How Does DSEAR Impact your Manufacturing Operations?

Get in touch – you may need a DSEAR assessment if you answer “yes” to any of the following questions:

The UK manufacturing industry, despite its decline since the 1970s, is currently the ninth-largest manufacturing nation in the world. And, according to the Office for National Statistics, it has grown by 1.4% a year since 1948. 

The ONS argues that the UK’s manufacturing growth is related to an up-skilled workforce, a shift in emphasis on quality products, improvements to manufacturing technology i.e., automation and artificial technology, a globalised economy and an increased emphasis placed on R&D.

As the UK’s manufacturing industry continues to both lead and evolve throughout the fourth industrial revolution, many organisations remain unaware of their need for a DSEAR risk assessment.

In this blog, we’ll summarise what a DSEAR assessment is and why it is necessary for your manufacturing business. We’ll then identify and explore a few key challenges that many clients from the manufacturing industry have recently faced when trying to comply with the requirements of DSEAR.

DSEAR stands for the Dangerous Substances and Explosive Atmospheres Regulations 2002 and is a risk assessment that focuses on the prevention and management of fires and explosions in your working environment. 

As part of this assessment, a hazard must be present – this is usually the presence of a flammable atmosphere and a source of ignition.

These hazards can include the handling and maintenance of potentially flammable, explosive and thermally reactive dusts, gases, vapours and other materials.

When undertaking a DSEAR assessment, the following ‘how likely’ questions are usually asked: 

• How and where can flammable atmospheres develop?
• How likely will a source of ignition be present?
• Who could be hurt, how severely, and what can be done to prevent it? 

If a flammable atmosphere cannot be prevented, then DSEAR utilises specific equipment to reduce the likelihood of ignition (ATEX equipment). Or it should manage any ignited events that occur – this will be a ‘Basis of Safety’ focussed on explosion prevention and protection.

DSEAR regulations apply to most activities that are undertaken throughout the manufacturing industry (if you use materials that are capable of combustion). These activities, as stated by the HSE’s brief guide to DSEAR include:

• Use of flammable solvents and liquids (e.g., acetone, ethanol, toluene)
• Handling or storing flammable gases (e.g., LPG, hydrogen, methane)
• Dust-producing operations (e.g., sanding, milling, grinding of wood or powders)
• Spray painting or coating processes using flammable substances
• Hot works (e.g., welding or grinding) near flammable materials
• Chemical mixing or reactive processes that release heat or vapours
• Use of ovens or dryers with flammable substances or residues
• Storing or handling flammable waste (e.g., solvent-soaked rags)
• Filling or dispensing flammable liquids/gases from drums or cylinders
• Handling or transferring combustible powders (e.g., flour, sugar, resin)

If any of these activities are undertaken at your place of work, then you are legally required to undertake a DSEAR risk assessment. The DSEAR that you undertake must focus on the specific work activities that involve the use of your dangerous substances.

If your manufacturing site stores dangerous substances above COMAH threshold quantities, you are likely to have additional duties under COMAH 2015 that sit alongside and go further than your existing DSEAR requirements.

Q: Does DSEAR apply to your manufacturing operations?

A: Yes-if there’s a chance of a flammable atmosphere forming, even briefly. Manufacturing operations that store flammable or combustible materials, or operate equipment that could ignite them, fall within the scope of DSEAR.

The way in which many manufacturers can demonstrate that they comply with DSEAR is by undertaking the Hazardous Area Classification (HAC) study. This study identifies the location of potentially flammable/explosive atmospheres alongside their size/extent and persistence. 

The HAC study is undertaken to identify and classify these ‘Zones’ to ensure that all equipment present in these specific zones are suitable.

These hazardous zones are defined by DSEAR as ‘any place in which an explosive atmosphere may occur in quantities such as to require special precautions to protect the safety of workers.’ 

Schedule 2 of DSEAR contains descriptions of the various classifications of zones for gases and vapours and combustible dust. We have a short blog on how to avoid over-zoning, which you can read here.

After classifying your zones, precautions for all manufacturing equipment need to be taken in order to prevent them from becoming a source of ignition. 

Depending on how you have classified your zones, specialist ATEX rated or non-specialist equipment can then be placed appropriately. 

This will include all of your manufacturing equipment, as well as fixtures, fittings and tools. Everything down to your personal mobile phone must all be rated as suitable or higher, for use in a hazardous zone.

As a manufacturing business, the updating of equipment due to technological advances can occur frequently. When manufacturing equipment is updated or modified, or hazardous zones are updated then an DSEAR assessment must be re-issued/reviewed by a competent person.

Looking back to the early 2020s, COVID-19 was a predominant theme that affected the personal and professional lives of everyone globally. 

