Posted By Sean Fraser
For those who are still grappling with the implications of DSEAR, here is a real scenario:

One of our employees is engaged in cargo inspection services for vessels, working primarily on a jetty which is classified as an hazardous zone. He has a hearing impediment for which he wears a hearing aid, and a concern has been raised that because it is battery operated, and is not an Ex device, it might constitute a possible ignition source. Since the actual danger is not known, there is a probability that the precautionary principle might be applied and the employee is asked to leave it behind while working in a zoned area.

I have concerns of my own about this. 1] In the Offshore industry, personnel are allowed to wear personal wrist watches that are battery operated and are a more likely danger due to the possibility of damage contributing to a short and hence ignition of atmosphere - so if it is OK for these personal convenience items, surely it is OK for a personal welfare item? 2] By reducing his auditory acuity, are we creating a more likely risk of harm as his ability to hear effectively may compromise his reactions to verbal communications and audible alerts?

Has anyone else come across this kind of problem before, and what were the conclusions?

Any comments would be welcome.

Posted By Philip McAleenan
Sean,

where there is a potential for an explosive atmosphere to arise then all equipment and apparel capable of generating a spark must be forbidden.

Your assessment will show that it is necessary for your worker to have a hearing aid in order to carry out his work safely. The solution is to provide him with a hearing aid that is both suitable for his personal requirements and is intrinsically safe. This is in accord with PPE requirements and disability discrimination regulations.

Check with hearing aid manufacturers if they have such a product, if not, the engineering solution has already been developed for other devices so it should not be too difficult for manufacturers to adapt the solution to hearing aids.

Regards, Philip

Posted By Sean Fraser
Good point Graham - proper application of DSEAR would be to identify and justify hazard zones. However, I think that there might be a mix of the precautionary principle, convenience and human factors involved here. In the first, if in doubt, ratchet it up one so that the safer option is implemented first, thereby lowering chance of a failure. In the middle, there is the inevitable temptation to classify one large area and be done with it, rather than identify (and hence mark and sign) individual areas differently. Finally of course there is the problem of getting people to take the right precautions in the right areas - by making them take the 'safer' option as standard, it theoretically prevents them from "forgetting" to suit up and change equipment when entering the zone - unless physical barriers are in place that need to be actively crossed etc..

Of course, there is the argument that once someone understands why they do things they are more likely to apply the appropriate measures, rather than just tell them that these rules apply without explanation and then hit them over the head whenever they fail to act accordingly. Currently reading an interesting booklet after following up on another thread yesterday from the UK P&I Club regarding human factors. The section on Human Error itself is particularly interesting and I would recommend it (see thread "Accident investigation). It discusses the nature of human error and insight into why it happens - deliberate and otherwise. Certainly supports my theory that over-proceduralisation leads to more, not fewer, "breaches" and hence institutionalises unsafe acts over time, ingraining them into the culture.

Anyway, we'll have a look at that area regarding classification of zones and see what comes up. Thanks again.