Petroleum Road Tanker Workshop Code

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Petroleum Road Tanker Workshop Code A
Regulators Perspective

• John Hazeldean
• Principal Specialist Inspector
• Hazardous Installations Directorate

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Relevant Legislation

• Management of Health Safety At Work 1999
• Work at Height Regulations 2005
• Equipment Protective Systems Intended for Use
  in Potentially Explosive Atmospheres Regulations
  1996 ATEX
• Dangerous Substances and Explosive Atmospheres
  Regulations 2002 DSEAR
• Regulatory Reform (Fire safety) Order 2005

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Relevant Legislation
Chemical Agents (CAD)
European Directives
Workplace
ATEX
Seveso II
UK LAW
Dangerous Substances and Explosive Atmospheres
Regs 2002 (DSEAR)
Control of Major Accident Regs 1999 (COMAH)
Management of Health Safety at Work Regs 1999
(MHSW)
Fire Rescue Services Act 2004
Regulatory Reform (Fire Safety) Order 2005 (FIRE
RRO)
Highly Flammable Liquids Liquefied Petroleum
Gas Regs 1972 (Petroleum Consolidation Act 1928)
Control of Industrial Major Accident Hazards Regs
1988
Fire Precautions Act 1971 Fire Precautions
(Workplace) Regs 1997 (as amended) Fire
Certificates (Special Premises) Regs 1976
Fire Services Act 1947
Repealed Legislation
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Explosion in building handling a flammable gas
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EPS 1996 Regulations

• Implement ATEX Equipment Directive
• Long transition period ended June 2003
• Applies to equipment for use in potentially
  explosive atmospheres
• Places duties on equipment manufacturers
  importers to supply equipment that meets EHSR
• Covers all ignition sources

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DSEAR 2002

• Implements the ATEX User Directive
• Implements the fire and explosion aspects of the
  Chemical Agents Directive
• Fully in force from June 2006
• Predominately goal-setting legislation
• Supported by guidance and ACOPs

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Guidance on DSEAR L138
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Status of ACOPs

• Special legal status
• If you follow the advice you will be doing
  enough to comply with the law. You may use
  alternative methods but if you are prosecuted
  you will need to show that you have complied with
  the law in some other way or a court will find
  you at fault.

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Status of Guidance

• Following guidance is not compulsory you are
  free to take other action. But if you follow the
  guidance you will normally be doing enough to
  comply with the law. Inspectors seek to secure
  compliance with the law and may refer to this
  guidance as illustrating good practice.

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Requirements of DSEAR
To ensure that the risks from Dangerous
Substances are either eliminated or reduced SO
FAR AS IS REASONABLY PRACTICABLE

• Assess the risks of work activities involving DSs
• Eliminate or reduce risks sfairp
• Classify places where explosive atmospheres may
  occur into zones and provide appropriate
  equipment
• Provide information, instruction and training
• Provide systems, equipment and procedures for
  emergencies

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Scope of DSEAR

• Applies to all workplaces
• Covers risks to employees, self-employed,
  contractors, visitors and the public
• Dangerous substances include
• Materials classified under CHIP (flammable,
  highly flammable, explosive etc)
• Dusts that could form explosive atmospheres
• Substances because of their properties and the
  way they are present or used create a FE risk

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Drum Explosion
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DSEAR Reg 5

• Requires a suitable and sufficient Risk
  Assessment that identifies
• the hazards from Dangerous Substances,
• the measures necessary to eliminate or control
  the FE risks, SFAIRP,
• appropriate mitigation measures.

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DSEAR Reg 6

• Hierarchy of controls
• Reduce quantity of dangerous substances
• Avoid or minimise release
• Control releases at source
• Prevent the formation of explosive atmospheres
• Contain or collect any DS that is released
• Avoid ignition sources adverse conditions
• Segregate incompatible materials

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Common Ignition Sources
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Control Measures Reg 6

• Mitigation Measures
• Reduce number of employees exposed
• Avoid propagation of fires or explosions
• Provide personal protective equipment
• Provide explosion pressure relief
• Provide explosion suppression
• Provide pressure resistant plant

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Schedule 1 General Safety Measures

• Reg 6(8) requires where appropriate
• Workplaces to be designed, constructed and
  maintained to reduce risks.
• Work processes to be designed, constructed,
  assembled, used and maintained to reduce risks.
• Appropriate systems of work, including written
  instructions and permit-to-work procedures.

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DSEAR Reg 7

• Classify places where flammables are used into
  hazardous and non-hazardous areas
• Select new equipment in accordance with the
  requirements of EPS (ATEX)
• Where necessary mark hazardous areas
• Verify overall explosion safety
• Ensure work clothing does not create an
  electrostatic hazard

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Hazardous Area Classification

• All new work areas, modified areas or places
  where new equipment is installed to be classified
  before being brought into use.
• Existing areas to be classified by 30 June 2006.
• DS includes combustible dusts as well as
  flammable gases and liquids.
• Standards, codes and guidance available but
  should be carried out by a competent person(s).
• Applicable to normal operation or foreseeable
  faults but not catastrophic failure.

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New Equipment

• Category 1, highest level of safety, should not
  cause ignition risk even in the event of a rare
  malfunction
• Category 2, high level of safety, no ignition
  risk in the event of a foreseeable operating
  fault
• Category 3, no ignition risk during normal
  operation

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Choosing the equipment category

• The user is responsible for zoning
• Ideally they should specify equipment properly
• In practise, the manufacturer must make
  assumptions about the way the equipment will be
  used.
• Proper instructions should avoid misuse.

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Mechanical ignition sources

• Very few types of equipment are an ignition risk
  in normal operation
• Hot surfaces and friction sparks can arise in
  fault conditions
• Many problems arise from lack of maintenance, or
  faulty maintenance

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Assessment of existing equipment

• Prioritise assess equipment in most hazardous
  situations first
• Group equipment together according to type and
  duty
• Take into account own operating experience
• Consult equipment suppliers regarding problems
  modifications
• Review against new standards (EN13463)
• Carry out improvements that are reasonably
  practicable

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Working at Heights

• Avoid work at height where possible,
• Use work equipment or other measures to prevent
  falls where working at height cannot be avoided,
• Where the risk of a fall cannot be eliminated,
  apply measures to minimise the distance
  consequences of a fall should one occur.

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Sources of information

• www.hse.gov.uk/fireandexplosion/dsear.htm
• http//europa.eu.int/comm/enterprise/atex/index.ht
  m
• www.hse.gov.uk/electricity/atex/index.htm
• PD CLC/TR 504042003 Electrostatics. Code of
  practice for the avoidance of hazards due to
  static electricity
• EI Model code of safe practice Part 15 Area
  classification code for installations handling
  flammable fluids
• BS EN 13463 Parts 1, 5, 8 Non-electrical
  equipment for potentially explosive atmospheres.
  Basic method and requirements
• Relevant HSE ACOPs and Guidance
• Industry Guidance EI, LPGA, BCGA
• The Work at Height Regulations 2005 Brief Guide
  INDG401

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Conclusions

• HSE supports industry in the publication of
  guidance and codes of practice
• HSE believes the EI Petroleum Road Tanker
  Workshop Code represents good practice in the
  industry and commends its use.

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Questions?