Which rules apply to major-hazard chemical sites in Iraq?

We found no Iraqi law equivalent to the EU Seveso III directive: no qualifying quantities, no safety report and no public information duty for major-hazard sites. Such sites are governed by general rules: the OSH duties of the Labour Law No. 37 of 2015, including emergency planning and annual inspection of pressure and lifting equipment, and the Law No. 27 of 2009 on the Protection and Improvement of the Environment, which requires an environmental impact report covering emergency cases and controls dangerous chemicals.

Short answer

• No Seveso-type regime identified: no tiers by inventory, no major-accident prevention policy or safety report required by law.
• Labour Law No. 37 of 2015: protection against all hazards, emergency plan management, annual inspection of steam boilers, pressure equipment, lifts and lifting gear by bodies authorised by the National Centre for Occupational Health and Safety, OSH licence from the Centre (Article 114(2)).
• Law No. 27 of 2009: environmental impact report before a project or expansion, including emergency pollution cases and precautions (Articles 10 and 12); Ministry of Environment approval for activities affecting the environment (Article 11); controls on producing, importing, storing and transporting dangerous substances and duty to notify accidental releases (Article 20); oil and gas exploration and production operators report fires, explosions, leaks and pipeline accidents (Article 21).
• ILO Convention No. 174 (major industrial accidents): check its status for Iraq on ILO NORMLEX.
• Practice: operators apply their own process safety standards (HAZOP, safety instrumented systems, management of change), often modelled on Seveso, OSHA process safety management or company standards.

The legal pieces in detail

The Labour Law No. 37 of 2015 (قانون العمل رقم 37 لسنة 2015) requires the employer to take all necessary measures for effective protection against occupational hazards, to have steam boilers, pressure equipment, lifts and lifting gear inspected every year by bodies authorised by the National Centre for OSH, to verify the safety of dangerous machinery through reports from authorised bodies, and to oversee the organisation of emergency plan management (Article 114(2)). The Centre grants an OSH licence to the enterprise after checking the safety requirements.

The Law No. 27 of 2009 on the Protection and Improvement of the Environment (قانون حماية وتحسين البيئة رقم 27 لسنة 2009) requires an environmental impact report before a project is established, covering positive and negative impacts, emergency pollution cases and preventive precautions, and less harmful alternatives (Article 10); this also applies to existing facilities and expansions (Article 12). Activities that affect the environment need the Ministry's approval (Article 11). The law allows national registers of dangerous chemicals and wastes (Article 19), prohibits producing, transporting, importing or storing dangerous substances without the procedures set in the rules in force, requires the owner to notify the Ministry of any accidental release of dangerous substances to the environment, and requires official approvals for dangerous wastes (Article 20). Oil and gas exploration and production operators must report to the Ministry of Environment the causes of fires, explosions, leaks and pipeline accidents and the measures taken (Article 21). Penalties include suspension or temporary closure after a 10-day warning, fines and imprisonment, doubled for repeat offences (Articles 33 to 35).

Comparison with the EU and Türkiye

Türkiye implements Seveso III through the Regulation on the Prevention and Mitigation of Major Industrial Accidents (Büyük Endüstriyel Kazaların Önlenmesi ve Etkilerinin Azaltılması Hakkında Yönetmelik, known as BEKRA).

A practical approach for a major-hazard site in Iraq

Example: An investor plans an LPG storage and filling plant near Baghdad. Iraqi law requires an environmental impact report with emergency scenarios, Ministry of Environment approval of the activity, an OSH licence from the National Centre for OSH, annual inspection of the pressure vessels and the emergency plan. To manage the actual major-accident risk, the investor also applies a Seveso-style approach: inventory check against Seveso thresholds as a benchmark, HAZOP, consequence modelling for fire and explosion, safety instrumented systems, hazardous area classification and Ex equipment, and an external emergency plan agreed with the civil defence authorities.

At a 2022 workshop in Basra held by IndustriALL Global Union with the ILO and trade unions, participants described the OSH situation in the southern oil and gas sector as alarming and pointed to gas emissions from extraction, which shows why many operators go well beyond the legal minimum.

Common mistakes

• Treating the environmental impact report as a full major-accident safety case.
• Forgetting the yearly statutory inspection of pressure equipment by an authorised body.
• Not coordinating the emergency plan with the local civil defence and health services.

Related on excodex

• Occupational safety and health in Iraq: law, authorities and employer duties
• Seveso III: major-accident prevention, tiers and duties
• How are explosive atmospheres and Ex equipment regulated in Iraq?
• BEKRA: major industrial accidents regulation in Türkiye

Standards and further reading

• Labour Law No. 37 of 2015 (قانون العمل رقم 37 لسنة 2015), Article 114; unofficial English translation: alnoor.edu.iq
• Law No. 27 of 2009 on the Protection and Improvement of the Environment, Articles 10 to 12, 19 to 21, 33 to 35: faolex.fao.org
• ILO, OSH in the Iraqi oil and gas sector (November 2022): ilo.org
• IEC 61511: functional safety, safety instrumented systems for the process industry.

This article is general occupational safety and health information prepared by the excodex editorial team. It does not replace the applicable legislation, standards, manufacturers' instructions or the assessment of a competent OSH professional or occupational physician.