The manufacturing industry, in many cases, had to rapidly adapt during COVID-19. Pharmaceutical manufacturing, for example, had to rapidly meet global demands for multiple medications.

If we take the above example, then any DSEAR documentation should have been reviewed as a significant change has occurred to the process. 

Management of Change (MoC) documentation and other checklists that have been completed must be sufficient enough to identify potential risks resulting from any change to your process. You can read more about the relationship between DSEAR and MOC here

Ultimately, a DSEAR assessment should always be reviewed if you believe that your current DSEAR may be invalid. 

To comply with the DSEAR regulations, employers must undertake risk assessments on their manufacturing operations when potentially dangerous substances are involved. Therefore, a DSEAR will be needed when a new product line is constructed. 

There are many ways in which your manufacturing processes can comply with DSEAR. This may include:

• the substitution of hazardous materials
• containment
• ventilation 
• explosion protection 
• explosion prevention

Although the prevention of risk via dangerous substances and/or their hazardous properties can be achieved by removing said properties altogether, in many cases this isn’t possible.

If your risks can’t be eliminated, they should be reduced as much as possible. 

DSEAR applies to the way in which your chemical substances are used, stored or processed. 

Diesel, for example, is classified as “flammable” under the Classification, Packaging and Labelling Regulations (CLP), as its flashpoint is around 58oC. 

At ambient temperatures, flammable atmospheres will not occur with diesel.  

However, diesel oils can become a fire and explosion hazard when heated to temperatures above the flashpoint (flashpoint testing can be undertaken by Sigma-HSE). 

As a result, if your process uses diesel at elevated temperatures then DSEAR applies to you.

This also applies to the use of all other substances that may decompose, release energy or react in standard manufacturing practices such as mixing, milling or dispersing.

When undertaking a DSEAR assessment we will use the information about the physical and chemical properties of your potentially dangerous substances alongside the operational characteristics of your facility’s work processes to determine your potential hazards and risks.

Whether you own a small business or are part of a global manufacturing corporation, your workplace’s safety, the employees who are working for you and the environment are of huge importance to the very fabric of your business.

By complying with the DSEAR regulations, you’re preventing any potential disasters that may arise from any dangerous substances used throughout your operation.

Therefore it’s not surprising that insurance companies are increasingly asking companies if they have undertaken a DSEAR assessment.  

Businesses must be prepared and have plans for any unexpected and unfortunate events caused by fire and explosions.

Over the years, we’ve received multiple queries from clients that have had to undertake DSEAR assessments at the request of insurance companies, because they need to prove that they are adequately managing the risks of fire and explosions.

Although there isn’t a specific fire and explosion damage insurance policy that can be issued by insurance companies, there are other forms of insurance that can pay to repair or replace items damaged due to a disaster caused by the above.

But, by undertaking a DSEAR assessment, you can decrease insurance costs by confirming to insurance companies that you have applied recognised safety regulations to your work environment.

For many manufacturing companies, simply complying with DSEAR by undertaking the assessment every 3-5 years isn’t enough.

Although this is the absolute minimum for legal compliance, there are a multitude of other factors that should be taken into consideration whenever there are significant changes to your process.

By undertaking a DSEAR risk assessment, you, as a manufacturing company, no matter your size, can begin to create effective process safety management systems leading to fewer accidents and near misses, optimised process systems and decreased insurance costs. 

But most important of all you can protect people, business, and the environment from fire and explosion risk. 

Sigma-HSE’s recognised process safety consultancy solutions have years of experience guiding the manufacturing industry towards DSEAR compliance. 

Our consultancy team is on hand to discuss your requirements and will work with you to provide actionable safety solutions to help your business achieve compliance with DSEAR and other explosive atmosphere regulations.

If you are unsure about the fire and explosion incidents involving dangerous substances handled at your facility, Sigma-HSE’s accredited testing laboratory can undertake any required testing, all in accordance with relevant standards and the fastest turnaround time in the UK.

For businesses in the EU, or for those wishing to comply with ATEX Directives, we also offer bespoke ATEX compliance solutions. 

If your facility:

• Uses or produces flammable gases, vapours, liquids, or dusts
• Operates heat-generating machinery or fuel-powered equipment
• Handles chemicals with hazard symbols like flame, explosion, or oxidizer
• Experiences spills, leaks, or generates dust during production
• Uses gas ovens, furnaces, or charges batteries indoors

You likely need a DSEAR assessment. We can help you review your Safety Data Sheets (SDSs), conduct dust and vapour hazard testing, and guide your path to compliance, both efficiently and cost-effectively.

Learn more about DSEAR in our FREE on-demand webinar.