Dsear

[Redone]

The use of flammable gases, such as acetylene, for welding and the handling and storage of flammable wastes such as waste fuel oils from a garage service bay come under DSEAR, but is there a cut off for quantity on site where the reg's don't apply?

Would one set of welding equipment qualify for DSEAR to apply, I'm thinking if the guy using the tackle performs his RA prior to use, with a written safe use policy on site, this would be adequate.

Am right or wrong?

[kurnal]

This is how I see it but is not necessarily gospel truth because I dont have desear in my competance package (at the mo- going on a course soon)
Its not down to quantity, its down to the risk of an explosive atmosphere arising that could be a hazard, and if it does arise how often and why. Then to look at the necessary zoning of areas where this atmosphere may arise and provision of safe equipment and working practices in those areas.

Theres no reason for waste oils to be a hazard under DSEAR unless they are contaminated with petrol.  But if you drain a vehicle petrol tank in a workshop or spray flammable paints then this is definately a DSEAR matter.  Similarly just because you use oxy acetylene welding theres not a need for a dsear assessment- it would take a failure of several safety precautions for a leak of acetylene and would be a most unusual event.

You do need a safe system of work for all these things and to consider the liklihood of an accidental release which may lead to problems. Part of the safe system of work may be a proper storage bin for small quantities of flammables up to 50 litres in the workplace, a purpose built store for up to 150 Litres and a purpose built external store for over 150 litres of flammables. These were the recommended limits under the old HFL regs which have been carired forward as good practice.

[Redone]

Cheers for the input Kurnal, what made me sit up was the lubricant store, over 2000ltrs off a battery charging area both vented and valve regulated charging, fire door removed to provide enough width to allow barrels in!

[Chris Houston]

Like Kurnal I only have a basic understanding of the DSEAR Regs, but I don't think the philisophy ought to be:

"as long as the guy who brings it to site does a risk assessment, then it is ok"

It should be more like

"this is my site and I want to know that there is no alternative means of doing the tasks without the need for these danngerous gasses before he even thinks about bring them to site".

I'm not sure the bloke who brings it to site the best person to assess the risk, as he is unlikely to know what else is going on there.  

And to add to Kurnal, not from a legislation point of view, but just a pragmatic one, it might not take a failure of the safety systems associated with the welding to cause a problem, the problem might be a fire starting nearby from another source, then there would be a problem.  The rules about quantities of flammables are a good benchmark, but really the starting point should be to try and remove any flammables, the flame proof cabinets are further down the ranking in the list of best control mechanisms.

[Redone]

The welding equipment is in use occasionally within a vehicle service workshop, by competent persons.  The battery charging room is off the workshop.

My concerns are around the oil store/battery room... fumes given off, poor ventilation and F/R from these rooms to workshop.

I'm sure I recall this quantity 2000ltr requires access from outside the building.

[peanut]

If the premises is one that the FSO applies to (it sounds like it is) then DSEAR does not apply to the extent that the FSO applies.  In otherwords, the FSO makes specific provisions for dangerous substances which take precedence over DSEAR (see Article 47 of the FSO).  This is something which has been missed by the government's guides and PAS 79.

Whilst this is unlikely to affect the technical measures provided, it is important to be clear which legislation is applicable.

[William 29]

I take your point peanut.  But if you look at article 9(2) of the Fire Safety Order it states that where a dangerous substance is present or liable to be present the FRA must include consideration of the matters in schedule 1.  (The definition of a dangerous substance is given in the interpretation section of the Order)

When you look at the info required in schedule 1 it is a copy almost of the info required under DESEAR.  Whenever we come across a dangerous substance in an FRA we also include an appendix detailing the substance under the headings below.  In my view this is a requirement of the Order.  If anyone wants a copy of an example e.g. acetylene then let me know, you can all pull it to pieces (sorry constructive criticism!)

   Chemical Formula
   Description
   Flammability
   Suppliers information:  
   Circumstances of work involved:
   Amount of substance: .
   Involvement and impact of other dangerous substances:
   Safe handling and storage and precautions to be taken when handling:.
   Precautions to be used in storage.
   Maintenance activities:
   Likely effect of the safety measures required by the Order:
   Likelihood of an explosive atmosphere:
   Likelyhood that ignition sources (e.g. electrostatic charges) will be present, active and effective.
   Scale of anticipated effects:  
   Additional safety information:

[peanut]

Yes, William 29, I agree that the Order makes requirements with respect to dangerous substances.  This is exactly my point - DSEAR makes requirements which 'relate' to provisions made under the Order and thus DSEAR does not (generally) apply any longer.  I appreciate that the provisions of  the Order are almost identical to those made under DSEAR, and thus there is unlikely to be any practicable difference between the two pieces of legislation.  I am just trying to make the point that one needs to be careful that they are clear which piece of legislation they are trying to comply with.

[davio1960]

Question
Why is the occupant using acetylene?

Is it because he has not attempted to reduce risk by changing to a substance that is less hazardous article 12(1)
Is it because some suppliers of this hazardous chemical indicate it is safer than oxy propane?
Is it that oxy-acetylene provides the supplier with a higher profit margin than other less hazardous substances?

If all the business consists of is tyres and exhausts why use oxy acetylene at all. There are some none flamming products on the market and I understand our neighbours across the water have produced an electrical gizmo for heating exhausts and brake linnings with no direct flame.

As a person who attempts to view the various "places" I visit in a balanced and not profit approach the real thingmy is the emergency services will take drastic steps when acetylene is or believed to be involved in fire  and his insuarance will go through the roof after he has a fire.
He will have a fire, garages often have fires, and fire services are only infrequently called. The insurance premium will increase because of all the claims for loss of earnings from everyone and his dog not allowed to enter their work areas cos they're within the 200m cordon that the fire and rescue service will evacuate.
Why not just get rid or change or ?
Davio

[Redone]

The occupant tells me it is used for general welding, cills etc, but really needs it for the heating up of bearings that have become fixed, especially on HGV's, admitted this is rare, but informed me no other equipment will provide the temperature required.

Procedure wise, the equipment is wheeled to the assembly point during evac.

[William 29]

Redone,  I have done an FRA where acetylene is used for the exact same circumstances.  I suggested safer alternatives but got the same response in thast other gases will not provide the temps to get bearings or wheel nuts free from vehicles etc.  I included a safety data sheet similar to the one you have requested from me.  Hope it helps......