In this article, Principal Consultant Tristan Pulford takes a look at the Dangerous Substances and Explosive Atmosphere Regulations (DSEAR), and why flour must be considered under the regs.
Bakeries use a variety of substances but one of the core substances that is used throughout is flour. Depending on your supplier the Material Safety Data Sheet (MSDS) may say that the substance is potentially explosive, or it may be more cryptic by saying that it “May form combustible dust concentrations in air”. Any potentially flammable dust, fluid or gas falls under the Dangerous Substances and Explosive Atmosphere Regulations (DSEAR) Regulations, and as such Flour must be considered under the DSEAR.
This means there is a legal obligation to:
- Create a hazardous area classification designating any potentially explosive atmospheres.
- Install the appropriate ATEX rated equipment into those areas.
- Ensure that anyone working in the vicinity is trained and informed about the hazardous areas.
- Ensure that maintenance is carried about by an ATEX competent person which is usually evidenced by a recognised training scheme, such as CompEX.
- Ensure that Safe Operating Procedures (SOPs) and Risk Assessments (RA) are updated and highlight the hazards associated with the potentially explosive substances.
- Store all of the above in a risk assessment document often referred to as an Explosion Protection Document (EPD).
Before we look into these sections in more detail, a step back is required as the hierarchy of control as it applies to DSEAR must be considered.
There is a responsibility placed on the User to first look at the substances used and whether it is required or whether an alternative can be used.
In the case of Bakeries, flour is required as part of the process and there is no alternative that reduces the potential for explosion. The next step is to control the quantity stored on-site, which requires a process analysis. These steps are frequently missed as part of DSEAR, or they are not documented. This documentation may be brief, but it is a requirement of the Management of Health and Safety at Work Regulations.
The next step in the hierarchy is to reduce releases, which is done by reducing the use of flexibles, and any open sections of the system, or by adding LEV at small bag hoppers where possible. If there is a release DSEAR requires you to put in appropriately rated equipment (known as ATEX rated equipment) within the areas where a release is potentially expected. Lastly, you provide information and training to anyone who will work in the area.
So now let’s look at the documentation requirements.
Hazardous Area Classification
One of the key parts of DSEAR is that areas are categorised into zones. This article will not discuss that in detail, but the idea behind it is to get an understanding of the probability of a potentially explosive atmosphere (dust or gas/mist) being present in an area and to document this as part of a hazardous area classification (HAC).
This will designate the areas as zone 0, 1, 2, 2NE (for gas/mist) or 20, 21, 22 (for dust) which can then be used to understand where additional controls may be required. These are normally placed onto a diagram which can look like this:
ATEX rated equipment
Within these zones, there is a requirement to install the appropriately rated ATEX equipment, with the idea being that the equipment rated for a more onerous zone (Zone 0), being less likely to create an ignition source when compared to that of equipment that is designed for a “higher” zone (e.g., Zone 2).
It is important when specifying the equipment that the correct type (dust or gas/mist) is specified, as well as that the equipment is specified for the substance, as different substances have different ignition temperatures and energies.
It is important that you hold an ATEX register of all the equipment within zones, and ideally store all of the relevant declarations of conformities for the equipment to evidence that they are appropriately rated.
Training and information
Anyone working within or near a hazardous area, need to be trained in the hazards that exist, and the controls in place. This may be in the form of a toolbox talk or separate training on the subject. It is also key that any contractors or visitors are made aware if they are likely to be in those areas. This is normally carried out through induction training and appropriate signage around the site.
For any maintenance staff working in the area additional training is required, to maintain the ATEX certification of the equipment. The industry-accepted training is called CompEX, but there are others, and takes the form of Electrical and Mechanical disciplines.
All training records should be stored and kept for staff working in potentially explosive atmospheres, and any maintenance system should ensure that only those correctly trained can work on the equipment.
Explosion and Ignition Risk Assessment
There is always confusion about Explosion and Ignition Risk assessments, as the terms are almost used interchangeably at times. If used correctly however an ignition risk assessment is a subset of the explosion risk assessment, and looks specifically at the control of ignition sources, while an explosion risk assessment looks more wholistically at the system.
It is a requirement to have a DSEAR risk assessment, to help identify where controls are required, and what mitigation is already in place. This helps in creating the basis of safety for the process and equipment used within it.
Safe Operating Procedures (SOPs) and Task-Based Risk Assessments
As part of your SOPs and task-based risk assessments, it is important that if it is working with a potentially explosive substance or within a hazardous area that the hazard is mentioned at the start of the SOP and within the Risk Assessment.
Explosion Protection Document (EPD)
Finally, we have what is called the Explosion Protection Document, which while required by the EU Directive but is often used to demonstrate compliance to DSEAR. It is not defined what goes in this. The EPD is your proof of compliance, and all the documents discussed above should go as part of this. That does not mean they all need to be in one place, but it does mean they should be accessible/ referenced.
For any more information about DSEAR and related topics, please contact [email protected].
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