Is an Explosion Protection Document mandatory for small companies?

Yes. The duty depends on the hazard, not on the size of the company. Under Article 8 of Directive 1999/92/EC, and under Turkey's 2013 regulation that mirrors it, every employer whose workplace may contain an explosive atmosphere that endangers workers must have an Explosion Protection Document (EPD) before work starts. A small company may keep the document short and simple, but it may not skip it. Size can matter only through national law: in Great Britain, for example, DSEAR requires the written record only where the employer has five or more employees.

Short answer

• EU directive: Article 8 of Directive 1999/92/EC contains no exemption for small or micro undertakings.
• Türkiye: the 2013 regulation on explosive atmospheres at work has no condition on the number of employees or on the workplace hazard class. The possibility of an explosive atmosphere decides.
• Great Britain: every employer must carry out the DSEAR risk assessment. The duty to record its significant findings applies from five employees.
• Proportionate content: the document can be brief where the hazard is small and simple. It still has to cover the risk assessment, the zones, the measures and the equipment.
• No hazardous atmosphere, no EPD: if a documented assessment shows that no hazardous explosive atmosphere can form, an EPD is not needed. That conclusion itself must be written down.

What the law says, country by country

The ATEX workplace directive 1999/92/EC places the duty on "the employer". Article 8 asks the employer to ensure that an explosion protection document is drawn up and kept up to date. The document must show the assessed risks, the measures, the zoned places, where the minimum requirements of Annex II apply, and that equipment is designed, operated and maintained safely. It must exist before work starts. The article mentions no headcount, turnover or hazard class.

The general framework directive 89/391/EEC lets Member States set documentation duties according to the nature of the activities and the size of undertakings (Article 9(2)). This is why national laws can differ in detail.

In Türkiye the regulation is the Regulation on the Protection of Workers from the Hazards of Explosive Atmospheres (Çalışanların Patlayıcı Ortamların Tehlikelerinden Korunması Hakkında Yönetmelik, Resmî Gazete 30 April 2013, No. 28633). It applies to workplaces under Occupational Health and Safety Law No. 6331 where an explosive atmosphere may form. Article 10 requires the employer to prepare the explosion protection document (patlamadan korunma dokümanı) before work starts. The Ministry of Labour and Social Security implementation guide is written particularly for small and medium-sized enterprises (KOBİ). It sets no size threshold, and it says the document is not tied to any particular format.

In Great Britain, the risk assessment itself is required for every employer with dangerous substances. The five-employee threshold only removes the duty to write it down. HSE inspectors will still expect a small firm to show how it controls the risk, and in practice a short written record is the easiest way to do that.

How small can a small company's EPD be?

The European Commission's non-binding guide to good practice for 1999/92/EC is aimed particularly at small and medium-sized enterprises. It proposes a specimen layout, but says the document should be tailored to the firm and not excessive, with a level of detail that depends on the type and size of the operation and the degree of risk. For a small workshop the EPD can be a few pages plus a zone sketch, as long as it answers the questions of Article 8:

1. Which flammable gases, liquids or dusts are used, and in what quantities.
2. Where an explosive atmosphere can form, and which zone each place is (a simple plan with Zone 1 and Zone 2 marked).
3. Which ignition sources were considered, including static electricity.
4. Which measures are taken: ventilation, closed containers, earthing, Ex equipment, no smoking, permits for hot work.
5. Which equipment is used in the zones, and that it is suitable (category or EPL, gas group, temperature class).
6. Who is responsible, how workers are trained, and when the document is reviewed.

Existing documents can be reused. Article 8 allows the employer to combine the EPD with other risk assessments, so a small firm can make it a chapter of its general risk assessment.

When a small company does not need one

An EPD is needed only where an explosive atmosphere can form in quantities that endanger workers. Some small firms use flammable products only in tiny amounts, in closed packages, or well below their flash point. Guidance from two prevention sections of the International Social Security Association (ISSA) says that if the assessment shows that no hazardous explosive atmosphere is expected, no EPD is required, but the result must be recorded in the safety documentation. The Turkish ministry guide gives a similar example for laboratories working with very small quantities: the exemption must be calculated and documented. A firm that cannot judge this itself should get help from a person competent in explosion protection. The employer remains responsible.

Common mistakes

• "We are too small for ATEX." Size does not decide. A garage, a bakery with a flour silo or a print shop with solvents can all need an EPD.
• Buying a long generic template. A short document that describes the real workplace is worth more than 80 pages that do not.
• Confusing the DSEAR threshold with an exemption. Under five employees in Great Britain, the assessment and the measures are still required; only the written record is not.
• Deciding "no explosive atmosphere" without writing down why. The reasoning must be documented so an inspector or a successor can check it.

Related on excodex

• The Explosion Protection Document (EPD) and area classification drawings under ATEX 1999/92/EC
• ATEX explained: the two EU directives 2014/34/EU and 1999/92/EC in plain language
• Which workplaces in Turkey must prepare an explosion protection document?
• How often must an Explosion Protection Document be reviewed or updated?
• Standards spaces: Directive 1999/92/EC, Turkish explosive atmosphere regulations

Standards and further reading

• Directive 1999/92/EC, Article 8 (explosion protection document): legislation.gov.uk
• Directive 89/391/EEC (framework directive), Article 9 on documentation according to the nature of activities and size of undertakings: legislation.gov.uk
• Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR), regulation 5: legislation.gov.uk
• Turkish regulation on protecting workers from explosive atmospheres, Resmî Gazete 30.04.2013, No. 28633 (text as published by the Ministry of Justice): adalet.gov.tr
• Ministry of Labour and Social Security, implementation guide on protecting workers from explosive atmospheres (in Turkish): csgb.gov.tr
• European Commission, non-binding guide to good practice for implementing Directive 1999/92/EC: EU-OSHA page
• ISSA Sections on Prevention in the Chemical Industry and on Machine and System Safety, practical assistance for preparing an explosion protection document (2nd edition, 2024): safety-work.org

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.