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John Elder  
#1 Posted : 06 August 2023 15:30:17(UTC)
Rank: Forum user
John Elder

Dangerous Substance and explosive Atmosphere Regulations 2002 DSEAR

From the outset please be aware that this post is not as an advertisement or attempt to obtain any form of Hazardous Area Classification or DSEAR Risk assessment works. It is also not intended to be trigger (and I apologise if it does) to any persons who feel that it is directed towards them for whatever reason. It is purely based upon observations from the last 15 years having looked over multiple independent DSEAR Assessments by various companies an consultants in the course of my work, as if I am called to complete an DSEAR assessment and an assessment already exists then I need to read it in order to ascertain and establish what has gone on before.

I find that we have to normally provide a lot more information if I am derating a hazardous zone to a lower severity or to perhaps non-hazardous, as opposed to increasing an existing hazardous zone or non-hazardous area to a hight level or severity. In all instances in our assessments either calculations are shown, computations software has been used or references to the standard providing the relevant standard model for such situations has been applied.

You would think after the 20 years that the DSEAR Regulations have been in place that a competence or governance framework would not have been drafted or introduced by now to regulate and control the various standard of consultants, contractors and organizations within this field of consultancy putting themselves forward as DSEAR Assessors.

ACOP L138 in its simplicity gives the impression that anyone can read that publication and complete a DSEAR Assessment competently. In reality although it is only in my personal opinion, it covers the Risk Assessment element well, but glosses over the Hazardous Area Classification element leading to over simplification of a complex subject matter.

Although  both elements form part of the same subject matter, the skill sets required to competently carry out both the DSEAR Risk Assessment and Hazardous Area Classification elements differ greatly. The qualifications and relevant experience required to complete both well are varied.

The health and safety consultant or assessor is well suited to identifying hazards and formulating a report/assessment identifying potential risks although there knowledge of chemistry, and engineering concepts may be limited and they are best perhaps suited  to simpler elementary assessments when conducting assessments on their own.

The process engineer/chemist is suited for complex applications where different substances are mixed together and obtaining different states depending upon the pressures exerted and temperatures applied. This can cause the mixed substances to combine and form potentially more complex structures or chemical substances and compounds that requires their skillset to identify those more complex hazards and risks.

The plant manager/process operator is suited to identify issues in the process/operation which can cause dangerous situations to occur and identify where the various substances are vented, pressure relieved and unloaded. How the substances are transported, handled, stored and utilized on a daily basis. They also know the maintenance operations required which might increase the risk of a potential fire and explosion.

This is why I have found over the years that the quality of DSEAR Assessment being completed are in the majority greatly flawed in their findings. Over classification is common place which leads normally too expensive Atmosphere Explosive (ATEX) Electrical and mechanical works to be required that actually wasn’t needed.

To try and put this into perspective/context an area which is over assessed where an electrical light and light switch might later be required to be installed will vary greatly in requirements and cost over the life of the installation.

An overclassified are where it should have been perhaps found non-hazardous a standard light and light switch (Non ATEX) would have sufficed. This might cost perhaps £100 to £250 for materials and £100 and £250 to install if the installation was simple. Whereas not that it has been over assessed it will require an ATEX Version which might cost between £400 to £800 for the materials and perhaps upwards of £450 to install.

Also the first standard installation if the area is non-hazardous only requires it to be electrically inspected perhaps ever 5 years over the next 25 years at let us say £250 per visit for. 5 visits equating to a total 25 year inspection life cycle cost of £1,250 for labour.

Whereas if the area is over assessed the ATEX Installation (if qualified skilled persons are not based upon site) will require a CompEx Electrician to install, inspect and maintain. The periodic inspection frequency may only be a maximum of every 3 years provided that sample inspections are conducted in between due to the lack of skilled persons employed upon site and depending on the risk of an ignition perhaps every 6 months.

This could equate to between 25 and 50 separate inspections over the life of the installation and you can assume it will be charged at a day rate if that is all that is to be inspected at a minimum of £280 and only going upwards in labour cost depending upon the contractor. This could in fact be a final life cycle maintenance cost over 25 years off between £7,000 and £14,000 labour cost.

That should help explain the cost risk associated in over assessment. Whereas the cost risk of under assessment and missing a hazardous area altogether could be greater in impact leading to loss of facility and life.

I am unsure if the reasons for over assessments are due to the lack of experience and competence by the persons conducting the average assessment, or if they are caused by a lack of confidence due to their experience and competence making them potentially risk adverse leading to their hedging their bets on over classification. Also to be considered is that they do not have to bear the initial and ongoing costs involved for their client in compliance once a hazardous zone has been established.

