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G.Wynne  
#1 Posted : 08 February 2022 20:57:38(UTC)
Rank: New forum user
G.Wynne

Hi, I am sure this has probably come up before, given diesels reclassicaltion in 2015. However in a discussion recently with another H&S professional regarding x3 diesel generators (3500lt bunded tanks) at a new site I recently visited, they mentioned that a DSEAR assessment was only required on diesel tanks when it was in volumes above 20,000lt..... I've been searching all over the HSE website, reading industry pieces and scracting my head a lot since trying to fact-check this statement, but can't find anything that states there is a minimum amount before a DSEAR Assessment is triggered. I'm no specialist in DSEAR, but I knew the flashpoints had been lowered in CLP meaning diesel now fell under DSEAR, however, in terms of min vols - this is new one to me!

Anyone out there with any experience of diesel generators, similar to this site and the requirements to undertake a DSEAR assessment on it? Is there a min.vol. before the assessment is triggered?

Thanks very much.

Alfasev  
#2 Posted : 09 February 2022 09:32:44(UTC)
Rank: Super forum user
Alfasev

I looked into this years ago associated with a standby diesel generator. I got a vague memory volumes are something to do with fuel storage facilities and perhaps COMAH rather specifically DSEAR.

I also remember the regulations had changed, and COP and the British Standard being out of line. After speaking to the manufactures it was confirmed you still need a DSEAR risk assessment. It was the refuelling method that posed the risk as long as the generator was maintained and there was good housekeeping. It was also in the building so fire compartmentation had to be correct.

I was only involved in the handover and did not have to do the DSEAR risk assessment, which was the responsibility of the landlord. Hope this helps.

Edited by user 09 February 2022 09:34:25(UTC)  | Reason: Not specified

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G.Wynne on 09/02/2022(UTC)
Kate  
#3 Posted : 09 February 2022 10:00:02(UTC)
Rank: Super forum user
Kate

As Alfasev suggests, minimum volumes before you have to do something are to do with COMAH, not DSEAR.  The quantity of flammables is obviously important to the DSEAR assessment and will influence how much effort you expend on both the assessment and the control measures, but there is no minimum quantity below which there is an exemption from the legal requirement to control fire and explosion risks!

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G.Wynne on 09/02/2022(UTC)
Ian Bell2  
#4 Posted : 11 February 2022 01:29:20(UTC)
Rank: Super forum user
Ian Bell2

There is no volume restriction under DSEAR for diesel. Diesel is low risk for DSEAR, the environmental spill risk is a bigger concern. As others have said that comes from the COMAH regs.

If you are in the UK, the flashpoint of diesel is so much higher than any ambient temperature that hazardous area classification isn't required. You do have to think about spray leaks though.

More DSEAR help if required?

Ian Bell2  
#5 Posted : 11 February 2022 01:34:15(UTC)
Rank: Super forum user
Ian Bell2

Just to clarify - diesel DOES require a DSEAR assessment, even though low risk. It is classified as 'flammable' so DSEAR applies. You can't just dismiss it and say no assessment required.

John Elder  
#6 Posted : 11 February 2022 14:34:09(UTC)
Rank: Forum user
John Elder

A DSEAR Assessment is required to ensure the following are answered and below is based only upon DIESEL as this is the substance you are asking about.

Is the substance flammable in your case yes

Is it being stored or handled at a temperature at or above its flash point or boiling point. in your case the answer I assumbe is going to be No, and if it was being handled as above then EI15 Part 4 gives you quantiteis at which you should consider doing a full DSEAR assessment e.g. outdoors in a volume greater than 200ltrs or indoors in a volume greater than 25ltrs.

Is there any potential for a release as a mist or spray.  I take it that in your case it is a Diesel tank feeding an item of equipment under gravity so therefor at low pressure so there is no risk that mist or spray could form from a leak in the connections or hoses/pipework. It ther is then you will have to do a full assessment.

How is the tank filled itself. Is it from a Tanker vehicle and if so is it filled under gravity or pumped from the vehicle under pressure or has it got its own suction pump to draw the fuel out of the tanker and into the tank as to create the risk of a potential mist or spray.

Where are the fumes within the ullage space of the Diesel tank expelled to whilst being filled for as the liquid level rises the air in the ullage space has to go somewhere e.g. is there a vapour recovery system on the tanker or a connection to a high level vent position in a safe area or do the fumes exit the vent on the top of the tank and fall to the ground into the surrounding bund forming a potentially hazardous Zone 2 around the vent postion and a potentially hazardous Zone 2 within the bund.

EI15 Part 4 is a good starting place but you need a full understanding of the subject matter to do it correctly.

Any questions then give me a shout as a DSEAR Compliance Manager I am afraid that Hazardous Area Classification, ATEX Installation works ATEX Design, Insepection and Testing is all I do for a living.

Ian Bell2  
#7 Posted : 13 February 2022 14:25:20(UTC)
Rank: Super forum user
Ian Bell2

There are 2 standards for assessing the Zones that you could use.

EI15 – Energy Institute Code of safe practice for area classification for flammable liquids

According to EI 15 diesel is a category C, Class III(1) – flashpoint  55oC + and handled below flash point.

Section A1.2 Mists or sprays & Section A1.4 Class II and III products, in summary say the following

Assuming UK conditions and the diesel cannot increase in temperature or become pressurised (other than from a low head of pressure in a storage tank), as you have already identified.

