Gary Horgan (CMSE Consultancy Manager at the Chris Mee Group) and his team are outlining the path for companies to ensure they are compliant with Part 8 “Explosive Atmospheres at Places of Work” of the Health, Safety & Welfare at Work (General Applications) Regulation 2007 in a series of focussed blogs.
This is Blog number 2 in the series.
- Blog 1, Explosion Accidents 2020
- Blog 2, Preparing for an Explosion Protection Document
- Blog 3, Summary of Legal Requirements
- Blog 4, What Are Explosions?
In our second process safety blog in this series, I want to talk about the type of information you need prior to preparing for the generation of an Explosion Protection Document (EPD), as required in Ireland under Part 8 “Explosive Atmospheres at Places of Work” of the Safety, Health & Welfare at Work (General Application) Regulations 2007. It is also fair to say that some clients are not aware of this regulation and the requirement for an EPD, and request us to complete an ATEX Report.
The word ATEX comes from the ATEX 137 Directive 99/92/EC, or ATEX Workplace Directive, which deals with the precautions to be taken in workplaces where explosive atmospheres might be present due to flammable dusts vapours or gases (or mixtures of these). This directive is transposed into Irish legislation as stated above or below in the UK.
In the UK, our clients request the equivalent DSEAR Report, coming for the Dangerous Substances Explosive Atmosphere Regulations 2002. The prepared Explosion Protection Document, ATEX Report or DSEAR Report often very similar in construction i.e. at a simple level it outlines how you manage your explosion hazards (gases, vapours or powders) at your facility.
It is important to note also that the requirement of an EPD is addition to any other Process Safety Reports and Legislation that may be applicable to your facility; Seveso III or COMAH i.e. dealing with potential Major Accident Hazards.
As a starting point, when CMSE Consultancy are appointed to prepare an Explosion Protection Document for a client, and prior to a site visit, we prepare a list of information we require to start the project. This information (non-exhaustive list) includes the following (Please note we will also cover these in greater detail in later blogs):
- Overview of the company & activities (it is important to note that we are not just talking about manufacturing facilities, it could be warehousing, R & D, utilities, processing, fuel storage, petrol stations, energy generation, waste generation, process waste water treatment)
- Are there any previous EPD, ATEX explosion safety reports available?
- List of the potential flammable substances; gases, vapours & powders
- Copy of relevant Safety Data Sheets (SDS) or Dust explosion testing reports
- History of any explosion related incidents?
- Process description in each potential area where flammable use is foreseen
- Activities involving flammables (raw material, intermediate products, finished products) to consider including the receipt, storing, transporting, handling, processing from raw material in to finished product or hazardous waste.
- Have you considered how you may end up with the formation of an explosive atmosphere i.e. normal operation, abnormal operation, maintenance, and emergencies?
- Have you classified work areas into the likelihood of a potential explosion atmosphere existing?
- Have you completed specific ignition risk assessments in potential flammable areas?
- If a company already has a level of explosion safety compliance, what do you have in place in each potential classified area?
- Basis of explosion safety controls – engineering
- Basis of explosion safety controls – organisational
- Do you have a schedule of Ex-rated equipment in your flammable areas?
- What emergency procedures/ resources are in place to deal with potential flammable atmospheres?
- What Preventative Maintenance Programs are in place?
- What relevant standard operating procedures are in place?
- What Permit to Work systems are in place?
- What control of contractors procedures are in place?
- What Explosion Safety Training was completed?
- What type of Personal Protective Equipment is used?
- Are potential flammable areas clearly indicated?
CMSE Consultancy provide a professional Health, Process, Explosion & Fire Safety Services.
If you require further information or assistance please contact us via email at info@cmse.ie, by phone at 021 497 8100 or start an instant chat with us via the chat box in the bottom right-hand corner of your screen.
Some useful references that may assist in gathering information on the explosion properties of dust/ powders include;
- GESTIS Substance Database; dguv.de/ifa/stoffdatenbank
- BIA Report 13/97; dguv.de/ifa/publikationen/reports-download/bia-reports-1997-bis-1998/bia-report-13-97