Dangerous Substances

[BLEVE]

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?

[nearlythere]

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.

[Midland Retty]

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.

[Mike Buckley]

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.

[BLEVE]

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?

[nearlythere]

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.

[dpjohno]

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

[nearlythere]

In total agreement dpjohno

[BLEVE]

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?

 

[nearlythere]

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?

[Tom Sutton]

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  ) ?

[BLEVE]

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.



 

[BLEVE]

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. 

[dpjohno]

There is no cop-out here old chap. I simply bring the matter to the attention of the RP. Best wishes, Dave

[BLEVE]

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.