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DSEAR compliant diesel storage

DSEAR compliant diesel storage and dispensing.

As most of you are entirely aware there is a contentious issue of whether or not Diesel installations in the UK require ATEX rated equipment.

This has led to large amounts of confusion within the industry indicating that there is a significant knowledge gap in correctly interpreting the regulations.

Our Managing Director is a qualified engineer with over two decades experience within the refuelling industry, specifying equipment into potentially hazardous areas both before and after the Atex directive was implemented, We are confident in our ability to make an informed statement.

With regards to our eligibility to offer readers this feedback, Our engineers are trained by the Energy Institute in Hazardous Area Classification and have also completed DSEAR Management training at the Health & Safety Laboratory in Buxton.

Regardless of whether the HSE decide to place a future cap on the volume of diesel storage which relies on HSG176 for guidance, the need for a site to undertake a DSEAR risk assessment on a diesel installation still exists. This is to ensure that misting and static ignition sources cannot occur and that the necessary protective measures are in place.

Let’s look at the facts of the situation.

In the UK, relevant apparatus in potentially hazardous area applications must be selected on the EPSR unless the risk assessment required by DSEAR regulations 5-7 finds otherwise.

This translates into the fact that the requirement exists for both manufacturers and site operators to perform a hazardous area risk assessment and confirm a hazardous area is NOT present and if one is present that it cannot be introduced to any ignition sources? Sounds complicated? Well it’s actually a lot simpler than you might think.

Irrespective of whichever risk assessment methodology you apply to identify if a hazardous area exists (either EI15 or BS60079), there are very few instances when ATEX rated dispensers or level sensors become a requirement when handling diesel.

Firstly let’s look at the instances when handling diesel could form a hazardous area. The obvious first answer is when it’s heated to above its flashpoint requiring that the subsequent vapour cannot be introduced to an ignition source. Additionally an explosion can also occur if diesel as a fluid comes into contact with a hot surface which is near to or above its Auto Ignition Temperature (typically 220-285°C).

Another requirement you are likely to hear about is mist formation. Mists can occur under pressure from a leaking joint or flange. They are considered a secondary release and are therefore classified hazardous. Mists are often atomised like an aerosol and could have a LEL of approximately 10% of equivalent vapour values, meaning that they can ignite at temperatures and volumes significantly lower than the liquids flashpoint.

Fortunately mist protection is achieved by simply ensuring firstly, that the system is designed to minimise the number of possible releases as far as is reasonably practical, (fewer joints and sealed adequately), secondly that all adjacent electrical equipment, pump motors etc, are rated to a minimum of IP54 (so that mists coalesce) and that any mists are not able to reach any ignition sources. Subsequently mists do not require ATEX rated equipment providing that these specific protective measures are adopted. EI15 and BS60079-10 both give further guidance.

However this does mean that some enclosures handling fuel which are in exposed (sunny) locations and/or have limited ventilation could give rise to a hazardous area if a leak were to go undetected. In this instance any electrical equipment contained within the enclosure should have sufficient protection from becoming an ignition source.

It is worth noting that it is also necessary for high volume storage facilities to require additional protective measures, simply due to the increased storage volumes and frequency of use.

Ultimately it is impossible for manufacturers to control the installation/locations/use of all of their products (or possible future changes to them), so you can understand why some manufacturers have responsibly chosen to adopt the requirements of the EPSR in full. However with correct product selection and system design it is almost always possible to negate the requirement to install ATEX rated equipment.

Interestingly another requirement within DSEAR is for all employees operating the dispenser to be suitably trained on the operation of the equipment, for it to be protected from unauthorised use and for it to be serviced regularly by an authorised representative.

Failure to observe these requirements as a supplier or installer can influence or even indemnify your Product Liability insurance and could also leave your customers with insufficient Employee Liability cover.

Subsequently we are a little surprised at all those pushing back against this implementation, especially as embracing the requirement of the DSEAR risk assessment not only also encourages better working practices within our industry but it also enforces regular maintenance, therefore stimulating demand. All of which helps us all build closer relationships with our customers whilst promoting professionalism and confidence throughout our industry at the same time.

We welcome feedback on this topic and are available for further comment.

© Copyright 2016, Commercial Fuel Solutions Ltd

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