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ajc  
#1 Posted : 19 February 2015 09:31:12(UTC)
Rank: Forum user
ajc

As I understand COMAH 2015, you will be allowed to store up to 2500 tonnes of Marine gas oil on site before falling into the lower tier class. Would DSEAR be the primary legislation applied to sites carrying, say, 2450t or is there some other legislation I am missing?
Ian Bell  
#2 Posted : 19 February 2015 10:01:52(UTC)
Rank: Super forum user
Ian Bell

Even DSEAR may NOT apply to a relatively heavy oil. You need to get an up to data Material Safety Data Sheet for the type of oil you store. If it is classed as Flammable, Highly Flammable or Extremely Flammable then DSEAR applies. If not, then DSEAR is unlikely to apply, with the exceptions below: I assume the oil will only be stored at ambient temperatures? Is there any likelihood of the oil being pressurised and if it leaks forming a mist of oil droplets?
stevedm  
#3 Posted : 19 February 2015 11:03:17(UTC)
Rank: Super forum user
stevedm

A good operator would still have a suitable safety assessment...just because you fall out of the bracket doesn't necessarily mean you lower your risk..depends whether it could contribute to MAH...
ajc  
#4 Posted : 19 February 2015 11:51:26(UTC)
Rank: Forum user
ajc

Thanks Ian, the mgo is not classed as flammable in the COMAH guidance as it has an flash point above 55oC, and yes, it will be stored at ambient temperatures and pressure.
Ian Bell  
#5 Posted : 19 February 2015 13:59:17(UTC)
Rank: Super forum user
Ian Bell

Its not the COMAH guidance you need to read - its the DSEAR ACOP L138!! However, agree its not likely to fall under DSEAR - but as with most safety legislation there is the usual generic 'catch all phase' about applicability - so read carefully.
ajc  
#6 Posted : 19 February 2015 20:24:36(UTC)
Rank: Forum user
ajc

Thanks again Ian, after looking at L138 I also realised that the 55oC I spoke about is now 60oC because of changes brought about by the Classification, Labelling and Packaging Regulations along with the GHS, a good day, I think.
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