Just a few years ago, many investors and plant owners associated explosion hazard assessment primarily with the chemical or fuel industries, or the storage of large quantities of hazardous substances. Today, this approach is too narrow.
After the entry into force of the Regulation of the Minister of Development and Technology of 12 September 2023 on occupational health and safety during surface cleaning, spray painting, dusting and thermal spraying, the topic of explosion risk has become much more important in investment and operational practice.
The regulation covers, among other things, abrasive blasting, spraying surfaces with varnish products, powder spraying and thermal spraying, and requires that these processes be carried out in a way that prevents explosions and provides protection against their effects.
Explosion Hazard Assessment – not just chemicals and fuels
In practice, this means that explosion hazard analysis is becoming increasingly important in many facilities that were not previously directly associated with explosive atmospheres. This applies particularly to facilities where:
- paints and varnishes,
- solvents,
- volatile organic compounds,
- process dusts,
- painting powders,
- technical gases,
- spraying processes or surface cleaning.
For such facilities, not only the technology itself is important, but also ventilation, the way substances are emitted, the possibility of creating explosion hazard zones, and the selection of equipment operating in these zones. The 2023 regulation refers directly to fire protection regulations, occupational health and safety requirements for workplaces where explosive atmospheres may occur, and requirements for equipment intended for use in potentially explosive atmospheres.
Where does the OZW obligation come from?
Polish fire protection regulations have for years included the principle that in facilities and areas where technological processes involving materials that may create explosive mixtures are carried out or where such materials are stored, an assessment of the explosion risk is madeThis assessment includes identifying rooms at risk of explosion, designating explosion hazard zones with graphic documentation, and identifying factors that could initiate ignition.
This is very important from a practical perspective: the problem doesn't begin only when someone calls a room an "Ex zone." The problem begins earlier—when a technological process can realistically create an explosive atmosphere.
Why does this matter when making new investments?
In new industrial investments, the lack of a reliable explosion risk analysis quickly impacts design, costs, and acceptance. This applies particularly to:
- paint shop,
- paint shop,
- spray lines,
- shot blasting chambers,
- rooms with solvent processes,
- installations with technical gases,
- areas where flammable dust or mists are generated.
The 2023 regulation explicitly states that painting rooms in which methods or materials pose an explosion hazard must meet the requirements applicable to rooms at risk of explosion, and electrical equipment used in such rooms must meet the requirements for equipment intended for operation in explosion hazard zones.
In practice, this means that an analysis performed too late may force costly changes in the design, selection of installations, ventilation, electrical equipment and the organization of the process itself.
Lack of documentation does not eliminate the risk
The most costly mistake is assuming that if a document hasn't been prepared, the topic doesn't exist. Quite the opposite is true.
The absence of an ACS or a reliable analysis does not eliminate the explosion hazard. It simply means that the investor, facility owner, or user lacks formal and technical justification for the solutions adopted. Responsibility for protecting the facility against fire and explosion hazards rests with the owner, manager, or user.
Supervision over compliance with fire safety regulations is exercised by the locally competent district or municipal commander of the State Fire Service, who, in the event of irregularities, may order their removal or even suspend the operation of premises or equipment if the irregularities found cause a hazard.
Does the Fire Department “approve” the Explosion Hazard Assessment?
Explosion Hazard Assessment it is not, in principle, a separate document formally approved by the State Fire Service in the usual administrative procedure. However, the State Fire Service may request documentation during inspection and reconnaissance activities and assess whether the obligations arising from the regulations have been properly fulfilled. If violations are found, the Chief of the State Fire Service may issue a decision ordering the removal of the violations or prohibiting the use of the premises, facilities, or parts thereof.
Therefore, from the entrepreneur's point of view, the most important thing is not "will someone sign it for me", but whether the documentation has been prepared in such a way that it is technically and legally defensible during an inspection, acceptance or after an incident.
OZW as a tool for investment protection
Well prepared Explosion Hazard Assessment is not an empty formality. It is a document that allows:
- determine whether an explosive atmosphere can actually occur,
- determine where and to what extent explosion hazard zones are created,
- select appropriate technical and organizational measures,
- avoid both underestimating risk and artificially overestimating it,
- reduce unjustified investment costs.
The latter is crucial. A poorly executed analysis can lead to two equally unfavorable situations: either it overly optimistically ignores the real threat, or it overly expands the zones and technical requirements, generating unnecessary costs for the investor.
OZW – the change in regulations has really changed the market
That's why, following the regulatory changes, the issue of SCI has resurfaced in many industries with renewed urgency. This applies not only to new investments but also to numerous existing plants where the technology had been implemented previously, but the documentation had not been updated to meet current requirements.
Today, explosion risk analysis and a properly prepared Explosion Risk Assessment are becoming one of the key elements in organizing process safety, design requirements and investment risk.
Summary
If paints, varnishes, solvents, dusts, powders or technical gases are present in the plant and the process includes, for example, spray painting, dusting, shot-blasting or other operations that may lead to the creation of an explosive atmosphere, the topic of ACS should not be postponed.
The sooner the analysis is performed correctly, the greater the chance that the investment or existing facility will avoid costly corrections, incorrect design assumptions, and problems during inspection or acceptance. Therefore, it's worth collaborating with specialists on this matter! We encourage you to contact Ekomeritum – we will explain exactly how we can help and answer any questions you may have.
