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ATEX Your brief guide to the regulations and a clarification of contentious issues

Contents
3 3 4 5 8 8 Introduction What is the ATEX directive? What causes a dust explosion? How is ATEX applied in practice? The importance of prevention Discussion of contentious issues relating to ATEX

Introduction
This paper briefly outlines the ATEX explosion prevention regulations and how they are implemented to minimise the risk of dust explosions in bulk storage and handling systems. It goes on to discuss a number of contentious issues that have hampered the universal acceptance and understanding of ATEX in the UK. The paper aims to address these issues and demonstrate that ATEX represents a straightforward, logical and helpful approach to preventing and mitigating potentially devastating dust explosions.

What is the ATEX directive?


ATEX comprises two directives designed to prevent dust explosions in bulk storage and handling systems. ATEX 137 (99/92/EC) was implemented in the UK as part of DSEAR (Dangerous Substances and Explosive Atmosphere Regulations 2002) and relates to the protection of employees. It is therefore a regulation for end users of silos and handling systems where potentially explosive products are being handled. It requires, as far as possible, the use of dangerous substances to be avoided.Where this is not possible, steps must be taken to minimise quantities and to prevent the formation of an explosive atmosphere. ATEX 94 (94/9/EC) relates to storage and handling equipment and the protective systems used in potentially explosive environments. It is therefore a regulation for equipment suppliers. It requires products to be designed, tested and certified for use in different hazard zones, as identified by a DSEAR assessment of the premises. For system integrators, like Portasilo, who not only manufacture equipment but also design complete storage and handling systems that are integrated with existing operations, both sets of regulations apply. System integrators need to ensure both that their own equipment is safe and certified for use in potentially hazardous environments, and that they create environments that are safe for the people working in them.

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What causes a dust explosion?


The ATEX legislation is relatively new, but dust explosions certainly arent. In fact, dust explosions can cause more havoc than dynamite. Thats because an airborne dust explosion, or deflagration, is self-propagating and will continue spreading as long as there is dust to fuel it. That means a dust explosion can very quickly spread throughout a plant and rapidly devastate a large area. The elements required to cause a dust explosion are: - Oxygen - Fuel (the dust itself) - An ignition source - The correct concentration of dust in the air - Containment If dry dust is present in the right concentration it can cause a flame front or fireball. If that fireball is contained within a vessel it can cause a huge pressure build-up resulting in a very damaging dust explosion.

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How is ATEX applied in practice?


The ATEX regulations set out a very clear and logical process for evaluating the potential hazard in any materials-handling process and then determining the appropriate response. This is done through a formalised five-step Explosion Hazard Review (EHR). The five steps are: Step 1: How dusty is the product? The first step is to determine the characteristics of the materials dust. Material suppliers are legally obliged to provide explosion parameter data for all of their products. However, if this information is not supplied it is easy to get a sample of the material tested. Only the dust is tested for the purposes of ATEX assessment. If no dust is available, the material is ground to create a dust for testing. Four parameters are measured: - Rate of explosion pressure rise (Kst) - Maximum explosion pressure (Pmax) - Minimum ignition energy (MIE) - Ignition temperature (for a layer of dust and a cloud of dust) Step 2: How dusty is the process? The next step is to find out how much dust is created during product handling and processing. This is the responsibility of the plant owner, but the duty to evaluate the dustiness of the process can be delegated to a specialist system integrator, like Portasilo. The assessor will look at the sources of dust and the likelihood of release. This information will be used to divide the plant into ATEX zones, according to how dusty they are, as follows: Zone 20: Dusty all the time. An area in which an explosive atmosphere is present continuously for long periods or frequently. Zone 21: Dusty some of the time. An area in which an explosive atmosphere is likely to occur occasionally in normal operation.

