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chris42  
#1 Posted : 24 February 2021 17:06:22(UTC)
Rank: Super forum user
chris42

Hi All

Fire Safety is not a subject I’m particularly Au fait with and normally would bring someone in to do assessments etc. However, while trying to understand something else, I noted in Article two (RRFSO) interpretation, something that didn’t entirely make sense and wondered if someone was able to explain it.

Under the interpretation of “Dangerous Substance” it has:

(a) [F5a substance or mixture which meets the criteria for classification as hazardous within any physical hazard class laid down in the CLP Regulation, other than “corrosive to metals” or “gases under pressure”, whether or not the substance or mixture is classified under that Regulation]

(b) a substance or [F6mixture] which because of its physico-chemical or chemical properties and the way it is used or is present in or on premises creates a risk; and

(c) any dust, whether in the form of solid particles or fibrous materials or otherwise, which can form an explosive mixture with air or an explosive atmosphere;

The bit that didn’t seem to make sense is in (a) where it sates other than “gases under pressure”. Surly gases under pressure are dangerous, so why exclude them? or is it a case “gases under pressure” fall under (b)

Thanks for any help in understanding.

Chris

A Kurdziel  
#2 Posted : 25 February 2021 09:53:17(UTC)
Rank: Super forum user
A Kurdziel

CLP is essentially the local iteration of the GHS system. There are a number of health hazard categories under that and the best know are Irritant, Toxic, Corrosive(to human tissue) and Harmful, also known as ITCH. Managing ITCH, is done under COSHH. Also under GHS are what they call physical hazard categories, Highly and Extremely Flammable, Explosive, Corrosive (to stuff other than human tissue)     and Compressed Gasses. The RRFSO requires the duty holder to make a risk assessment taking into account, the presence of Highly and Extremely Flammable, Explosive substances, which it describes as Dangerous substances. It excludes  Corrosive (to stuff other than human tissue) and Compressed Gasses because they to do not in themselves aggravate a fire, ie make it burn more. But if a substance is compressed and flammable eg hydrogen  it has to be included in the risk assessment.  

This is where people get it wrong and make it more difficult for themselves in that they create separate risk assessment documents for COSHH, DSEAR and RRFSO. It is perfectly possible to integrate all of these into a single document for example if you are looking at a chemical store.  The guidance on DSEAR effectively   says this, since it mentions that the controls for chemical  hazards ( ie COSHH) may be the same as those for DSEAR and under the RRFSO

thanks 1 user thanked A Kurdziel for this useful post.
chris42 on 25/02/2021(UTC)
Roundtuit  
#3 Posted : 25 February 2021 10:16:13(UTC)
Rank: Super forum user
Roundtuit

Gasses under pressure are cassified against four criteria in CLP:

Compressed, Liquefied, Refrigerated liquefied and Dissolved

For three of the four the Hazard Statement reads H280: Contains gas under pressure; may explode if heated whilst the third reads H281: Contains refrigerated gas; may cause cryogenic burns or injury

As AK has indicated the cryogenic hazard affecting tissue is ignored under RRSFO.

For the remaining three it is not the substance itself that would create danger rather the effect of increased temperature & therefore pressure potentially rupturing the container (the word "may").

Explosives, Flammable liquids/solids, Oxidising Agents would by their nature present danger when exposed and contribute to fire.

Metal corrosion requires water as a medium for the reaction to occur.

thanks 2 users thanked Roundtuit for this useful post.
chris42 on 25/02/2021(UTC), chris42 on 25/02/2021(UTC)
Roundtuit  
#4 Posted : 25 February 2021 10:16:13(UTC)
Rank: Super forum user
Roundtuit

Gasses under pressure are cassified against four criteria in CLP:

Compressed, Liquefied, Refrigerated liquefied and Dissolved

For three of the four the Hazard Statement reads H280: Contains gas under pressure; may explode if heated whilst the third reads H281: Contains refrigerated gas; may cause cryogenic burns or injury

As AK has indicated the cryogenic hazard affecting tissue is ignored under RRSFO.

For the remaining three it is not the substance itself that would create danger rather the effect of increased temperature & therefore pressure potentially rupturing the container (the word "may").

Explosives, Flammable liquids/solids, Oxidising Agents would by their nature present danger when exposed and contribute to fire.

Metal corrosion requires water as a medium for the reaction to occur.

thanks 2 users thanked Roundtuit for this useful post.
chris42 on 25/02/2021(UTC), chris42 on 25/02/2021(UTC)
chris42  
#5 Posted : 25 February 2021 10:27:27(UTC)
Rank: Super forum user
chris42

Thanks, that makes sense now. I Think I was considering all compressed gases as being flammable or extremely flammable, as I had spent a large chunk of the day reading the RRFSO, so had this on the brain. Obviously, you may have other non-flammable compressed gasses (as indeed we do).

It was not the thing I was trying to find out about (evacuation plans and what is specifically required in them), and it just seemed a little odd at the time as I always like to read through the interpretation of terms.

Once Covid is under control a bit more, I think I would like to do some fire related training, but proper training as not so keen on this virtual stuff. I’m not entirely convinced about some of these (supposed expert) fire risk assessors we have brought in in the past.

Again, thank you.

Chris

Ian Bell2  
#6 Posted : 25 February 2021 10:37:20(UTC)
Rank: Super forum user
Ian Bell2

#2 DSEAR also requires you to undertake hazardous area classification and if necessary produce a suitable drawing of the zoned areas. 

Simply incorporating the dangerous materials into your FRA might omit this exercise.

DSEAR also requires you to identify and select correctly rated ATEX equipment for the hazardous areas.

So while (certainly for simple situations) it is acceptable to add in an appendix etc to your FRA, you should be happy that you haven't missed a few key requirements of DSEAR such as these.

thanks 1 user thanked Ian Bell2 for this useful post.
chris42 on 25/02/2021(UTC)
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