DSEAR Risk Assessment is a vital part of achieving Safety and Compliance for any business in any industry where substances are present.
A dangerous substance is one that is flammable (has a flashpoint of less than 60 Degrees C) like Diesel, Ethanol, Resins, Acetone, Jetfuel etc. or a combustible powder or dust suspended in air like wood dust or flour.
There are a few other substances or processes, including substances that are combustible but under high pressure of over 40-60bar pressure, for example, but the flashpoint is the main aspect.
Identifying hazardous areas and determining the concentration of these substances are crucial for maintaining a safe working environment and ensuring compliance with regulations such as the Dangerous Substances and Explosive Atmospheres Regulations (DSEAR).
This blog will outline how to identify hazardous areas, discuss the impact of recent regulatory changes, and provide practical steps to mitigate risks. We will also present two case studies to illustrate these concepts.
Identifying Hazardous Areas
Hazardous areas are locations where flammable gases, vapours, or dust are present in concentrations that could ignite and cause an explosion. To determine if a hazardous area is present, the following factors must be considered:
Quantity of Flammable Substances:
- Facilities that store more than 50 Liters of flammable liquids or multiple gas cylinders indoors are likely to require a DSEAR assessment.
- Examples include workshops with gas cylinders (e.g., propane) and storage areas with significant quantities of flammable liquids.
Storage Locations:
- Flammable substances stored indoors pose a higher risk of creating hazardous areas.
- Moving storage outdoors to dedicated storage areas can mitigate this risk and potentially remove the requirement for a DSEAR assessment.
Processes and Activities:
- Certain activities such as decanting, mixing, and spraying flammable substances increase the risk of creating hazardous atmospheres.
- For instance, paint mixing and spray-painting operations often create hazardous zones due to the use of volatile solvents.
Impact of Regulatory Changes
In 2016, the European Union revised the temperature classification of flammable substances, increasing the flash point from 55°C to 60°C. This adjustment has brought substances like diesel within the scope of DSEAR, significantly affecting many industries. As a result:
- Increased Regulatory Scrutiny: Regulators such as the Health and Safety Executive (HSE) and insurance bodies have heightened their focus on DSEAR compliance, meaning they are looking much more in detail than they used to. This is why you may have had a previous inspection, and it was not identified, but is more recently.
- Increased Insurance Awareness: Insurance companies are also much more aware and risk managers and inspections pick DSEAR up as a requirement much more frequently now than they used to. This is because it is a physical risk they are aware of, but also a regulatory risk they see needs insuring.
- More Frequent Assessments: Companies are now more frequently required to perform DSEAR risk assessments, that may not previously have been expected to or advised to do so. Because the enforcement and inspections have increased, additional attention is on the subject such as Fiore risk assessors are now required to identify the need in their reports, where they may not have been aware previously.
- Heightened Awareness and Training: Increased awareness and mandatory training for HSE inspectors, insurance risk managers, Fire risk Assessors etc. have led to more rigorous enforcement of DSEAR regulations.
Practical Tips for Compliance
Assess Storage Practices:
- Evaluate if flammable substances can be stored outdoors in dedicated storage areas to reduce the need for a DSEAR assessment.
- Example: Moving a large quantity of flammable liquids from inside a building to an external storage area may be the difference between needing an assessment and not.
Conduct detailed Assessments:
- If hazardous areas are identified, conduct a thorough DSEAR risk assessment to understand the extent of the risks and necessary controls.
- This involves identifying all potential ignition sources and evaluating the likelihood of hazardous atmospheres forming.
- Hazardous Zones must also be part of the assessment. It is something that is missing from DSEAR Risk Assessments still, but Regulation 7 of the DSEAR regulations states the requirement to assess the facility and determine the Hazardous Area Classification (HAC).
Implement Controls:
- Relocate storage areas, eliminate ignition sources, and ensure proper training and documentation.
- Example: Installing explosion-proof equipment, ensuring proper ventilation, and enforcing strict no-smoking policies.
Case Study 1 – Steel Fabrication, Welding and Spray Booth
Situation
The steel fabrication facility carried out grinding, welding, shot blasting, and spray painting—each of which generated significant hazardous risks due to the use of flammable substances and the presence of propane gas cylinders and diesel. The outdoor storage of these materials did not eliminate the risk of fire and explosion, given the high volume of flammable substances and the mechanical processes involved.
Task
The task was to identify and mitigate hazardous areas, ensuring the facility’s compliance with DSEAR regulations. DSEAR requires employers to control the risks of fire, explosions, and similar events arising from dangerous substances in the workplace.
Actions
1. Hazardous Area Identification
The first step involved detailed identification of hazardous areas across the site.
- Hazardous Zones: 8 to 10 hazardous zones were identified, based on different operations like paint mixing, decanting, and spray painting.
- Zone Classification: Each area was classified using DSEAR’s zoning approach:
▪ Zone 0, 1, or 2 (gas hazards), or Zone 20, 21, or 22 (dust hazards). For example, the spray-painting booth and paint mixing areas were likely classified as Zone 1, where an explosive gas atmosphere might occur during normal operations. Welding areas and shot blasting may have fallen under Zone 2, where explosive atmospheres are less likely but still a risk. - Gas and Dust Hazards: The accumulation of combustible dust from shot blasting or vapours from paints and solvents further contributed to the complexity of risk management, especially in confined spaces.
