Definitions. ATEX The term used to refer to the EU Atmosphères Explosibles Directives DSEAR Dangerous Substances and Explosive Atmospheres Regulations

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1 DSEAR and COMAH Awareness for IOSH 20 th April 2017 Definitions Dangerous Substance Explosive, extremely flammable, highly flammable or flammable substance i.e. Any substance capable of forming an explosive atmosphere in air ATEX The term used to refer to the EU Atmosphères Explosibles Directives DSEAR Dangerous Substances and Explosive Atmospheres Regulations COMAH Control of Major Accident Hazards 1

2 Acetylene Fire COMAH Addresses Larger Hazards 2

3 Legislation UK Regulation - COMAH Control of Major Accident Hazards Regulations 2015 Implement Directive 2012/18/EU (Seveso Directive) Aim to limit the potential for major accident hazards at industrial sites and ensure appropriate measures are in place for emergency response Came into force 1 st June 2015, replacing the 1999 Regulations 3

4 What is a COMAH site? A COMAH site is one that stores a sufficient quantity of dangerous substances to fall into the definition of an Upper Tier or Lower Tier site. Schedule 3 of the Regulations provides the substances and stored quantities that may qualify a site as a COMAH establishment. There are 48 named substances as well as substance groups with associated threshold quantities to determine whether a site is upper or lower tier. COMAH Summary of the Main Requirements Duties relevant to all sites Notification Hazardous Substances Consent (HSC) Major Accident Prevention Policy (MAPP) All measures necessary Duties relevant to Upper Tier sites Prepare a COMAH safety report Prepare and test an on-site emergency plan Supply information to local authorities for off-site emergency planning purposes Provide certain information to the public 4

5 COMAH Safety Report A COMAH Safety Report demonstrates how a high hazard site controls the risks associated with the materials and processes on site. The Safety Report includes a risk assessment to identify and understand the hazards on site. The other sections of the Safety Report then demonstrate the systems in place to control these hazards and mitigate their consequences. The preparation of a Safety Report will highlight any shortfalls in the physical plant, its operation, management systems or emergency preparedness. Substances Named Substances Hydrogen Chlorine Hydrogen Sulphide Oxygen 3-(2-Ethylhexyloxy)propylamine Categories Health Hazards: H1, H2, H3 (Toxics) Physical Hazards: P1 P8 (Explosives, flammables, oxidisers, self reactive chemicals, peroxides and pyrophoric compounds) Environmental Hazards: E1, E2 Other Hazards: O1 O3 (Substances carrying specific hazard statements) 5

6 Substances COMAH substances can be restrictive, other hazardous materials and processes may be present on site Should be identified through compliance with other regulations such as DSEAR, COSHH, HSWA It is important to have systems in place to identify these hazards A non-comah substance is not non hazardous! 2015 Regulations The 2015 Regulations came into force on the 1 st June 2015, with the HSE demanding much more from the Safety Reports in terms of supporting evidence, particularly for the ALARP demonstration. Introduction of Globally Harmonised System (GHS) labelling led to reclassification of substances and potential changes to site COMAH status. Changes to requirements for emergency response planning Public information requirements for lower tier sites Changes to the Safety Report Assessment Manual (SRAM) criteria requiring greater detail and supporting evidence to be supplied within the Safety Report 6

7 COMAH Prosecutions and Enforcement Cristal Pigment UK Limited 3 m (October 2016) Roxel (UK Rocket Motors) Ltd 386,000 (July 2016) Buncefield Total 3.6m with 2.6m costs Hertfordshire Oil Storage Limited 1.45m with 1m costs British Pipeline Agency Ltd 300k fine 480k costs Ineos Enterprises Group Improvement Notice Contract Chemicals Improvement Notice Valtris Speciality Chemicals Limited Improvement Notice PLUS costs of reworking Safety Reports HSE charge for reviewing and inspecting so repeat work is extra cost! UK Regulation DSEAR Dangerous Substances and Explosive Atmospheres Regulations 2002 Enacts ATEX 1999/92/EC into UK law Aim was to harmonise standards across EU Regulations came into force in Dec

