TSA Insight Magazine Issue 26 - Magazine - Page 31
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drawings and schedule
(regulation 7)
DSEAR risk assessment and
based upon this, a demonstration
that risks have been reduced ‘so
far as is reasonably practicable’
(regulation 5 and 6)
Emergency response
arrangements (regulation 8)
Training and competency records
(regulation 9)
Relevant operating procedures
and safety management systems
(regulation 9)
Viewed collectively, these documents
provide evidence that dangerous
substances are being managed
appropriately
and
demonstrate
to regulators that risks have been
reduced so far as is reasonably
practicable.
Many operators already possess
the necessary building blocks. The
real challenge is bringing them
together into a structured, auditable
demonstration of compliance.
Understanding the actual risk
A common misconception is that
DSEAR focuses solely on determining
where a flammable atmosphere
might exist. In reality, the regulations
require operators to undertake a
suitable and sufficient risk assessment
that considers both the likelihood
of an incident occurring and the
consequences should one arise.
For bulk storage facilities, this means
understanding:
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The hazardous properties of
stored products
Inventory quantities and storage
arrangements
Potential release scenarios
Operational activities such
as loading, unloading and
maintenance
Sources of ignition
The potential impact on
personnel, neighbouring facilities
and the wider environment
The complexity of modern storage
terminals often means that risks
extend well beyond the areas shown
on HAC drawings. Human factors,
maintenance activities, simultaneous
operations and abnormal operating
conditions can all introduce risks that
require consideration.
Demonstrating risk reduction
DSEAR
requires
employers
to
eliminate or reduce risks so far as is
reasonably practicable. This involves
demonstrating
that
appropriate
prevention and mitigation measures
have been implemented.
For tank farms, these measures may
include:
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Overfill prevention systems
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Tank gauging and high-level
alarms
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Vapour recovery systems
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Bonding and grounding
arrangements
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Leak detection systems
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Ignition controls
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Inspection, testing and
maintenance programmes
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Operational controls and permitto-work systems
Importantly, compliance is not simply
a matter of installing protection
systems. Operators must be able to
demonstrate why controls have been
selected, how they are maintained
and whether they remain effective
throughout the life of the facility.
As
storage
terminals
diversify
into alternative fuels and lowercarbon products, the suitability of
existing safeguards should also be
reviewed. Products may possess
different physical properties, ignition
characteristics or storage requirements
compared to traditional hydrocarbons.
Emergency preparedness matters
Even
with
robust
preventative
measures in place, DSEAR recognises
that incidents can still occur. Effective
emergency planning therefore forms a
critical part of compliance.
For bulk storage facilities, emergency
arrangements should address scenarios
such as:
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Tank overfill events
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Vapour cloud releases
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Pool fires
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Escalation between storage tanks
and neighbouring installations
Emergency plans should clearly
define responsibilities, communication
routes, evacuation arrangements
and emergency resources. Operators
should also ensure that plans are
regularly reviewed, exercised and
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