DSEAR Risk assessment and Hazardous Area Classification is not cheap. Yet nobody bulks at taking their car for repair at £75.00 per hour because its easier, and you normally go to them rather than they come to you. You might give it to your mate down the road to do it cheaper but what competence and insurance will he have for the work.

It might be that due to the costs of assessment some DSEAR Assessors feel obliged to actually find a hazardous zone to warrant the costs incurred. These charges are normally depending upon how they had to quote the works and if their client actually had a scheme of requirements for the works to be conducted.

As clients normally do not understand the requirements of DSEAR and what they actually want completed, to alleviate this as a company we quote what we call a DSEAR Stage 1 assessment which identifies all the hazardous substances being stored, their quantities and how they are being used, transported or processed upon site and any sources of release and type of release that may be occurring. This is based at a lower cost as the final documentation and overall assessment is less onerous and in the majority of cases should produce findings that either conclude that the process being conducted or substance being stored is considered as Non-Hazardous regarding DSEAR Explosion or DSEAR Increased Fire Risk, or that a further in depth DSEAR Stage 2 assessment is required.

An in depth DSEAR Stage 2 assessment includes the identification of the type of release and its extent, the assigning of Hazardous Areas/Zones and production of any Hazardous Area Classification drawings showing plan and elevation views to enable a 3D conceptualisation of the hazardous zone to be found. It also covers the ATEX Equipment Explosion Protection Levels (EPL) required for each area and may also contain if required a Consequence of Ignition Assessment, and Ignition Hazard Assessment along with any requirement for signage and training. The additional cost for the Stage 2 assessment can be mentioned in the initial costing/quotation as (If required) and the client then knows what they might have to uplift their final costs to at the outset of the works.

Most assessments and facilities shouldn’t find anything relevant to requiring a Stage 2 DSEAR Assessment and Hazardous Area Classification requirement.

A short list of typical areas that require Hazardous Area Classification are Paint Spray Booths, Wood working Extraction Equipment, Natural Gas installations and metering equipment, potentially compressed gasses upon site e.g. cylinders if the required separation distances have not been adhered to or the correct built storage facilities erected. Refuelling areas or fuel storage, Flammable processing equipment and so forth. This list can go on and on.

To all persons requiring a DSEAR assessment it is up to you to vet your subcontractor as to their suitability and competence. To be honest in most instances you are going to be on a hiding to nothing and in the hands of the gods as to what you end up with.

That being said there are some though few competent assessor working in the field but it will be up to you to cut the wheat from the chaff.

That is why I honestly believe there should be some sort of governance or decent formal qualification for DSEAR Risk Assessment and Hazardous Area Classification. The courses currently available are limited in their scope normally lasting 3 days to a week, and a comprehensive course would take a minimum of 4 weeks to deliver to cover the basic standards and their interpretation and implementation available.

This would cover as a minimum before letting an assessor loose plus conducting at least 2 assessments that are peer reviewed should be the following:

BSEN 60079-10-1 Hazardous Area Classification Explosive Gas Atmospheres

BSEN 60079-10-2 Hazardous Area Classification Explosive Dust Atmospheres

Energy Institute EI15 Safe Code of Practice for installations handling flammable substances

IGEM/SR/25 Hazardous Area Classification Natural Gas Installations

UKLPG Code of Practice No. 1

British Compressed Gasses Association (Various standards)

Along with the various BSEN Requirements for Safety for spray booths, wood working chip extractions systems, battery installations and so forth as a minimum.

Once again this article is solely my personnel opinion and not that of my companies. It is not intended to trigger anyone into a ranting or raving about their competence or abilities as you will notice I have not mentioned or covered my qualifications or experience to that point.

The post is intended to those perhaps contemplating competing a DSEAR Assessment in house themselves or looking to employ an assessor to inform them of considerations to take into account during the process. I though it also best placed on the public forum as opposed to the members forum for the widest audience.

thanks 2 users thanked John Elder for this useful post.
pseudonym on 07/08/2023(UTC), chris42 on 07/08/2023(UTC)
pseudonym  
#2 Posted : 07 August 2023 07:51:19(UTC)
Rank: Forum user
pseudonym

This is an area, much like fire risk assessment (in my opinion) where the usual training people get ie NEBOSH, Post-grad Cert / Dip & MSc, may give many people a false impression that they are capable of performing such assessments (Dunning-Kruger effect, indeed John). 

I looked at the references in the Government guidelines for fire risk assessement in offices and shops / factories and warehouses and decided I haven't got the time to keep up to date with all of them; so I wont do FRAs or DSEAR RAs because although a scientist by original training I'm never going to be fully up to date across all the background material necessary. I'm happy to be a hack, generalist with, hopefully a  decient idea of my limitations

thunderchild  
#3 Posted : 07 August 2023 09:38:23(UTC)
Rank: Forum user
thunderchild

Agreed, we have specialist in to do both our FRA and our DSEAR as we are an energetics business.

