Who can carry out an ATEX explosion risk assessment and what qualifications are needed?
Abstract
The employer is legally responsible and must have the assessment done by competent people: with knowledge of the process, the substances, explosion protection and the standards. EU law sets no single qualification; national rules may require specific ones, so check the country.
The employer is responsible for the explosion risk assessment and the explosion protection document, and must have the work done by people who are competent for it: people who understand the process and the substances, explosion protection, area classification and the applicable standards. EU law does not prescribe one diploma or licence for this; it requires competence. Some countries add their own conditions, so the national rules decide whether a specific qualification is needed.
Short answer
- Duty holder: under Directive 1999/92/EC (Article 4) the employer assesses the explosion risks, and (Article 8) draws up and keeps up to date the explosion protection document (EPD).
- Who does the work: the employer's own competent staff, external consultants, or a team combining both. Under the framework directive 89/391/EEC the employer uses competent internal people and, if they are not enough, competent external services.
- What competence means: enough training, experience and knowledge for the task. In Great Britain, for example, a competent person has "sufficient training and experience or knowledge and other qualities".
- National conditions: Germany allows only persons with the required expertise (fachkundige Personen) to carry out the hazard assessment; other countries have their own rules. Turkey's implementation guide calls for all responsible persons to take part in preparing the document.
- Evidence of competence: a technical degree plus relevant experience is commonly expected for the area classification part; the IECEx Certificate of Personnel Competence unit Ex 002 (classification of hazardous areas) is one internationally recognised proof.
Responsibility stays with the employer
Directive 1999/92/EC is addressed to employers. It requires them to assess explosion risks overall, taking into account at least the likelihood and duration of explosive atmospheres, the likelihood that ignition sources, including electrostatic discharges, are present and effective, the installations, substances and processes and their interactions, and the scale of the possible effects. Places connected by openings to such areas must be included. The result is the EPD, which must show that the risks have been determined and assessed, which measures are taken, which areas are classified into zones and that equipment and workplaces are suitable. It must be drawn up before work starts and revised after significant changes.
Hiring a consultant does not move the legal duty. The consultant prepares the analysis; the employer must provide the information, understand and accept the conclusions, implement the measures and keep the document alive. A report bought off the shelf and filed away does not meet the directive.
What competence the assessment needs
An explosion risk assessment combines several fields, and one person rarely covers all of them. Good practice is a small team led by someone with explosion protection experience:
| Part of the assessment | Knowledge needed | Typically provided by |
|---|---|---|
| Substances and their properties | Flash point, explosion limits, gas groups, dust parameters | Process or chemical engineer |
| Release sources and ventilation, zoning | IEC 60079-10-1 and -10-2 methods, grades of release | Area classification specialist |
| Ignition sources | Electrical, mechanical and electrostatic ignition, hot surfaces | Ex electrical and mechanical engineers |
| Operation and maintenance | How the plant actually runs, start-up, cleaning, permits | Operations and maintenance staff |
| Measures and documentation | Equipment selection, protective systems, organisational measures | Team leader, safety specialist |
The area classification standard IEC 60079-10-1 has its own clause on the competence of the personnel who carry out classification. Other standards in the series set competence requirements for design and installation (IEC 60079-14), inspection and maintenance (IEC 60079-17) and repair (IEC 60079-19).
The directive also asks for competence beyond the assessment itself: workers must receive sufficient and appropriate training in explosion protection, and before first use the overall explosion safety of workplaces with hazardous areas must be verified by persons competent in explosion protection through experience and/or professional training.
National rules: examples
| Country | What the rules say about who assesses |
|---|---|
| EU framework (89/391/EEC, Article 7) | Employer designates competent workers or uses competent external services; Member States define the required capabilities |
| Great Britain (DSEAR with the Management Regulations) | Employer appoints competent persons, preferring a competent employee to an outside one |
| Germany (Hazardous Substances Ordinance, section 6) | Only persons with the required expertise may carry out the hazard assessment; an employer without it must obtain expert advice |
| Turkey | Regulation on the protection of workers from the dangers of explosive atmospheres (Çalışanların Patlayıcı Ortamların Tehlikelerinden Korunması Hakkında Yönetmelik, Official Gazette 30 April 2013, No. 28633); the ministry's guide says all responsible persons should take part in preparing the explosion protection document (patlamadan korunma dokümanı, PKD) |
Because these rules change and differ, check the current national text and any guidance from the labour ministry or regulator before choosing who signs the document.
Example: A paint factory needs an EPD. Its safety specialist knows the plant and the regulations but has never classified areas. The company engages an external area classification engineer holding a relevant competence certificate, and forms a team with the production manager, the maintenance electrician and the safety specialist. The engineer leads the classification; the team identifies sources and ignition hazards; the employer approves the document and assigns owners for each measure.
Common mistakes
- Treating the EPD as a consultant's product. The employer remains responsible and must keep it up to date.
- Choosing by certificate alone. A course certificate does not prove experience with the specific process, dust or gas.
- One-person assessments without operations input. The people who run and maintain the plant know where leaks, cleaning and start-up really happen.
- Ignoring national conditions. Some countries define who may prepare or sign safety documents; follow them.
Related on excodex
- ATEX explained: the two EU directives 2014/34/EU and 1999/92/EC in plain language
- The Explosion Protection Document (EPD) and area classification drawings under ATEX 1999/92/EC
- Competence of people working in hazardous areas: IECEx CoPC and other schemes
- Who can prepare an Explosion Protection Document in Turkey?
- What competence does a person need to carry out a hazardous area classification?
Standards and further reading
- Directive 1999/92/EC (ATEX workplace directive), Articles 4 and 8 and Annex II: legislation.gov.uk text
- Directive 89/391/EEC (framework directive), Article 7 on protective and preventive services: legislation.gov.uk
- Management of Health and Safety at Work Regulations 1999 (Great Britain), regulation 7: legislation.gov.uk; HSE overview of DSEAR: hse.gov.uk
- German Hazardous Substances Ordinance (GefStoffV), section 6: gesetze-im-internet.de
- Turkish Ministry of Labour and Social Security, implementation guide to the 2013 regulation (in Turkish): csgb.gov.tr
- IEC 60079-10-1:2020, classification of areas, explosive gas atmospheres (includes a clause on competence of personnel)
This article is general technical information prepared by the excodex editorial team. It does not replace the applicable standards, the equipment certificates and instructions, national regulations or the assessment of a competent person.