Policy
Dangerous Substances and Explosive Atmospheres Policy
How the university ensures Schools and Directorates have appropriate arrangements in place for complying with the requirements of the Dangerous Substances and Explosive Atmospheres Regulations 2002
Updated on 4 December 2024
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Objectives
To ensure that School and Directorate management are aware of their responsibilities and put in place appropriate measures regarding:
- Duty holders
- Assessing risks
- Managing risks
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Policy Statement
Schools and Directorates are required to ensure that the health and safety risks associated with the presence of dangerous and/or explosive atmospheres (as defined) within the work/study space are managed in line with statutory requirements. To ensure the effective management of such atmospheres, Schools and Directorates will implement the arrangements detailed below and will also comply with other University policies as appropriate to the activities undertaken.
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Scope
The Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) require employers to assess the risks from substances or preparations that may give rise to fire, explosion or other similar event and eliminate or, if this is unachievable, reduce the risks so far as is reasonably practicable. DSEAR deals with the immediate danger to life or health from fires or explosions resulting from the ignition of dangerous substances and should not be confused with COSHH, which deals with the chronic and acute health effects of exposure to substances hazardous to health. Processes and the storage involving dangerous substances that require a DSEAR assessment will also require COSHH assessments.
DSEAR applies if the following conditions are met:
- Work is being carried out by an employer in a workplace. ‘Workplace’ means any premise or part of a premise used for work, and includes industrial, commercial, educational and higher education premises, vehicles, vessels, roads, houses and other domestic dwellings and common parts of buildings, in every undertaking.
- A dangerous substance (see below) is present or is liable to become present. For example, a chemical reaction generates an unstable product, flammable solvents are stored/used in an area where sparks might occur.
- The dangerous substance presents a hazard to the safety of persons who may be affected, as opposed to their health.
The following classes of dangerous substances are covered:
- Oxidising;
- Extremely flammable;
- Highly flammable;
- Flammable;
Examples of dangerous substances include (note that this is not an exhaustive list):
- Most common organic solvents;
- Flammable gases (e.g. acetylene; hydrogen, methane);
- Petrol;
- Varnishes;
- Liquified Petroleum Gas (LPG);
- Kerosene;
- Styrene monomer;
- Acryl amide monomer;
- Fine dusts that when suspended in air to form a cloud produce an explosive atmosphere;
- Any other substances, or mixtures of substances, which because of their physical properties create a risk to safety from fires and explosions;
Examples of activities to which specific DSEAR controls may apply (note that this is not an exhaustive list):
- Storage of petrol as a fuel for cars, boats or horticultural machinery;
- Use of flammable gases, such as acetylene, for welding;
- Handling and storage of combustible dusts;
- Handling and storage of flammable wastes such as fuel oils;
- Welding or other ‘hot work’ on tanks and drums that have contained flammable material;
- Work that could release naturally occurring flammable substances such as methane in coalmines or at landfill sites;
- Use of flammable solvents in laboratories;
- Storage and display of flammable goods, such as paints;
- Filling, storing and handling aerosols with flammable propellants such as LPG;
- Transporting flammable substances in containers around a workplace;
- Deliveries from road tankers, such as petrol and bulk powders;
- Chemical manufacturing, processing and warehousing;
- Experimental or research work with the potential for 'thermal runaway' chemical reactions.
- Chemical or gas manufacture resulting from research or teaching;
It will be noted above that the word “may” has been added to the preamble to the list of activities. This is because specific DSEAR controls are not automatically required simply because a certain type of material is being handled. DSEAR will apply if there is a substantial hazard presented by the material and how it is used, stored, transported, etc. Hence, a risk assessment for DSEAR is required to be completed so that it can be assessed whether DSEAR controls apply (see section 4.2 below).
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Arrangements
4.1 Duty Holders
4.1.1 Director of Estates and Campus Services
The Director of Estates and Campus Services will ensure that DSEAR risk assessment outcomes notified to them by Deans/Directors are included within building planning and maintenance activities, as appropriate.