It didn't go down too well when I stated that the trained NEBOSH Fire trained person was not going to do our FRA as that only makes to competent to medium risk which we are not and I admitted that I wasn't competent either....this (I have learnt) was not a good think to state where you're lacking in competence and I said I did not want to do the full FRA course to make me competent. 

We have experts in this field for a reason, they do it all the time not once a year!

mrkjd  
#4 Posted : 07 August 2023 10:42:38(UTC)
Rank: Forum user
mrkjd

I think the confusion largely stems from deciding proportionality and ownership of the risks. If a workshop has some oil, odd can of degreaser and WD40 does it need DSEAR? Where is that line in the sand where DSEAR does become a reasonable requirement and a "regular" Haz Log / RA process insufficient? Work places where there is a clear use / storage of bulk flamables etc probably understand the requirement - it is more marginal scenarios such as a small workshop in an otherwise relatively low haz mat use workplace where there is doubt.

I have read somewhere recently that there is no specific requirement to undertake a specific DSEAR RA - a "regular" RA may suffice if detailed enough etc. That doesn't seem to be a sound foundation to me. Many of us may have corporate off-site HSE management asking for DSEAR RA - those people may also clearly not understand the process or whether it is neccessary. How does an onsite Safety Officer address this? The "regular" RA may well be sufficient but how do they demonstrate they considered DSEAR requirements unless some form of DSEAR assessment has been produced?

Many of us may be working on project sites or facilities that we lodge or are not principle contractors. We may understand very well how our processes and use operationally requires assessing and mitigating (and have those documented and in place) but would the site principle / owner have that knowledge? Is it within the gift of an  operator renting / lodging a facility to identify Haz Zones and ATEX requirements? With such overlaps how is the ownership of the requirement to DSEAR RA and mitigations agreed? Operations say the Site owners should do it / Site Owners say the Operatiors should do it! Consequence is they dont get done or a token effort is made. 

John Elder  
#5 Posted : 08 August 2023 20:26:53(UTC)
Rank: Forum user
John Elder

Most small site situations like small cans of oil WD 40 and so forth can be managed under HSG 51 Storage of flammable liquids in containers. Are below the threshold values for requiring a DSEAR depending on what you are doing with the substance.

If the landlord rents his site or buildings to a tennent for use in most cases, it is the responsibility of the tennent/operator of the building/operation to complete the DSEAR Assesment as they are the person manufacturing the substance, using or processing the substance, storing or transporting the substance.

The landlord is responsible for the building fabric the operation has to take responsibility for his processes.

I work with large defence estates whom rent buildings to other companies or contractors. they are responsible for all the buildings but only the works being conducted in their areas, whereas the other company or contractors are responsible for managing and assessing what they are doing.

I also get envolved in DSEAR and energitic material processing 

Ian Bell2  
#6 Posted : 10 August 2023 20:19:29(UTC)
Rank: Super forum user
Ian Bell2

Wow thats some rant. DSEAR can be easy, complicated and everything in between.

I'm not going to address every point raised/discussed by John, I haven't got the time or inclination.

I can't help thinking the extensive list of standards you have listed - probably amounts to 1000pages or more.

So its a big ask to expects a training course to deliver adequate coverage of all of the standards, even in 3-4 weeks. In reality who is going to pay for 3-4 weeks training just on DSEAR. Not to mention the cost of the standards - £1500-2000 for all of those listed.

Sure teach the broad outline of the standards - but competence and deeper knowledge comes from regular use/reading of the standard.

I guess like most people who move into a new subject - you start off on simple assessments and gain experience over time by doing more assessments and more complex assessments/situations.

As regards minimum quantities of flamamble liquids - by strict application of DSEAR, there is no minimum quantity. If you have a DSEAR substance on your premises, then an assessment is required. How complicated it is, is another matter. In fact quite DSEAR can be quite subjective about how hazardous area classification is applied.

EI 15 gives some guidance as to when they think hazardous area classification should be undertaken. From memory (so don't have the time to look it up) 5litres of LPG, 25 litres of flamambles if indoors, 200 litres if outdoors. 

As regards the HSE L138 DSEAR acop is pretty poor when it comes to advising/discussing explosive dusts - even when reading the associated HSG103 Flammable/explosive dusts.

Yup, I consider myself to be competent to do DSEAR assessments, having had a number of DSEAR assessment reviewed by the HSE - with no adverse comments, 20 years in engineering design in the oil& gas and defence sector, engineering degree etc. So yes DSEAR assessments are expensive - I want pay back for my training, experience and the many exams taken over the years.

thanks 1 user thanked Ian Bell2 for this useful post.
stretch3144 on 04/03/2024(UTC)
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