.4, §7.5 packaging and labels), §8 in-store (§8.2 scheduled inspection, §8.3, §8.4 temperature and humidity), §9 outbound; §11.3.3 (no opening, splitting or repackaging in a storage warehouse).
- GB/T 34525-2017 — Safety rules for handling, loading and unloading, storing and using of cylinder (SAMR/SAC, China).
- 《食品安全法》 (Food Safety Law) (National People’s Congress, China) — Article 33, paragraph 1, item (6), and the second paragraph of the same article: food is not stored or transported together with toxic or harmful substances, and the requirement extends to businesses that are not food businesses where they store, transport or handle food.
- 《危险化学品安全管理条例》 — Regulations on the Safety Administration of Hazardous Chemicals (State Council, China) — storage of hazardous chemicals in dedicated warehouses, sites or storage rooms.
- 《道路危险货物运输管理规定》 (Ministry of Transport; current text as amended by the fourth amendment, MOT Order No. 6 of 2026, in force 20 March 2026) — dedicated dangerous-goods vehicles; a dedicated vehicle may not carry food, daily necessities, medicines or medical devices together with dangerous goods.
- GB/T 16483-2008 — 《化学品安全技术说明书 内容和项目顺序》 (SDS content and order of sections).
- Vapour relative density (heavier than air) as stated on the safety data sheets held for R22, R134a and R410A (relative vapour density, air = 1, is greater than 1 for all three).
Prepared by Quzhou Huafu New Refrigeration Material Co., Ltd — a warehousing and filling operation (storage and cylinder filling/repacking), not a manufacturer. The warehouse and storage values quoted above reference public frameworks; the values that apply to a particular site, and the licence scope of any particular site, remain subject to local regulation and to that site’s own approvals.
Need current specs, quota status, or a mixed-load quote for Separation Rules, Stacking and the Records That Trace a Cylinder Back to Its Lot (GB 15603)? Contact tom@hufluor.com with your spec & destination port.