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FIRE SAFETY => Fire Risk Assessments => Topic started by: BLEVE on July 30, 2010, 08:37:54 AM
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How many people encounter or consider the issue of dangerous substance,explosive atmospheres, associated control measuresand emergency arrangements as a part of the fire risk assessment process.
Do assessors in general have the competence to either carry out this work firts hand or to evaluation the information provided by other parties?
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How many people encounter or consider the issue of dangerous substance,explosive atmospheres, associated control measuresand emergency arrangements as a part of the fire risk assessment process.
I do.
Do assessors in general have the competence to either carry out this work firts hand or to evaluation the information provided by other parties?
In general no but I would recommend that the RP use the services of a DSEAR person same as I would recommend they employ the services of electrician if I came across what I condsidered an electrical fire risk.
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Article 12 of the Reg Ref.(Fire Safety) Order (in England and Wales) states that dangerous substances should be eliminated or reduced, so I would expect to that addressed in the fire risk assessment.
For the most part all competent risk assessors I've dealt with on DSEAR / COMAH sites. or similar, do address the issue of dangerous substances properly, and I think there is good reason for that.
Most responsible organisations dealing with dangerous substances atleast seem more on the ball than your average RP, and employ competent assessors / risk managers on their sites to keep a good eye on things.
(Remember Im only talking about assessors I have dealt with - other members may have come across something to the contrary )
To answer you second question, most of the assessors I have dealt working on COMAH sites seem to have the required competence to manage the risk under the RRO, COMAH, and DSEAR. Only a few have brought in outside specialists to assist them.
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Fine for the big sites, what about the little firms that do some paint spraying etc? It is quite possible for an assessor to walk into a DSEAR situation and the owner of the company not even know (or care) what DSEAR is.
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MB
Thanks, thats exactly the subject I was trying to raise. You would expect the majority of COMAH sites to have a handle on DSEAR but there will be plenty of ordinary run of the mill premises where explosive atmospheres and dangerous substances will be a factor and there will be cases where the fire risk assessor has not identified these issues.
I would not mind trying to expand and discuss DSEAR on the new thread covering that subject but there does not seem to be much activity to date. :(
How many firerisk assessors recognise that a three dimensional explosive atmosphere exists under DSEAR around a bolted flange and that a protracted zone will exist when that pipe line contains a flammable liquid as opposed to a gas?
Again, how is this captured in the proforma type risk assessment?
Similarly, taking account of the FSRRO, how often do we encounter acetylene cylinders and maybe overlook the possibility of replacement for less hazardous agents?
Same goes for conventional or even lithium type battery charging activities, how are we capturing these in our assessments?
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Similarly, taking account of the FSRRO, how often do we encounter acetylene cylinders and maybe overlook the possibility of replacement for less hazardous agents?
What I look for with acetylene welding kits when, depending on the type of welding, there isn't a suitable alternative.
Suitable user checks, maintenance & training. Locate cylinders outside in secure ventilated enclosure away from exposure hazards and pipe to workplace.
This may go some way to preventing the disruption caused when cylinders are exposed to fire.
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Remember, you are conducting a Fire Risk Assessment. DSEAR is a completely different ball game. This is an phrase I used recently in a FRA.
It was noted that flammable gases are in use in the premises. It should be ensured that a specific risk assessment is conducted under the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR).
Similarly, a colleague conducted a FRA at a petrol station. He used the following paragraphs.
In this report an assumption is made that the responsible person is operating the site in strict compliance with the conditions imposed by the licensing authority, in addition to rigid adherence to the guidance issued by the HSE.
The determination of compliance with the relevant statutory provision (see below) is the sole responsibility of the licensing authority.
Petroleum (Consolidation) Act 1928 (as amended by DSEAR)
http://www.hse.gov.uk/fireandexplosion/petroleum.htm
I hope this helps. Dave
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In total agreement dpjohno
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Too be fair, isn't that a bit of a cop out. We may as well say something along the lines of:
We notice that the building is provided with compartmentation and fire detection system, It should be ensured that a specific risk assessment is conducted by another to ensure compliance with the RRFSO!