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Zone 22: Dusty infrequently. An area in which an explosive atmosphere is not likely to occur in normal operation and, if it does occur, will only persist for a short period. Step 3: Select suitable equipment Once the zones have been determined, appropriate categories of equipment need to be specified for each zone, to minimise the risk of explosion. Under ATEX, equipment is categorised according to the ignition risk it presents. ATEX 94 sets out three categories of equipment: Category 1: Equipment that does not provide an ignition source, even in the event of multiple or unlikely malfunctions. To qualify for this category, equipment needs to be vetted and certified by a Notified Body. Category 2: Equipment that does not provide an ignition source, even in the event of more likely operating malfunctions. A Notified Body may be involved in testing and certifying this equipment. Category 3: Equipment that does not provide an ignition source during normal operation, but may provide an ignition source during malfunction. This equipment can be self-certified by the supplier. As a rule, Category 1 equipment is specified for Zone 20 areas of the plant, where there is the highest risk of a dust explosion, while Category 3 equipment is safe to specify in Zone 22 environments. Category 2 equipment is suitable for Zone 21 environments. However, there are exceptions (see Contentious issue 4 on page 11) which mean that its essential to maintain the distinction between Zones and Categories. Equipment should always be classified by Category not by Zone. Step 4: Select a basis of safety for the equipment This involves determining what will prevent a dust explosion in each part of the plant and for each piece of equipment installed. The basis of safety will vary depending on the type of equipment, the size of the plant and the likelihood of a dust explosion. The basis of safety may include: 1.Venting relieving any build-up of pressure within a silo or other vessel by venting it to the atmosphere. This is not a suitable solution for harmful or toxic dust, as it will contaminate the air.
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2. Suppression this requires equipment that can detect an explosion and immediately inject a suppressant into the vessel to stop it escalating. The disadvantage is that the suppressant will contaminate the material, so its unsuitable for many products such as foodstuffs. 3. Inerting rather than stopping an explosion once it has happened, this method aims to prevent an explosion from happening by maintaining an inert atmosphere inside the storage vessel. 4. Containment containing the explosion within the vessel, so that it cannot spread to other parts of the plant. This requires vessels to be manufactured to withstand 10bar of pressure. Small hoppers are routinely manufactured to this specification, but the thickness of steel wall required to withstand 10bar pressure on larger silos makes it prohibitively expensive for these vessels. 5. Elimination of the ignition source this involves removing any possible source of ignition from the operational environment. However, this is a highly contentious basis of safety (see Contentious issue 6 on page 11) Step 5: Select appropriate equipment to limit propagation and mitigate the effect of an explosion Mitigating the effects of any explosion is crucial to saving lives and protecting plant and equipment. Limiting the extent of the explosion and its propagation far beyond the ignition source is a primary aim of safe system design. The deflagration can be halted using barriers and chokes (referred to as autonomous protection equipment in the ATEX legislation). Rotary valves are a classic barrier between vessels. Explosion diverters can be used in ducts and pipework to divert the explosive force away from essential equipment. Interlocked valves can be fitted to the top and bottom of silos, so that both can never be opened at the same time which would allow an explosion to escape in two directions. It means silos can either be filled or emptied, never both at the same time. Fast-acting valves are another way to stop the spread of an explosion, as are localised suppression systems, which create a plug in pipework or ducts.
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The importance of prevention


The thrust of the ATEX regulations is that prevention is better than cure. ATEX should never be used as an excuse to sell more protective equipment which, in many cases, may not be necessary. Good housekeeping and dust prevention are the best ways to prevent an explosion happening in the first place. Where risks remain, its essential to have the correct protective and categorised equipment in place to prevent loss of life and damage to plant and equipment in the event of an explosion. As well as good housekeeping, the risk of dust explosions can be minimised by installing well-engineered and robust dust-extraction systems. Dust levels can also be reduced by pelletisation or granulation of the material. Electrostatic hazards should be minimised as these could spark an ignition, particularly in materials with an MIE of less than eight. Maintenance hazards should also be minimised by carefully controlling and monitoring any hot work. So the first rule is to tighten up housekeeping, dust-management and safety systems as far as possible, before assessing what risks remain. These risks can then be addressed with appropriate protective systems, where required.

Discussion of contentious issues relating to ATEX


While the ATEX regulations have been around for a number of years, they have taken some time to become widely understood and accepted. There has been cause for confusion, misunderstanding and even mistrust in some quarters, due to a number of areas of uncertainty. However, as outlined above, the ATEX requirements are actually very clear and straightforward. In this section, we outline the six key contentious issues relating to ATEX and try to provide some clarity.

