Risk Assessments v DSEAR v ATEX

Written by Craig Ayling

This is a good question and we have dealt with many clients who have implemented very good measures against fire and explosions but have fallen significantly short on the risk assessment. DSEAR places great importance on and requires a documented risk assessment. The risk assessment may be qualitative or quantitative, it may be 20 pages, or it may be 200 pages long, DSEAR does not require any set style of risk assessment but ultimately it should be tailored to suit the unit operations being assessed. Over the next couple of paragraphs, we will discuss some of the reasons for completing the DSEAR risk assessment and some of the added benefits it may provide.
The first reason is fairly straight forward; without producing a formal and coherent risk assessment, how do you know that you have done enough? This will be a key question posed by authorities! Evidence, evidence, evidence! On the other side of the coin, there are also cases where you may have done too much! Almost every company faces the fact that budgets are not limitless and so we must spend this effectively as to not leave other areas vulnerable. A risk assessment is a useful tool for prioritisation and will allow for effective planning and distribution of resources.
The second reason is that DSEAR requires a hierarchical approach when it comes to protecting personnel from fire and explosions. Without completing a DSEAR risk assessment it is very difficult to ensure and demonstrate that this has been followed.
The hierarchical ‘Three Rules of DSEAR approach:
1. Do not have a flammable atmosphere, but if you can’t and you do…
2. Do not ignite it, but if you can’t and you do…
3. Do not hurt anyone.
This means that we explore all practicable options for avoiding flammable atmospheres before we begin implementing ignition source control, beyond this we must then explore all practicable options for ignition source control before we begin implement explosion protection (i.e., explosion venting or chemical suppression). During DEKRA’s long history as DSEAR/ATEX specialists, we have seen many clients jump straight to the use of ATEX certified equipment without looking at ways of reducing flammable atmospheres in size and severity. We have also seen vessels and dust collectors with explosion panels installed when the units have not needed them. The further down the hierarchy you go, the more balls you will be juggling to maintain a Basis of Safety and upkeep may be more cost and resource intensive.
Finally, in completing a documented DSEAR risk assessment, you should end up with a clear and concise guidance pack outlining what keeps your processes safe in respect to fire and explosions. This guidance pack can then be passed on and extend corporate memory beyond the careers of individuals. There have been many occasions where safety has fallen due to staff turnover. Documenting thought processes, reasoning and conclusions are our biggest defence against this.