8 Importance of DSEAR Very few COMAH sites are not subject to DSEAR Compliance with DSEAR is a benchmark for the Process Safety technical criteria and is also considered as part of Mechanical criteria As part of the demonstration for Regulation 5, all sites must consider any benchmark standards DSEAR assessment will cover substances and events outside the scope of COMAH e.g. dust explosions Control of ignition sources is a key safeguard against major accident scenarios involving flammable substances DSEAR Summary of the Main Regulations Regulation 5 Requires employers and the self-employed to assess risks to employees and others whose safety may be affected by the use or presence of dangerous substances at work (Risk Assessment) Regulation 6 Sets out how the risk to safety from dangerous substances should be eliminated or reduced (Elimination & Risk Reduction) Regulation 7 Contains specific requirements to be applied where an explosive atmosphere may be present (in addition to the requirements in Regulation 6) (Area Classification & Equipment Selection) Regulation 8 Requires the provision of arrangements to deal with accidents, incidents and emergencies (Arrangements) Regulation 9 Requires the provision of information, training and instruction on dangerous substances (Information & Training) Regulation 10 Requires the identification of pipes and containers where these contain dangerous substances (Hazard Contents) 8

9 DSEAR Prosecutions and Enforcement Batley Foundry Limited 15,000 (August 2016) Sears Manufacturing Co (Europe) Ltd 40,000 (April 2016) SAFC Hitech 120,000 (April 2013) Redmondis UK Ltd Improvement Notice Catalloy Limited Improvement Notice Itac Ltd Immediate Prohibition Notice Delamere Cabinet Makers Ltd Immediate Prohibition Notice Bosley Wood Mill Immediate Prohibition Notice (Fatal Accident August 2015) Flammable Substances 9

10 Flammable Substances In teams, try and identify:- What flammable substances are used on your site? Gases Liquids Dusts Flash Point lowest liquid temperature at which, under certain standardized conditions, a liquid gives off vapours in a quantity such as to be capable of forming an ignitable vapour / air mixture Petrol FP = -40 C Diesel FP = 50 C Ethanol Port FP = 38 C Whisky FP = 29 C Absinthe FP = 13 C 10

11 Flammable Ranges of Typical Materials Carbon Monoxide Methane Propane Hydrogen Acetylene Percentage of Explosive (Flammable) at STP Gas or Vapour in Air Auto Ignition Temperature (AIT) The Auto-ignition Temperature of a chemical is the lowest temperature at which a material will ignite without an external source of ignition. Lube oil 230 C Diesel 230 C Methane 540 C Hydrogen 560 C Ammonia 630 C 11

12 Ignition energy Minimum quantity of Energy to needed to Ignite an Ideal mixture of a specific flammable Gas, vapour or dust and air This is normally measured in microjoules (μj) and varies from substance to substance Typical gas and vapour values lie between 20 and 300 microjoules Typical dust values lie between 1000 and microjoules Flammable Properties of Dust Dusts can ignite in either layer or cloud form Dusts and vapours behave differently: spread of flammable atmosphere sensitivity to ignition Gas or vapour cloud eventually dispersed by ventilation Dust emission creates cloud, settles as layer, can be disturbed as a cloud again Risk assessment and Area classification should take this into account 2 m Glass 25 W Flammable dust cloud 12

13 Imperial Sugar Why did this happen? 13

14 Risk Assessment Risk Assessment Every activity involving a dangerous substance MUST have a risk assessment in place It should consider The consequence of a fire or explosion It must identify A basis of safety The activity should only go ahead if the risks are tolerable Overlap with COMAH Be sure not to duplicate risk assessments COMAH RA s may miss DSEAR scenarios e.g. flammable gas cylinders, gas metering houses etc. 14

15 DSEAR Hierarchy of Control Prevent Flammable Atmosphere Formation Control Ignition sources Mitigate Effects of Explosion/Fire Prevention How can we prevent a flammable atmosphere forming? Substitute by less or nonhazardous materials Limit amount of flammable materials Containment Ventilation to extract, dilute or disperse 15

16 Control of Ignition Sources What ignition sources can you think of? How can they be controlled? Electrical equipment Normal Operation Faults Mechanical equipment Sparks Friction Hot surfaces Vehicle engines Reformer tubes Naked Flames Certified equipment Haz area inspection Retrospective assessment Maintenance procedures Certified equipment Restrictions on access Can t be controlled! Hot work controls Smoking Mitigation of Effects How can the effects of a fire or explosion be mitigated? Exclude people from the zones Deluge systems ROSOVs Engineering measures Explosion panels or suppression Pressure containment PPE Emergency response 16