4.1.2 Deans and Directors
Deans and Directors are responsible for ensuring that the risks arising from the use of dangerous substances are reduced, so far as is reasonably practicable, and have a duty to:
- Ensure that any equipment / services procured are assessed for DSEAR implications and that suitable liaison with manufacturers / suppliers occurs (see also Procurement below)
- Ensure that suitable and sufficient DSEAR risk assessments are carried out (see below) in relation to all work/study activities under their control that are within scope of this policy and that these are reviewed and updated regularly.
- Ensure that where a third party (e.g. spin-out company, tenant) uses space within a building under the control of their school/directorate, that arrangements are put in place to co-ordinate the implementation of protective measures identified by any DSEAR risk assessment. Note that overall responsibility rests with the Dean/Director.
- Ensure that any person they appoint to conduct DSEAR risk assessments has appropriate competence to do so (see below)
- Ensure that all risks identified in the risk assessments conducted are reduced to as low a level as is reasonably practicable.
- Ensure that plans for any new building they propose are risk assessed for DSEAR implications and the Director of Estates and Campus Services notified of assessment outcomes so this can be included in the planning process.
- Ensure that any proposed change to use of space within buildings under their control where dangerous substances are stored/used is DSEAR risk assessed and, should this identify changes to hazardous area classifications requiring changes to infrastructure and/or signage, that this is communicated to Director of Estates and Campus Services.
- Ensure that before any facility / workplace that has been classified as a hazardous area under DSEAR is used for the first time, that they seek assurance from a suitably qualified person that the requirements of this policy have been met.
- Ensure that all DSEAR risk assessments and control measures relating to process fire precautions are to be brought to the attention of the University Fire Safety Adviser to allow the impact on the wider general fire precautions for the University to be evaluated and to ensure compliance with fire safety legislation.
4.1.3 Managers and Supervisors must:
- Comply with the finding of DSEAR risk assessments and ensure that anyone they manage/supervise likewise complies;
- Ensure that any proposed changes to activities that might affect the validity of the DSEAR risk assessment (e.g. changes to dangerous substance type, quantity or activity it is used in) are notified to the DSEAR risk assessor prior to such changes taking place;
- Provide appropriate supervision and monitor compliance with this policy in addition to local rules and procedures;
- Assess the competence of persons under their control to work safely and, where appropriate, arrange for necessary training. An assessment of competence should be carried out on all persons new to the school or directorate and new to a type of work or risk category;
- Ensure that Safe Systems of Work are in place to prevent the accidental release of a dangerous substance and prevent the presence of potential ignition sources within zoned areas.
- Ensure that personnel, contractors and visitors proposing to enter an identified hazardous zone are provided with relevant information, instructions and training, including safe systems of work, which shall include at least:
- the dangerous substances present in the workplace and the risks they present including access to any relevant Safety Data Sheets and information on any other legislation that applies to the dangerous substance;
- the findings of the risk assessment and the control measures implemented as a result (including their purpose and how to follow and use them);
- emergency / rescue procedures that should be implemented; and
- the control of prohibited items (e.g. smoking materials, mobile phones, radios, MP3 players, etc).
- Ensure that training noted above is delivered by a competent person, and that training records are retained.
- Ensure that all equipment within DSEAR zones is regularly checked so that it is safe to operate and cease using any equipment identified or suspected of being defective until it has been repaired/replaced. For building infrastructure items, any identified defects must be reported to Estates and Campus Services.
- Ensure that appropriate work clothing and tools that minimise the risk of electrostatic discharges that could ignite an explosive atmosphere are to be provided when required by the DSEAR risk assessment. The provision of PPE may also be required under COSHH for occupational health and safety protection. The manager must put in place checks to ensure these are maintained and used when working in hazard zones. Routine checks on the effective control of prohibited items and other control measures identified by the Stage 2 DSEAR risk assessments (see below) must be conducted by managers.
- Managers responsible for maintenance operations are to ensure that an appropriate task risk assessment has been undertaken, including any additional measures necessary to ensure the safety of personnel; and that only competent personnel who are aware of the additional hazards and control measures undertake such work in the DSEAR zoned area. Maintenance activities shall be conducted under a permit to work system.