I do not believe that a suitable & sufficient fire risk assessment can be completed unless :
where applicable dangerous substances and or explosive atmospheres have been suitably assessed by another and correctly interpreted by the fire risk assessor or that they have been assessed by the fire risk assessor first hand.
What caveat do you employ where the emplyer or RP is not obliged to record the findings of DSEAR?
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I'm not completely sure what your expectations are of a FRAer Bleve.
You obviously have a comprehensive knowledge base on dangerous substances and or explosive atmospheres and it is apparent that this is your particular area of expertise.
Fire risk assessments also require a level of knowledge on fire alarm systems, an area you have said you are unfamiliar with.
Does that mean you are not competent to do fire risk assessments?
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Am I right in thinking the Health and Safety Executive (HSE) enforces the DSEAR regulations and ATEX in Industrial Premises, with the regulations being enacted under the Health and Safety at Work Regulations 1974. Local Authorities, Fire Brigades and Petroleum Licensing Authorities are also be closely involved in ensuring compliance.
If so why would the FR assessor need to conduct another RA other than ensuring compliance and I assume s/he would not need to calculate the volume of gas clouds around flanges ( gX uy-sfius/uoi+wtuoiu ???) ?
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NT, Tom,
So I guess we can remove any requirement to assess risk from dangerous substances or explosive atmospheres from the RRFSO?
Anyone carrying out a risk assessment for the RP can simply say "you dont have to bother mate" "The HSE deal with that" or "dont worry pal my risk assessment covers everything but dangerous substances and explosive atmospheres but I recommend you get some one elese to look at it"
or "Oh I see you have had a risk assessment covering GS and ATEX, tell you what I will review it as a part of the fire risk assessment process but have not got a clue what I am looking at.
Risk assessment
9. —(1) The responsible person must make a suitable and sufficient assessment of the risks to which relevant persons are exposed for the purpose of identifying the general fire precautions he needs to take to comply with the requirements and prohibitions imposed on him by or under this Order.
(2) Where a dangerous substance is or is liable to be present in or on the premises, the risk assessment must include consideration of the matters set out in Part 1 of Schedule 1.
SCHEDULE 1
PART 1
Article 9(2)
MATTERS TO BE CONSIDERED IN RISK ASSESSMENT IN RESPECT OF DANGEROUS SUBSTANCES
The matters are—
(a) the hazardous properties of the substance;
(b) information on safety provided by the supplier, including information contained in any relevant safety data sheet;
(c) the circumstances of the work including —
(i) the special, technical and organisational measures and the substances used and their possible interactions;
(ii) the amount of the substance involved;
(iii) where the work will involve more than one dangerous substance, the risk presented by such substances in combination; and
(iv) the arrangements for the safe handling, storage and transport of dangerous substances and of waste containing dangerous substances;
(d) activities, such as maintenance, where there is the potential for a high level of risk;
(e) the effect of measures which have been or will be taken pursuant to this Order;
(f) the likelihood that an explosive atmosphere will occur and its persistence;
(g) the likelihood that ignition sources, including electrostatic discharges, will be present and become active and effective;
(h) the scale of the anticipated effects;
(i) any places which are, or can be connected via openings to, places in which explosive atmospheres may occur; and
(j) such additional safety information as the responsible person may need in order to complete the assessment.
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On the contrary NT
Have a reasonable knowlege of DSEAR, on shore off shore and nuclear safety case field, but my main area of expertise is FRA. I am able to get by wrt fire alarm system design and installation including VESDA but do not consider myself a fire alarm engineer just the same as I can design a suppression system or sprinkler protection system from first principles but not my main stock in trade.
Anyway wrt to alarm systems provided proof of design and maintenance then not a huge problem wrt the FRA.
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There is no cop-out here old chap. I simply bring the matter to the attention of the RP. Best wishes, Dave
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Article 9(2)
Schedule 1 (g) requires that 14 types of ignition sources be consideredin the context that they may be present in or on the premises and that they may become active and effective.
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dp
but is that considered to be a suitable & sufficient risk assessment. Ultimately you are off scot free but the RP is not.
