DSEAR/ATEX UPDATE

The ATEX 137 Directive was formally adopted into law in the UK in 2003 and requires that all companies operating with areas classified as “Hazardous” classify their production areas into zones and assess the risks both to their employees and their plant assets. So why are we still getting enquiries from people asking “What is DSEAR all about, and does it apply to me?” We believe there are several underlying reasons behind this:-

Firstly, some people have found it difficult to understand the standards that support the legislation, particularly those associated with non-electrical ignition sources. It’s one thing to have to spend money on achieving compliance, another if you misinterpret the requirements of the legislation and end up spending money and still find that you are not compliant. Unfortunately, lack of understanding of the requirements is no excuse for lack of action in the eyes of the HSE, and indeed the insurance companies. Certain aspects of DSEAR/ATEX can appear confusing, but this legislation is all personnel safety, allowing the workforce to understand the issues associated with their place of work, and ensuring that the number of accidents and injuries to persons operating in these industries is reduced.

Secondly, the devastating and very public incident at Buncefield in December 2005 has resulted in the HSE putting a higher priority on health and safety of operations involving flammable materials. In fact, the HSE have already started to bring prosecutions to court for non compliance with DSEAR/ATEX, (and have a 100% conviction record to date). Whilst this is enough of an incentive for most organisations to get moving towards compliance at the earliest opportunity, there are still some who prefer to ‘stick their heads in the sand’, and hope that the HSE doesn’t come knocking on their door!

So how can PROjEN help ?

PROjEN has been supplying consultancy and engineering services associated with DSEAR/ATEX for a number of years now, and have successfully supported a number of well known clients through the compliance process with the minimum of disruption and cost. This has all been achieved by following a scalable and phased approach to compliance developed by our in house compliance engineers.

Whilst all clients are in a different position in relation to DSEAR/ATEX compliance, there are a number of common steps that can be applied to the compliance process. We have developed a simple phased approach designed to:-

• Minimise the costs
• Make the cash flow predictable by spreading expenditure into ‘bite sized pieces’
• Allow the client to develop his understanding of the compliance issues.
• Demonstrate to the HSE that the client understands the compliance process and is moving forward in a logical fashion.

The following is a typical approach to compliance, and has been included here to demonstrate what activities may be associated with the various phases:-

Gap Analysis

This generally involves 1-2 days on site, reviewing the client’s installations, understanding the processes and talking to maintenance and operational personnel. The output from this process is a report detailing the client's current position and highlighting any critical issues, an outline of the ongoing compliance project (a compliance strategy), and indicative costs for the next recommended phase of work (if required).

Phase 1 – Key Compliance Activities/Documents

This phase concentrates on the key compliance activities and associated documentation:-

Area Classification – This involves the quantification of any hazardous areas and starts with a review of COSHH/material data sheets in order to allow an inventory of flammable materials to be created. The process then moves on to review the storage and use of any flammable materials, (including dusts and fibres), and then formally assigns the appropriate hazardous area zones and extents. The output of this exercise is a report and a set of drawings.

DSEAR Risk Assessment – This is a thorough review of the process operations carried out on the plant(s). It is designed to highlight any risk associated with these operations, and examines the validity of any risk reduction measure put in place. The output of this exercise is a report detailing the review process and highlights any improvements necessary to reduce risk to an acceptable level.

Explosion Protection Document – This document, (EPD), is a vital part of the compliance process. The EPD sets out to give an overview of how the client manages their DSEAR/ATEX compliance. The EPD is designed to be an overview/signpost document laying out the overall compliance strategy and ‘pointing’ to the detailed compliance documentation. It covers a wide range of compliance related topics.

Phase 2 – Equipment Inspection/Risk Assessment

Once the hazardous area zones have been defined, then a list of all ignition sources needs to be gathered, (This includes, Instruments, electrical, mechanical, process, static, lightning etc). This inventory forms the basis of the list of equipment requiring risk assessment and inspection.

Phase 3 – Replacement of non-compliant equipment

Any equipment which ‘fails’ phase 2 risk assessments/inspections needs to be changed and/or repaired before being re-inspected. This phase sees the EPD finalised and the inspection/maintenance regimes being put in place.

The above information describes PROjEN’s approach to compliance. Although it may seem a daunting process at the outset, hopefully it can be seen to be rarely as ‘painful’ as first imagined.

PROjEN is involved with a number of compliance activities for a diverse range of clients. The following is a brief case study concerning a current DEAR/ATEX compliance project for a well known multinational company.
Case Study – Specialist Equipment Compliance

In January 2007 we were contacted by an existing client to carry out a project on behalf of their R&D department. The project involved the use and production of flammable materials, (both vapour and dust) and was therefore covered by the DSEAR/ATEX regulations. The core compliance activities were carried out at the start of the project which formally assigned the zones, and highlighted any risks which required addressing as part of the design process. The zone definition allowed the appropriately certified equipment to be sourced in all cases apart from one. Due to the innovative nature of the research being carried out, one item of equipment, (assembly), was only available from an American manufacturer. Unfortunately, the United States are not party to the ATEX regulations, and generally design their products to US standards only. However, as the assembly was designed for use in a Zone 2/22 area, it is possible for the manufacturer to carry out a self certification, although in this case the manufacturer in question did not have any prior experience in the self certification process. As this equipment was vital to the project, one of PROjEN’s compliance engineers was flown to Boston to review the equipment and advise the manufacturer on how to self certify the equipment. Our engineer reviewed all of the proposed equipment associated with the assembly and advised where ATEX approved equipment must be used, and where risk assessments should be carried out.

The self certification process involves the production of a technical file containing:-

• Description of Equipment
• Principles of Operation
• Task analyses/Risk Assessment
• Ignition Hazard Risk Assessment
• Surface Temperature measurement specification
• Component Velocity Calculations
• Stability Review/Calculations
• Operation and Maintenance Procedures
• Intrinsically Safe System Calculations (DSDs)
• Equipment Certification
• Engineering Drawings

Our compliance engineers supported the manufacturer through the design process and audited all of the design documentation, calculations and associated risk assessment paperwork. PROjEN then guided the manufacturer through the production of the technical file, and interfaced with the notified body, (TUV), to resolve any technical issues. Once completed the technical file was deposited with TUV.

Once the assembly was complete, PROjEN’s compliance engineer attended the Factory Acceptance Test for the equipment, and carried out a detailed inspection of the equipment versus the requirement of the ATEX regulations.

Although not a typical compliance project, this assignment did serve to demonstrate PROjEN’s ability to work in conjunction with a number of organisations involved with a complex compliance issue. This work required innovative thought and on occasions, remote assistance to the manufacturer who was 5 hours behind UK time. The feedback from the notified body, (TUV), was very positive and PROjEN were complemented on their thorough but pragmatic approach to this project.

If you do not fully understand the legislation or if it even affects you, or you have made some progress, but are finding it difficult to see the way forward to compliance, why not phone or e-mail one of our compliance engineers to discuss your requirements, We have a vast range of knowledge in all aspects of DSEAR/ATEX compliance, and are always willing to offer help and advice.