4.1.4 Staff and other individuals must:
- Be conversant with this policy and the DSEAR risk assessments that apply to their work;
- Adopt safe practices (safe systems of work) in activities involving dangerous substances;
- Undertake such training as is required to enable them to understand and comply with all instructions provided.
- Cooperate with their manager and supervisor, Health, Safety and Wellbeing team members, and/or any other person appointed to monitor the safe use of dangerous substances within the school or directorate.
4.1.5 Staff procuring equipment and services:
Persons responsible for procurement and delivery of equipment / services and maintenance of equipment and infrastructure have the responsibility to ensure that equipment and infrastructure procured, operated or maintained is safe to use. Analysis of explosion protection and consideration of prevention or control measures must be carried out at an early stage by, or in conjunction with, the manufacturer / supplier who should have the required competences. It is the responsibility of the person procuring goods or services, or maintenance activities for equipment to ensure that anyone assessing DSEAR risks in relation to this procurement is competent to do so. The explosion protection analysis must include the identification and calculation of DSEAR zones and equipment category requirements, along with any necessary design alterations. Design risk assessments must be obtained from suppliers in accordance with the Construction (Design and Management) Regulations 2015 where this applies.
Persons responsible for the procurement or maintenance of plant, equipment and / or facilities which involve hazardous substances must ensure that relevant information is provided to persons undertaking DSEAR risk assessments. This will include, but is not limited to, hazard analysis, Hazardous Area Classification Drawings, ratings of equipment etc, Safety Data Sheets (SDS) and information on required / recommended control measures.
DSEAR risk assessments provided by manufacturers or suppliers may not relate to the specific circumstances (use and location) in which the equipment will be used by the University. Therefore, a DSEAR risk assessment which considers the factors relating to University use must be completed. DSEAR information must be readily available to the Emergency Services in the event of an emergency on site and is to be included within local hazardous area plans.
4.2 Assessing risks
Before work is carried out, the fire and explosion risks that may be caused by dangerous substances must be assessed. The purpose of the assessment process is to help determine what needs to be done to eliminate or reduce the risks from dangerous substances and should take account of:
- Dangerous substances in the work or study place;
- The work activities involving those substances;
- The ways in which those substances and work/study activities could harm people;
A Stage 1 assessment is conducted initially. If there is no risk to safety from fires and explosions, or the risk is trivial, then no further action is needed. However, if there are risks then duty holders must consider what else needs to be done to eliminate or control these risks in order to comply with the requirements of DSEAR. This is achieved by completion of a Stage 2 assessment. Guidance on how to conduct assessments and templates for recording assessments are provided within the DSEAR Sharepoint site.
Alternatively, duty holders may utilise the services of an external DSEAR assessor, who will work with the duty holder to conduct an assessment and may utilise an alternative assessment method.
4.3 Managing risks
The well-known and accepted hierarchy of risk control is the foundation used by DSEAR. The application of all or some of the following can be shown to reduce the risk and will form the basis for controls identified in DSEAR risk assessments:
- Elimination/substitution – where a dangerous substance is considered for use, consider if safer materials might be used;
- Reduction in quantity to minimise consequence;
- Avoidance of release/containment – see whether any containment method can be used (e.g. sealed systems), but beware that in attempting to contain the process, the containment, if it fails, does not contribute to the severity of the dangerous occurrence. (e.g. a fume cupboard will contribute to avoidance of release, but will not, unless specially designed, contain a fire or explosion);
- Control the process at source – keep tight control over the process dynamics;
- Prevent explosive atmospheres from developing – use efficient ventilation;
- Avoid build-up of potentially dangerous materials - by correct storage, collection and disposal;
- Remove potential for ignition – remove electrical equipment which is not safe, but also remember to consider auto-ignition, materials with very low ignition temperatures etc. Intrinsically safe / flameproof equipment may be required.