17 Mitigation of Effects Is the Risk Tolerable? 17

18 Vehicle Impact With Hydrogen Cylinders Vehicle Impact With Hydrogen Cylinders 18

19 Ways to reduce the risk Eliminate hydrogen from the process Eliminate vehicles from the site Control ignition sources Pipe in the hydrogen from an alternative location, removing all portable cylinders Install robust crash barriers Relocate the cylinder bank behind the wall Vehicle Impact With Hydrogen Cylinders 19

20 Sample Actions Arising From DSEAR RAs Sample Actions Arising From DSEAR RAs 20

21 Sample Actions Arising From DSEAR RAs Hazardous Area Classification 21

22 Hazardous Area An area in which an explosive gas, mist or dust atmosphere is or may be expected to be present, in quantities such as to require special precautions for the construction, installation and use of equipment The process to identify these areas is Area Classification So as to select equipment for installation within these areas that has been designed, constructed and tested so as to prevent means of ignition Area Classification Zones Zone 0/ 20 present continuously or for Long periods or frequently Zone 1/ 21 Likely to occur in Normal operation occasionally Zone 2/ 22 Not likely to occur in Normal operation and will persist for a short time 22

23 Sample HAC Drawing Area Classification in practice Solvent Storage Tank Single Mechanical Seal Pump Agitated Reactor Vessel 23

24 Points of Emission Solvent Storage Tank Single Mechanical Seal Pump Agitated Reactor Vessel Zone / Solvent Storage Tank Single Mechanical Seal Pump 1 Agitated Reactor Vessel 24

25 Hazardous Area Equipment Equipment Marking New Equipment Category Gas Group εx II 2 G IIB T3 Equipment Group Gas Temperature Rating 25

26 Equipment Categories Zone Category & 2 2 1, 2 & 3 Equipment Selection Which zones could equipment bearing these nameplates be used in? εx II 3 G Zone 2 εx II 2 G Zone 1 and 2 26

27 ATEX Nameplate Electrical Equipment Built to:- Not create an ignition source Keep out flammable gases or dusts Contain an explosion Must be correctly specified, installed and repaired by competent people Many apparatus types require routine maintenance or inspection to ensure safe use 27

28 Mechanical Equipment Built to:- Not create an ignition source Contain an explosion Must be correctly specified, installed and repaired by competent people Many apparatus types require routine maintenance or inspection to ensure safe use Pre 2003 equipment can continue to be used if assessed for suitability Equipment Ignition Sources Electric Motor Oiled Bearings Tyre coupling and Guard Single Flushed Seal Pumping hot oil at 280 C in a T3 Area 28

29 Equipment Ignition Sources Ignition Source Shaft snapping Bearing heating up Seal dry running Coupling catching on guard Motor sparking Hot surface Static accumulation Normal Operation or failure Rare failure Expected failure Expected failure Expected failure Normal operation Normal operation Normal operation Electrostatic Ignition Sources Earth all conductors Fixed equipment to a known earth Mobile equipment with grounding clamps Earth before introducing flammables! Wear the standard issue dissipative footwear Tester to be installed Avoid insulating materials Plastic containers larger than 5L Other plastic items unless assessed Remove accumulation mechanism No splashing liquids Relaxation time for insulating liquids 29

30 Signage Warnings before entering an area Likely to be reviewed across the site. Ensure you and any visitors understand what they mean:- No unauthorised sources of ignition Correct PPE Identification of Equipment and Containers All equipment and containers must be identifiable Marking and labelling to be improved Training Ensure containers are not stored in the wrong store or location (e.g. flammable pressurised cylinders not stored with oxygen) 30

31 Emergency Response If you are a COMAH site, likely to be driven by COMAH requirements Ensure planned response is proportionate to risk. Consider life safety first but also consider environmental effects and asset protection. Don t rely on the fire service to protect your business they will save lives but not risk themselves to preserve assets. If All Else Fails RUN! 31

32 Any Questions? RPS Risk Management 105 Dalton Avenue Birchwood Park Warrington WA3 6YF Tel: +44 (0) Steve Sherwen Mob +44(0) Louise Platt Mob +44(0)