DSEAR stands for the Dangerous Substances and Explosive Atmospheres Regulations 2002.
Dangerous substances can put peoples’ safety at risk from fire, explosion and corrosion of metal. DSEAR puts duties on employers and the self-employed to protect people from these risks to their safety in the workplace, and to members of the public who may be put at risk by work activity.
Some companies, often much bigger organisations with a good understanding on process safety, don’t even consider DSEAR as a priority.
Some company policies explicitly exclude the requirement for a “DSEAR Risk Assessment”, instead putting the reliance on other studies, such as HAZOP, to reveal DSEAR risks.
Here’s why we think that is misguided at best, and potentially dangerous at worst.
The DSEAR Regulations do allow you to offload your risk assessment requirements, to other studies, as long as they adequately assess your risks. So in theory there is no issue with this, however there are some key aspects that will never be picked up in a HAZOP.
We love HAZOPs but with respect to DSEAR they will not provide the appropriate focus on:
🔥Storage of materials in areas, which may develop over time, beyond the original layout intent.
🔥Non process risks such as maintenance, cleaning (unless it’s really understood at HAZOP stage and properly assessed).
🔥Systems to which HAZOP is not as well suited, or not carried out for – such as machinery operations and utility systems.
🔥Housekeeping standards which play a very important role for dust zoning in particular.
🔥Workarounds that operators may develop, which could unveil new DSEAR issues.
In our view, a dedicated DSEAR risk assessment is always worthwhile, and a design stage assessment should always be followed up with an as-built assessment.
Although HAZOP should generally be updated at least every five years much like DSEAR, it is far less likely that this will be the case for a HAZOP, than a DSEAR Risk Assessment.
So next time someone asks if your DSEAR is up to date, and you rely on a HAZOP and hazardous area classification, think about whether those studies really reflect the reality of your operations.