- Clothing that does not create the risk of an electrostatic discharge igniting an explosive atmosphere (e.g. anti-static footwear) may also be required; the clothing provided depends on the level of risk identified;
- Segregate potentially reactive materials (e.g. oxidisers and flammables);
- Care in storage and weighing out of materials;
- Reduce the number of persons who might be affected by an uncontrolled event – either remove the people from the reaction or remove the reaction to a segregated location;
- Avoid the propagation of an uncontrolled reaction – by using more than one of the steps already outlined in combination;
- Provide explosion relief where practicable;
- Provide suppression – by working in, or cloaking the reaction with inert atmospheres;
- Provide intrinsically safe / flameproof / pressure resistant equipment;
- Permit–to–work systems and area access permits should also be used as part of any risk assessment and mitigation programme (e.g. Hot work permits);
4.4 Information, instruction and training
All persons involved in work with dangerous substances must receive adequate information, instruction and training to allow them to work safely. The level of information, instruction and training required will be determined by the DSEAR risk assessment for the activity / location.
Information, instruction and training will be provided by appropriately qualified and competent individuals:
- For work with dangerous substances where Stage 1 DSEAR risk assessment has identified that specific DSEAR requirements do not apply, this means managers / supervisors who are familiar with the risks involved and the controls required.
- For work with dangerous substances where Stage 1 DSEAR risk assessment has identified that specific DSEAR requirements do apply and a Stage 2 DSEAR risk assessment has therefore been undertaken, this means the Stage 2 DSEAR risk assessor.
Training records will be kept for all training provided.
4.5 DSEAR risk assessor competency
Two stages of DSEAR risk assessment exist, for which different competency requirements exist.
For Stage 1 assessments, two signatories who are directly involved in conducting the assessment are required. The two signatories must not be the same person and will be:
- the manager responsible for the process; and
- an assessor qualified to at least NEBOSH General Certificate in Occupational Health and Safety (or an IEng, or a national or University recognised equivalent) and who has undertaken suitable DSEAR awareness training (see Handbook located in the DSEAR Sharepoint).
For Stage 2 assessments, the assessment team must meet the same competence requirement as for conducting a Stage 1 risk assessment (with additional input from appropriate stakeholders, where required). Where bespoke Hazardous Area Classification Drawings and zone calculations are required, the person signing them off must hold a current Certification of Personnel Competency for IECEx Unit Ex 002 (or equivalent nationally recognised certified scheme) or provide evidence by other means of equivalent qualification, knowledge, experience, and quality assurance systems.
Any external DSEAR assessor being appointed by a duty holder must possess appropriate formal qualifications and experience in relation to DSEAR assessment. The duty holder must undertake due diligence checks to ensure external assessor competency.
4.6 Site Emergency Procedures
Site emergency procedures must be developed to cover any potential emergencies identified in the risk assessment process. These should cover regular safety drills; First Aid and suitable communication and warning systems proportionate to the risks. If an emergency occurs, workers tasked with carrying out repairs or other necessary work must be provided with the appropriate equipment to allow them to carry out this work safely. The information contained in the emergency plans and procedures, site plans and DSEAR risk assessment must be made available in advance and on entry to the site, to the Emergency Services. See the DSEAR handbook for more information.
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Further Information
5.1 Related University policies
- University Health and Safety Policy
- Fire Evacuation policy
- SPA01 – School/Directorate Health and Safety Management
- Equipment used at work
- Other Dundee University Health and Safety Policies
- Estates Hot works
5.2 Related University guidance and resources
- DSEAR Sharepoint Site
- Workplace Inspection Handbook and Templates
- University Incident Reporting Form
- Incident Reporting and Investigation Handbook
- Incident Register
5.3 External resources
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Document Information
6.1 Equality Impact Assessment
This policy has undergone screening for impact on protected characteristics covered under the Equality Act 2010 and no impact has been identified.
6.2 Approvals Renewals
Document Name | Dangerous Substances and Explosive Atmospheres Policy |
Status | Approved |
Responsible officer/department/school | People Directorate |
Policy owner | People and Organisational Development Committee |
Date last approved | 02-12-2024 |
Due for review | 02-12-2026 |
Authorised and approved for publication | People and Organisational Development Committee |
Date authorised for publication | 02-12-2024 |
Information classification: public/internal | Public |
Location in repository | |
Approval route and history | Health, Safety and Welfare Committee |
Code | NA |