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Contentious issue 1: Applicability of ATEX There has been considerable confusion about whether ATEX applies to certain processes or materials. The answer is very simple. ATEX applies if the material is potentially explosive when ground to dust. Materials suppliers should provide this information but, if they dont, it is a simple process to have the dust tested. If the dust is found to be potentially explosive, then ATEX does apply. Many organisations handling plastic pellets, for example, may feel that their product does not represent an explosive risk. However, tests of polythene dust have shown it to be explosive, with a Kst of 131 so the ATEX regulations do apply. However, having established that the dust is explosive, the next step in the Explosion Hazard Review is to determine the levels of dust generated by the material-handling process. In most cases, handling plastic pellets creates very little, if any, dust, so no ATEX-certified protective equipment is likely to be needed. Put simply, ATEX regulations do apply if the materials dust is explosive. However, that doesnt always mean that protective equipment will need to be fitted that depends on whether or not the handling process generates hazardous levels of dust. Contentious issue 2: Extent of zoning Excessive zoning of a plant is a common problem in ATEX implementation. It can result in organisations over-specifying their protective equipment, just to be on the safe side incurring unnecessary expense. The aim of any EHR should firstly be to identify housekeeping improvements and areas where dust can be reduced, perhaps using local exhaust ventilation (LEV) systems. Remember, the aim of ATEX is not to sell more protective equipment, but simply to make materials handling processes safer. The first step should always be to design out the risk. Once that has been done, realistic zones can be allocated across the plant. Contentious issue 3: Internal environments When the ATEX regulations were first released in English, there was some confusion about whether the rules applied to the internal environments of machines and silos. The loose phraseology that was causing the confusion has now been tightened up to make it unambiguous that, yes, ATEX does apply to internal environments, because dust explosions can just as likely start there as in the external environment.

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The diagramme below gives an example of how the internal environment of a silo and associated conveyors can be zoned.

Zone 22

Cat 1 conveyor
Zone 20

Zone 22

Cat 3 conveyor

The area below the level probe can be classified as a low-risk Zone 22 because the silo is rarely emptied below this point. The penthouse and skirt are also low-risk areas with very little dust. The most dust is generated above the material as the silo is filled, so this is a high risk Zone 20 environment. The conveyor feeding the silo needs to be the safest ATEX-certified Category 1 equipment, because it is feeding into the high risk Zone 20 part of the silo. The discharging conveyor can be a Category 3 device because it is emptying material from a low risk Zone 22 environment.

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Contentious issue 4: Availability of equipment In the early days of ATEX, the availability of certified equipment was a problem for plants trying to implement the regulations. Back then, for example, there were no Category 1 conveyors on the market. Now Portasilo manufactures a Category 1 conveyor, as do two other suppliers. The HSE (Health & Safety Executive) has been sensible in its enforcement of the regulations, fully aware of the supply difficulties. However, availability is becoming less of a problem, and the situation will only improve as more ATEX-certified products are developed and released onto the market. Nevertheless, the scarcity of Category 1 equipment does not mean that ATEX requirements cannot be fulfilled. Thats because it is permissible to fit Category 3 equipment in the highest risk Zone 20 environments, IF suitable Category 1 equipment is not available AND additional protective equipment, such as explosion vents, are installed. Contentious issue 5: Propagation prevention DSEAR, of which ATEX is a part, sets out the requirement to mitigate the effect of any explosion, which includes preventing its propagation between significant inventories, such as silos. This is typically done using ATEX-certified barriers and chokes, which are Category 1 devices, requiring third-party approval. However, in many industries there is a history of using home-made, un-tested mechanisms for preventing explosions spreading from silo to silo. These may or may not work in practice, but the problem is that they have not been tested and approved by a Notified Body so there are no guarantees. Where these devices exist they should be replaced by ATEX-certified Category 1 equipment, or at least be properly tested so that they can be correctly categorised, and then replaced if necessary. Contentious issue 6: Using elimination of ignition source as a basis of safety This is a particularly dubious basis of safety when it comes to preventing dust explosions. Eliminating ignition sources is a very good first design principle for storage and handling systems, and everything possible should be done to remove ignition sources from the plant, particularly for the most dusty and hazardous products.

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However, it is never possible to eliminate all possible ignition sources for the life of a plant. Maintenance work may require welding to be carried out and, no matter how strict a permit system is applied, there will always be human error. Smouldering material can be moved undetected around a plant into high risk areas, and there are a whole host of other unpreventable ways in which an ignition source can be created. Therefore, eliminating ignition sources is never a sound basis of safety. Ignition sources should certainly be designed out of the process, but then suitable protective equipment should also be fitted to mitigate the effect of any explosion.

For advice on carrying out an Explosion Hazard Review or implementing the requirements of ATEX at your bulk storage and handling facility, call the specialists at Portasilo on +44 (0)1904 624872 or visit www.portasilo.co.uk to find out more.

Porta and Portasilo are registered trade marks. Portasilo Limited 2011. Produced by the Portasilo Marketing Studio. PS7723/02/11.

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