DSEAR and ATEX Legislation and Risk Assessment

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The ATEX 137 Directive was formally adopted into law in the UK in 2003 and requires that all companies operating with areas, (including those containing ammonia refrigeration plant), classified as ‘Hazardous’ classify their production areas into zones and assess the risks both to their employees and their plant assets.  So why are we still getting enquiries from people asking “…What is DSEAR all about, and does it apply to me…?”

Maurice Young Consulting believes there are several underlying reasons behind this:

Firstly, some people have found it difficult to understand the standards that support the legislation, particularly those associated with non-electrical ignition sources. It’s one thing to have to spend money on achieving compliance, another if you misinterpret the requirements of the legislation and end up spending money and still find that you are not compliant. Unfortunately, lack of understanding of the requirements is no excuse for lack of action in the eyes of the HSE, and indeed the insurance companies. Certain aspects of DSEAR/ATEX can appear confusing, but this legislation is all about personnel safety, allowing the workforce to understand the issues associated with their place of work, and ensuring that the number of accidents and injuries to persons operating in these industries is reduced.

Secondly, the HSE is putting a higher priority on health and safety of operations involving flammable materials.   In fact, the HSE have already started to bring prosecutions to court for non-compliance with DSEAR/ATEX, (and have a 100% conviction record to date).  Whilst this is enough of an incentive for most organisations to get moving towards compliance at the earliest opportunity, there are still some who prefer to ‘stick their heads in the sand’, and hope that the HSE doesn’t come knocking on their door..!

So how can Maurice Young Consulting help…?

Maurice Young Consulting have successfully supported a number of well-known clients through the compliance process for the ammonia refrigeration plants with the minimum of disruption and cost.  This has all been achieved by following a scalable and phased approach to compliance developed by our in house specialists.

Whilst all clients are in a different position in relation to DSEAR/ATEX compliance, there are a number of common steps that can be applied to the compliance process.  With this in mind we have developed a simple phased approach designed to:

  • Minimise the costs
  • Make the cash flow predictable by spreading expenditure into ‘bite sized pieces’
  • Allow the client to develop his understanding of the compliance issues.
  • Demonstrate to the HSE that the client understands the compliance process and is moving forward in a logical fashion.

The following is a typical approach to compliance, and has been included here to demonstrate what activities may be associated with the various phases:

Gap Analysis

This generally involves 1 or 2 days on site, reviewing the client’s ammonia plant installations, understanding the processes and talking to maintenance and operational personnel. The output from this process is a report detailing the client’s current position and highlighting any critical issues, an outline of the on-going compliance project (a compliance strategy), and indicative costs for the next recommended phase of work (if required).

Phase 1 – Key Compliance Activities/Documents

This phase concentrates on the key compliance activities and associated documentation:

Hazardous Area Classification – This involves the quantification of any hazardous areas and starts with a review of COSHH/material data sheets in order to ensure an inventory of flammable materials has been created. The process then moves on to review the storage and use of any ammonia on site, and then formally assigns the appropriate hazardous area zones and extents. The output of this exercise is a report and assisting the client in preparing a set of drawings.

DSEAR Risk Assessment – This is a thorough review of the process operations carried out on the plant(s).  It is designed to highlight any risk associated with these operations, and examines the validity of any risk reduction measure put in place.  The output of this exercise is a report detailing the review process and highlights any improvements necessary to reduce risk to an acceptable level.

Explosion Protection Document – This document, (EPD), is a vital part of the compliance process.  The EPD sets out to give an overview of how the client manages their DSEAR/ATEX compliance.  The EPD is designed to be an overview/signpost document laying out the overall compliance strategy and ‘pointing’ to the detailed compliance documentation.   It covers a wide range of compliance related topics including gas dispersal studies.

Phase 2 – Equipment Inspection/Risk Assessment

Once the hazardous area zones have been defined, then a list of all ignition sources needs to be gathered, (including, instruments, electrical, mechanical, process, static, lightning etc.).  This inventory forms the basis of the list of equipment requiring risk assessment and inspection.

Phase 3 – Replacement of non-compliant equipment

Any equipment which ‘fails’ phase 2 risk assessments/inspections needs to be changed and/or repaired before being re-inspected.  This phase sees the EPD finalised and the inspection/maintenance regimes being put in place.

The above information describes Maurice Young Consulting’s approach to compliance. Although it may seem a daunting process at the outset, hopefully it can be seen to be rarely as ‘painful’ as first imagined.

If you do not fully understand the legislation or if it even affects you, or you have made some progress, but are finding it difficult to see the way forward to compliance, why not phone or e-mail Maurice Young Consulting to discuss your requirements.   We have a vast range of knowledge in all aspects of DSEAR/ATEX compliance for ammonia plants, and are always willing to offer help and advice.

REMEMBER – ALL EXISTING AMMONIA REFRIGERATION PLANT MUST RETROSPECTIVELY MEET THE DSEAR AND ATEX REQUIREMENTS AFTER JULY 2006…!