2. Relocating Substances and Gas Cylinders
- Propane and Diesel Storage: The storage of propane gas cylinders and diesel outside was already a step in the right direction, but additional measures were needed to reduce the risk. Propane cylinders were moved to ventilated areas with explosion-proof electrical fittings, and diesel was stored in properly bunded tanks to contain any spills.
- Segregation: The site rearranged storage areas to ensure that flammable liquids and gas cylinders were kept away from heat and ignition sources.
3. Training and Procedures
Employee training and procedure implementation were critical in maintaining safety:
- DSEAR Awareness: Employees were trained on hazardous areas, specifically focusing on the risk of explosive atmospheres caused by gases, vapours, and combustible dust. This included understanding the zoning classifications and how their work contributed to potential hazards.
- Eliminating Ignition Sources: Workers were trained to identify and eliminate potential ignition sources. For instance, battery-powered devices (e.g., cordless drills) were identified as potential sources of ignition in hazardous zones, so their use was either restricted or eliminated within certain zones.
4. Equipment Modifications
Significant modifications were made to equipment and systems to minimise risk:
- Compressed Air Systems: Battery-powered spray guns and breathing apparatus were replaced with compressed air systems, which drastically reduced the risk of sparks or electrical malfunctions.
- Ventilation: The spray booths were equipped with enhanced extraction and filtration systems to remove paint vapours and dust particulates, thereby maintaining a lower risk of flammable atmospheres accumulating.
- Anti-Static Measures: Grounding and bonding of equipment were installed to eliminate static electricity build-up, which could serve as an ignition source.
Results
The combination of hazard identification, improved storage, worker training, and equipment upgrades led to a significant improvement in the facility’s risk profile. Key results included:
- Enhanced DSEAR Compliance: Detailed CAD diagrams and updated written procedures ensured that the hazardous area classifications and control measures could be clearly communicated and maintained.
- Risk Mitigation: By moving substances and introducing more suitable equipment, the likelihood of fire or explosion incidents was reduced.
- Improved Safety Culture: With training and procedural updates, employees were more aware of risks and able to respond appropriately, ensuring ongoing compliance and safety.
The case study demonstrates how technical and administrative controls can significantly reduce risks in hazardous environments, particularly in industries dealing with explosive atmospheres.
Case Study 2 – Manufacturing site with Propane Cylinders
Situation
The manufacturing facility stored propane gas cylinders and a 1,000-liter diesel day tank inside the building. The facility was subject to a DSEAR risk assessment to evaluate these risks and identify necessary actions.
Task
The task involved conducting a DSEAR risk assessment to identify hazardous areas and assess the potential for fire or explosion risks associated with the indoor storage of propane and diesel. The assessment sought to determine measures to mitigate these risks, aiming to comply with safety regulations and reduce hazardous zones.
That said, if the facility was able to reduce the volume of storage, particularly indoors, a DSEAR Assessment will not have been needed.
Actions
1. Relocating Gas Cylinders
- External Storage Cage: The propane gas cylinders were moved from their indoor location to an external storage cage. This significantly reduced the risk of gas leaks accumulating indoors, where an explosive atmosphere could form in confined spaces.
- Ventilation and Separation: By moving the propane cylinders outdoors, the facility ensured that any potential propane leaks would disperse into the open air, minimising the chances of gas buildup. This relocation also adhered to the principle of separating flammable gases from potential ignition sources indoors, such as welding equipment and electrical systems, reducing the overall hazardous area.
- Compliance with Standards: The external storage cage was designed to meet DSEAR storage requirements, including proper ventilation and explosion-proof electrical fittings where necessary. Cylinders were secured in a well-ventilated area, reducing the likelihood of accidental releases leading to dangerous concentrations of propane in the air.
2. Repositioning the Diesel Day Tank
- Day Tank Relocation: The 1,000-liter diesel day tank was originally located in a sprinkler room, a confined space where diesel vapours could accumulate, creating a significant fire hazard. The DSEAR risk assessment identified this as a major risk.
- External Relocation: The day tank was moved to an outdoor location, thereby mitigating the risk of diesel vapours accumulating indoors. The external
environment provided adequate natural ventilation, preventing vapor buildup and
reducing the potential for creating an explosive atmosphere. - Bunded Storage: To prevent any accidental spills or leaks, the day tank was placed in a bunded area, ensuring that any diesel that leaked would be contained, minimising environmental contamination and fire risks.
Results
- Elimination of Hazardous Areas: By moving both the propane cylinders and the diesel day tank outside, the facility significantly reduced or eliminated the hazardous zones identified under DSEAR. This allowed the facility to avoid the need for further hazardous area classification and reduced the number of indoor areas requiring expensive explosion-proof equipment or monitoring systems.
- Cost Savings: The elimination of the need for a full DSEAR assessment inside the facility resulted in cost savings by reducing the complexity of the regulatory requirements. Without the hazardous areas, the company could avoid the costs associated with further assessments, installing flameproof equipment, or training staff for high-risk zones.
- Compliance and Safety Improvement: The actions taken ensured the facility remained compliant with both DSEAR regulations and fire safety standards. The risk of fire or explosion due to the indoor accumulation of flammable vapours was minimised, resulting in a safer work environment for employees.
This case highlights the importance of proper hazardous substance storage and the benefits of proactive risk management. By relocating hazardous materials, the facility improved both its safety profile and operational efficiency, aligning with DSEAR’s goal of controlling fire and explosion risks associated with dangerous substances.