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There is no need to lecture or to quote chapter and verse old boy. If I find a DSEAR substance I ask for the DSEAR risk assessment. If they do not have one, I advise them to undertake one. similarly with plant and machinery, the advice is to operate in compliance with apprpriate HS guidance. Dave
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Flour can be a dsear substance. IMO you cannot complete a FRA without having sight of an existing DSEAR RA or carrying one out on the spot.
Also, and lets be clear, you carry out a FRA but then provide advice to have someone else carry out an assessment of fuel and ignition sources.
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LMAO? Getting a tad pompous now old boy. Do you also undertake the periodic inspect of the electrical installation when necessary? ;-)
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RRFSO
Calls for DS to be considered explicitly lad plus DS can have an immediateeffect on building structure & MOE
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ha-ha lad! I wish. You do yours...I'll do mine....take care. Dave
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So I guess we can remove any requirement to assess risk from dangerous substances or explosive atmospheres from the RRFSO?
Yes, I do not see why it was included in the RR(FS)O because it is dealt with by the HSE and one aim of the RR(FS)O was to reduce all the unnecessary fire legislation and two regulations doing the same job doesn't make sense.
Because it has been included then I would consider ensuring compliance with DSEAR by the FR assessor would suffice. As for the RP it is his/her responsibility under both pieces of legislation and should be made aware of it.
What did surprise me was how close the relevant articles in the RR(FS)O are to the DSEAR almost cut and paste, but it shouldn't, with all the other cock ups from the DCLG.
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never the less it is clearly included and required meaning that we consider it during the fire risk assessment or are capable of understanding a third party report on this matter
Trouble is that the third party report is sometines wide of the mark
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I accept that but it still doesn't make sense to me and I will try to get hold of the consultation document to see if there is any explanations there.
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I comment on hazards present (coshh, hazmat etc). Therefore also, that measures are/not taken to manage them. That's not a get out. You do not need to be an expert in all fields, but you should know your limits, and, what to do if you reach or extend those limits.
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Mr P. I have no problem with someone recognising their limitations.
However, The presence of DS within a building has the potential to compromise the general fire safety arrangements within that building. The RRFSO does not require consideration of COSHH etc, it does specify the consideration and assessment of Dangerous Substances as a part of the fire risk assessment process.
You cannot complete the fire risk assessment in a suitable & sufficient manner by not recognising the effects that the DS has on the general fire safety arrangements. To that end IMO it is not acceptable to simply state that the RP should carry out a risk assessment in compliance with DSEAR etc. Similarly, a number of fire risk assessors may review the significant findings of a DSEAR report without having a clue what they are looking at and in a number of cases DSEAR assessments can and have been carried out by assessors without the competence to do so.
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Mr P. I have no problem with someone recognising their limitations.
However, The presence of DS within a building has the potential to compromise the general fire safety arrangements within that building. The RRFSO does not require consideration of COSHH etc, it does specify the consideration and assessment of Dangerous Substances as a part of the fire risk assessment process.
You cannot complete the fire risk assessment in a suitable & sufficient manner by not recognising the effects that the DS has on the general fire safety arrangements. To that end IMO it is not acceptable to simply state that the RP should carry out a risk assessment in compliance with DSEAR etc. Similarly, a number of fire risk assessors may review the significant findings of a DSEAR report without having a clue what they are looking at and in a number of cases DSEAR assessments can and have been carried out by assessors without the competence to do so.
In essence I would agree with what you are saying Bleve.
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Flour can be a dsear substance. IMO you cannot complete a FRA without having sight of an existing DSEAR RA or carrying one out on the spot.
Also, and lets be clear, you carry out a FRA but then provide advice to have someone else carry out an assessment of fuel and ignition sources.
Hey BLEVE!
I conducted a FRA in a pie shop in the town where they actually use flour to make them! ;D
Do you think I should conduct a DSEAR RA? ???
I think it might be self-raising! ;)
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How many in the F&RS would be qualified or competent to audit a DSEAR FRA?
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How many in your industry would be competent to spell competent? ;D
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Haven't a clue what you're getting at. ??? ;)
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;D A fine piece of editing! lol ;D
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How dare you, you hussy.
Expect a letter from my lawyer soon.
However, you will be glad to know that I do offer quite generous discounts for out of court settlements.
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:o ;D :o ;D :o