This is the first question an inspection puts to a chemical warehouse: does this facility need a Plan, or only Measures? Law on Chemicals No. 69/2025/QH15 divides them by two things: the chemical list and the quantity threshold.
Chemical incident prevention and response Plan (Article 37)
Applies where storage involves chemicals that are on the list and above the threshold in clause 2 of Article 37. The list, and the threshold for the largest quantity stored at any one time, are issued by the Government — they are in Decree 24/2026/ND-CP.
- The project owner must build the Plan during project preparation and may store chemicals only after the Plan has been approved (point a clause 1);
- The organisation or individual managing and operating the facility must have the Plan approved before carrying out storage (point b clause 1).
Chemical incident prevention and response Measures (Article 38)
Applies to storage of hazardous chemicals not covered by clause 1 of Article 37. Measures only need to be issued, not approved.
- The project owner builds the Measures during project preparation and may store only after the Measures have been issued (point a clause 1);
- The organisation or individual operating the facility must build and issue the Measures before carrying out storage (point b clause 1);
- ★ Before transporting hazardous chemicals, the transporting organisation or individual must build and issue Measures for transport and carry them throughout the journey (point c clause 1).
That last point is often missed: the transport Measures are a separate document, and they have to be on the vehicle.
What happens after you have one (Article 39)
- Fully implement the contents of the approved Plan or issued Measures (clause 1);
- On expansion of scale or a change of production line or equipment for production, use or storage, the document must be amended. The changed items may only be put into operation after the Plan is approved or the Measures are issued (clause 2);
- Update the Plan or Measures into the specialised chemical database (clause 4).
Transition
A Plan already approved and Measures already issued before the Law took effect may continue to be implemented as they are (clause 4 of Article 48).
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