DSEAR – How to overcome challenges during COVID

The past 12 months have brought many challenges to the world of process safety which has affected the way we work and raised the question ‘How can we remain compliant with safety regulations during this difficult period?’.

Whilst restrictions remain in place on being able to visit some client facilities, it’s still not impossible to ensure you remain compliant and safe. So, how can you overcome DSEAR challenges during COVID?

DSEAR (Dangerous Substances and Explosive Atmospheres Regulations 2002) puts the responsibility on the employer to ensure that people and the environment are protected from risks associated with dangerous substances under the scope of the Regulations, described below. 

Does DSEAR Apply to me?

DSEAR applies to any facility storing or handling flammable materials, this includes flammable liquids and gases and combustible dusts.  As of 2015, compressed gases also require assessment under DSEAR, this includes non-flammable gases, the Regulations also cover substances corrosive to metals.

Exemptions apply for medical applications and domestic gas supplies, and DSEAR applies to maritime activities only in certain circumstances when a ship is in a British port.

What are my responsibilities as an employer?

The DSEAR Regulations place specific duties on employers to assess and control the risks from dangerous substances at their facilities.  The overall aim is to ensure all reasonably practicable measures are implemented to protect employees. 

The key elements of DSEAR compliance are as follows;

• Regulation 5 – requires employers to assess all potential risks to employees and others whose safety may be affected by the use or presence of a dangerous substance.  This is generally conducted through a semi-quantitative analysis, but should always have sufficient detail and rigour to reflect the level of risk at the facility.
• Regulation 6 – requires that all risks identified within the risk assessment are either eliminated or reduced so far as is reasonably practicable.  Risk reduction measures should be applied in accordance with the hierarchy of risk control as set out in regulation 6(4), prioritising elimination and prevention of hazards and hazardous events.
• Regulation 7 – requires competent identification of hazardous and non-hazardous zones i.e. classification of areas where an explosive atmosphere may occur.  The overall explosion safety of any new facility or process must be verified by a competent person prior to operation.
• Regulation 9 – requires that appropriate information, training and instruction is given to contractors and employees on the dangerous substances present at the facility, together with information on the hazards, risks, precautions and actions necessary for them to remain safe.

Conducting a DSEAR Assessment in Lockdown

In order to conduct a DSEAR assessment, a suitably competent person should survey the facility, considering all areas that store or handle materials that have the potential to generate flammable atmospheres, as well as areas storing or handling gases under pressure and substances corrosive to metals.

The survey involves a visual inspection only, the surveyor should be escorted by an operator or site employee who has detailed knowledge of the process equipment and procedures. 

For complex sites and processes, an onsite survey is recommended to ensure suitable understanding and allow a thorough assessment. 

However, simple sites can often be assessed remotely removing the need for an onsite survey and ensuring a no-contact process is adopted.  Throughout the Coronavirus pandemic, this has proven to be both efficient and cost-effective. 

Past experience has shown that facilities with a small number of areas requiring assessment under DSEAR will often have a limited budget for such an assessment, and will often go without,  putting their facility and employees at great risk. 

A remote assessment provides the option for a low-cost, quick turnaround assessment conducted by a competent person.  

Additional guidance on DSEAR can be found on the HSE website

For further information on how we can support you with your DSEAR Compliance, please contact us

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