Provided the diesel stays at least 5oC below its flash point, which it will in the UK  - a hot day is circa 35oC, then EI15 says that hazardous area classification isn’t required for Class III diesel products in a storage installation.

For a spray leak to be of much concern the resulting spray cloud would have to be so dense as to be difficult to see through. At an attended fuel tanker off load, shut down would be expected to very quick by the tanker driver.

Personally I’ve never seen a tanker loading operation suffer a ruptured hose when off loading etc, small liquid drips/dribbles but nothing serious.

I used to work for an organisation that sprayed diesel into the exhaust of an aircraft engine – no ignition, no problems.

BS60079-10-1 Explosive atmospheres

If you plug in diesel properties to the various formula in BS60079-10-1 April 21 edition for either a pool release or spray release.

Assume a 5m dia pool, molecular weight circa 180kg/kmol, diesel vapour pressure circa 5kpa, static pressure for a tank of circa 0.3bar (5psi) results in-

Liquid pool evaporation Qg = 4,69 x 10^-7 m3/sec volumetric   release rate from the pool i.e. very little evaporation of the liquid

Road tanker leak

Spray release treated as a vapour for a 1mm area hole (Table B1), equation B5, Wg = 2.84x10^-8 kg/sec mass release from the tanker hose

For a ‘Secondary’ grade release – a reasonable assumption for a tanker loading. Assume outdoors location, with a wind speed of 0.3m/s (Table C1) . Dilution is confirmed as ‘HIGH’

‘Availability’ should be at least ‘Fair’, more likely ‘Good’. Not ‘Poor’ for an outdoors case.

Hazardous area distance, for a ‘Heavy Gas’ is much less than 1m

The overall result gives a ‘Non hazardous’ zone, as expected.

A Kurdziel  
#8 Posted : 14 February 2022 09:34:33(UTC)
Rank: Super forum user
A Kurdziel

Ian so this means that despite diesel fuel now being regarded as highly flammable, in reality this only applies if it is  a mist and if the ambient temperature is a good deal higher than might be expected in the UK  ie 55 °C plus.

chris42  
#9 Posted : 14 February 2022 10:56:27(UTC)
Rank: Super forum user
chris42

Or if it goes onto a surface that will heat it above its flash point of 55 DegC, where it will give off a flammable vapour. You would then still need an ignition source for there to be a problem.

The stuff (diesel and similar ie Kerosene heating oil flash point of 57 DegC) is exactly the same as before the definition changed from 55 to 60 DegC, so likely all the controls you had in place before are still good. It’s just they were just outside the definition and are now inside it. You should really have a document (DSEAR assessment) to confirm it is all good.

Ian Bell2  
#10 Posted : 14 February 2022 12:06:21(UTC)
Rank: Super forum user
Ian Bell2

Diesel is classed as 'flammable' not highly flammable. H226

Its properties as such are low risk from the DSEAR point of view. As a bulk liquid fuel it is difficult to ignite.

But as Chris42 has said your DSEAR assessment should consider the overall use/work situation - not just the basic properties of diesel. Completion of an ignition assessment being a key part of the DSEAR assessment.

Spillage onto hot surfaces

Spray leaks from pipe flanges etc

It is correct diesel is only under DSEAR because of the technical change back in 2015 on the definition of a flammable liquid

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A Kurdziel on 14/02/2022(UTC)
A Kurdziel  
#11 Posted : 14 February 2022 12:57:56(UTC)
Rank: Super forum user
A Kurdziel

now I get it!

peter gotch  
#12 Posted : 14 February 2022 14:42:59(UTC)
Rank: Super forum user
peter gotch

GW - before the reclassification of diesel you had to do a risk assessment (Management of Health and Safety at Work Regulations 1992, then 1999) which should have considered any fire and explosion risks.

Now you have to do a risk assessment to comply with DSEAR.

But, DSEAR doesn't say that this risk assessment has to be separate from any other risk assessments for the storage and use of diesel, NOT that the document has to have the title DSEAR (or anything else - you could call it e.g. an Operating Procedure).

So, unless your assessment to comply with MHSWR was not "suitable and sufficient" or if the risks have actually changed, it seems to me that the reclassifcation of diesel in terms of the application of DSEAR is irrelevant.

One of the problems that has resulted from the UK's approach to "transposition" of EC health and safety directives via "copy out" (supposedly to avoid "gold plating" EC Directives) has been a multitude of different requirements for risk assessment when very often just one for each task would be better.

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A Kurdziel on 14/02/2022(UTC)
chris42  
#13 Posted : 15 February 2022 13:40:51(UTC)
Rank: Super forum user
chris42

The thing with general H&S people trying to look at DSEAR issues is that the two pieces of guidance which would help people get an idea are not HSE documents, but a BS and an industry guidance document. They cost £400 & £168, so £568, so not exactly peanuts. Yes, aimed at those experts as above, but are also useful for the generalist H&S people whose jobs skirt around the edges of DSEAR. Those that would like to have knowledge of when to bring experts in and when they can deal with simpler things themselves or just have questions like the OP.

H&S guidance in all forms should be either free or reasonable cost price, IMHO.

Chris

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RVThompson on 15/02/2022(UTC)
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