Do You Need a DSEAR Assessment for your Warehouse?

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

In the early 2000s, Dr Andy Fowler, former Technical and Operations Director at Sigma-HSE and a Process Safety Specialist Inspector at the HSE, helped shape UK warehousing safety guidance.

He led the development of HSG71: Chemical Warehousing – The Storage of Packaged Dangerous Substances, a document aimed at any facility storing dangerous goods—regardless of size. This included distribution centres, chemical production sites, and even open-air compounds.

Before drafting the HSG71 guidance, Dr Fowler surveyed the warehousing industry. The examination and analysis of multiple returned survey forms raised a significant issue – only 30% of respondents stated that they stored chemicals or dangerous substances. 

A subsequent question on the survey provided a clear reason for the above feedback. When asked what type of dangerous substances were stored, the replies stated pharmaceuticals, household and commercial consumer products, cosmetics, agrichemicals, food products etc. The wider warehousing industry did not recognise that their products were to be classified as dangerous substances.

When looking into the products stored by warehouses across the UK, items such as hairspray were seen as a simple consumer product, despite being an aerosol containing extremely flammable gases (LPG). This was, and continues to be commonplace, even though individual aerosol cans are correctly labelled as a dangerous substance.

You only need to travel along the UK’s motorway network to appreciate the growth in extremely large warehousing and logistics operations throughout the country (which continues to expand significantly) to understand how much potential there is for catastrophe if dangerous substances are not correctly understood, let alone stored or transported properly.

The Dangerous Substances and Explosive Atmospheres Regulations 2002 requires that businesses in the UK manage the risks connected to fires, explosions, and dangerous substances.

If your warehouse 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.

DSEAR regulations deal with anything that may cause a fire or explode. This can include standardised materials that have already been classified as explosive or flammable alongside other materials that may not. 

Many combustible substances are not classified as dangerous, but can still be ignited, thus resulting in fire and explosion risks.

To safeguard workers and the public from explosions and fire, it is necessary to eliminate, mitigate or control these risks. This is done by complying with DSEAR.

Q: Does DSEAR apply to warehouses?

A: Yes—if there’s a chance of a flammable atmosphere forming, even briefly. Warehouses that store flammable or combustible materials, or operate equipment that could ignite them, are within scope.

DSEAR regulations will apply to most activities that are undertaken throughout the warehousing industry (if your stored materials are capable of combustion). The HSE state that a DSEAR may apply to any of the below activities:

• storage of petrol as a fuel for cars, boats or horticultural machinery
• handling and storage of waste dust in a range of industries
• handling and storage of flammable wastes such as fuel oils
• storage and display of flammable goods i.e. paints in shops
• filling, storing and handling aerosols with flammable propellants such as LPG
• transporting flammable substances in containers around a workplace
• deliveries from road tankers i.e. as petrol and bulk powders
• chemical manufacturing, processing and warehousing
• the petrochemical industry, both onshore and offshore

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

The primary focus of the DSEAR regulations are to prevent fires and explosions. This, in turn, will require the prevention of a flammable atmosphere (a mixture of fuel and air capable of combustion).

Where such flammable atmospheres are present on-site, you must then reduce the probability of potential ignition sources becoming realised.

As a result, mechanical or electrical equipment that have the potential to create an ignition source and is located within a flammable atmosphere generated under normal and expected malfunction operations must be special – this is often known as ATEX or Ex equipment.

Again, the Boots Nottingham incident involved a forklift truck that was not certified for use in flammable atmospheres.

To ensure that all equipment present in a flammable atmosphere are suitable, the determination of where on your has potential (to become a flammable atmosphere) and their extent/size is done by undertaking a Hazardous Area Classification (HAC) study. This, in effect, results in the creation of specifically classified zones.

Once your zones are known, any mechanical or electrical equipment, including fixtures, fittings and tools, must be removed or replaced by special ATEX or EX equipment.

However, a challenge that many companies that Sigma-HSE have worked with, as stated in a previous blog on how to avoid over-zoning in hazardous areas, is that when they undertake risk assessments, they err on the side of caution. 

Overcautiousness can result in larger hazardous areas being designated and, in some cases, a higher than necessary classification of zoning (i.e. Zone 1/21 instead of Zone 2/22) or the blanket zoning of entire areas.

By incorrectly assigning an area the wrong zone, a large amount of financial expense in terms of purchasing and maintaining ATEX or EX certified equipment can be caused.

In most warehousing operations, packaged substances are simply stored and then transported. These materials, when in their individual containers, ensure that the generation of flammable atmospheres is not possible. 

If these materials are spilled during stock movement, or if any containers leak, the possibility of generating a flammable atmosphere increases.

The safe storage and supply of goods, alongside the safety of your employees and business infrastructure are of vital importance to the success of your business. So, by complying with DSEAR regulations, you’re preventing potential disasters that could severely impact your operations.

We touched upon the topic of insurance for the manufacturing industry in a recent blog that you can read here.

Sigma-HSE have had multiple requests from these manufacturing businesses to undertake a DSEAR as requested by insurance companies. Warehousing businesses should start to think about the relationship between DSEAR and their insurers. 

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. 

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

Sigma-HSE’s recognised process safety consultancy solutions have years of experience guiding the warehousing 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.

If your warehouse:

• Stores flammable, combustible, or dusty goods
• Operates heat-producing or fuel-powered equipment
• Handles any chemicals with hazard symbols
• Has spills, leaks, or dust clouds
• Uses gas heaters or charges batteries indoors

You likely need a DSEAR assessment. We can help you review your SDSs, conduct combustibility testing, and guide your path to compliance, both efficiently and cost-effectively.

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