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HSE Chris Wright  
#1 Posted : 02 April 2020 12:27:25(UTC)
Rank: Forum user
HSE Chris Wright

Hi All,

Regarding the requirement for an explosion protection document under EC 1999/92/EC, does this document need to be drawn up prior to commissioning the system itself or is there a timeframe in which it has to be complied with? 

I would have thought commissioning of the system would be perhaps permitted but not actually using the system with the explosive product or substance until the EPD is done?

Ian Bell2  
#2 Posted : 02 April 2020 12:37:56(UTC)
Rank: Super forum user
Ian Bell2

There is no specific requirement under DSEAR which enables the ATEX directive to produce an explosion protection document. However, if you produce decent DSEAR assessments and ignition assessments, HAC drawings, equipment schedules, maintenance and inspection records etc then you come very close to an explosion protection document in any case.
HSE Chris Wright  
#3 Posted : 02 April 2020 12:40:50(UTC)
Rank: Forum user
HSE Chris Wright

Hi Ian,

Sorry, I should have mentioned this is for a project outside of the UK, in Denmark. where the full requirements of ATEX 153/137 apply, specifically article 8.

I think by finding this specific section, I have answered my own question.

Originally Posted by: Ian Bell2 Go to Quoted Post
There is no specific requirement under DSEAR which enables the ATEX directive to produce an explosion protection document. However, if you produce decent DSEAR assessments and ignition assessments, HAC drawings, equipment schedules, maintenance and inspection records etc then you come very close to an explosion protection document in any case.

Ian Bell2  
#4 Posted : 02 April 2020 13:04:33(UTC)
Rank: Super forum user
Ian Bell2

Article 8 is about the need to produce a Technical File for items sold as ATEX rated equipment - pumps/motors etc.

The EPD is more about risk assessment & technical measures to reduce EX risks etc.

Here is the guidance from the Irish HSE website equivalent

https://www.hsa.ie/eng/Topics/ATEX_and_Electrical_Apparatus/Atex_Regulations_-_Frequently_Asked_Questions/

What is an EPD? An EPD is an explosion protection document which contains the findings of a risk assessment of any work activity involving flammable/or explosive atmospheres. It may be incorporated or at least referenced in the Safety Statement, be part of other risk assessment documentation or included in the Safety Report for those establishments subject to the European Communities (Control of Major Accident Hazards Involving Dangerous Substances) Regulations.

It must detail:

  • Technical or organisational measures so as to reduce or prevent the risk of explosions (as set out in Schedule 2) and measures used to mitigate the effects of an explosion.
  • The operation of early warning devices.
  • Training instruction and supervision given to workers who work in places where an explosive or flammable atmosphere may occur.
  • Operational procedures, maintenance, operation of permits to work, and co-ordination between employers.
  • Classified places (according to Schedule 1) where explosions may occur called hazardous zones and detail marking of areas as well as location.
  • Means of escape in the event of an explosion.
  • The properties of substances that present an explosion hazard.
  • Selection and use of suitable equipment for use in hazardous zones including certification and calibration documents.
  • Equipment used that is CE marked and in compliance with SI No 230 of 2017 European Union (Equipment and Protective Systems for use in Potentially Explosive Atmospheres) Regulations 2017 (the ATEX product Regulations).
  • How often the EPD is reviewed and when is it due to be reviewed again.
stevedm  
#5 Posted : 03 April 2020 09:54:10(UTC)
Rank: Super forum user
stevedm

currently working in Denmark myself...but they like I have found elswhere ins europe only have a HAC as the key document...as most of it is still regulated by the Fire authorities in these countries they seem to miss the requirement for the EPD (in most but not all cases)...that is starting to change as some regulating bodies are either merging or handling the Seveso responsibilities over...not really helpful just some background from my experience ...:)

HSE Chris Wright  
#6 Posted : 03 April 2020 13:01:59(UTC)
Rank: Forum user
HSE Chris Wright

Originally Posted by: stevedm Go to Quoted Post

currently working in Denmark myself...but they like I have found elswhere ins europe only have a HAC as the key document...as most of it is still regulated by the Fire authorities in these countries they seem to miss the requirement for the EPD (in most but not all cases)...that is starting to change as some regulating bodies are either merging or handling the Seveso responsibilities over...not really helpful just some background from my experience ...:)

Hi Steve, thanks for the reply. That is the same impression I am getting. simply extend the HAC from the existing process (even though the design concept is different) and wait for fire authorities to sign it off.

Interestingly I think very few EU countries take much notice of anything coming out of Brussels!

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