5 replies to this topic

[spectrum]

I am looking for information on safety distances for burning / testing under the new 2014 regs.

 

These distances were provided by EIG, the document I have only lists recommended safety distances to inhabited buildings on one table and then safety distances to factory or magazine buildings.

 

These two tables will satisfy some of the requirements but not all I suspect - class A - H.

 

Any ideas?

[exat808]

Hi,

 

I guess that you are operating under an HSE site license?

 

Your license Schedule should identify the designated burning and testing areas and should have distances prescribed on it.

 

If  however you are working to a Police or LA site license and you are conducting activities such as burning or testing which are not captured by the definition of "manufacture" in ER2014 then my understanding is that you would maintain the SD's prescribed for Class H in the relevant tables. Class H captures process buildings and "other places" which will include burning grounds, test sites etc etc.   

[spectrum]

Hi Danny,

 

Yes, HSE licensed site but a proposed new burning ground/testing site, previous prescribed distances etc. not a problem when they were shown on the original license however, the original license only required distances to Class1, 2 and 3.

 

ER2014 now requires distances from A - H.

 

The original document providing this information, produced by EIG only lists:

 

(a) Recommended safety distances to inhabited buildings and,

( Recommended safety distances to factory or magazine buildings

 

This document therefore only enables two options and not eight as demanded on the building schedule created by the current regs.

 

More up to date guidance published by HSE provides 6 tables - 1.3.1, 1.3.2, 1.3.3, 1.3.4, 1.3.5, 1.3.6 - not much use really as they refer back in some instances to diisposal operations in which the material undergoing disposal is compared to TNT equivalent.....really helpful when you're burning off flashpots, roman candles, thunderflashes etc! In any event - they don't provide data which can be used to address the eight classes listed on the building schedule.

 

Some deal with fireballs which presumably sit somewhere between hazard types 3 and 4 - but don't mention HT's 3 and 4. All with a cop out at the beginning excusing responsibility and passing it onto the applicant. The scenarios simply do not apply or corrulate to the hazard types demanded by the licensing authorities - it's up to the applicant to make a relevant comparison and then, the comparison is highly subjective and open to debate.

 

There are distance tables for all hazard types with a range of weights for storage/manufacture. It beggars belief that disposal "guidance" can't follow the same pattern - before anyone says it simply can't for whatever reason I would say it can and it previously did to the satisfaction of the Explosives Inspectorate.

[exat808]

Hi again,

 

Have you looked at any of the MOD SD's?

The HSE will quite often make use of these SD's as mitigating factors when deciding license distances. The applicant (you) must submit a safety case based using accepted modelling techniques to convince HSE that the distance you are requesting is suitable.

 

Also the MOD regs take special account of the destruction of only 1.4 and 1.3 material then a more lenient approach may be taken - this quote here from current MOD Regs

 2.2 Outside Quantity Distances

2.2.1 If disposal is by burning or incineration, and only explosives of HD 1.3 and/or HD 1.4 are to be destroyed, the Outside Quantity Distance (OQD) to be applied is not to be less than the applicable IBD for the quantity and HD of the explosives involved.

[spectrum]

That actually mirrors a comment made by a colleague Danny and the distances observed by another licensed manufacturer I deal with - albeit they're distances were agreed under MSER and I was unsure as to whether or not there would have been a change with the 2014 regs.

 

I'm very grateful to you for the information and I will use this approach on the application to vary which is being submitted (hopefully) this week. I reckon I might owe you a beer!

[exat808]

Although not directly related to SD's the attached has been of use when dealing with burning ground emissions for COMAH safety cases.  EXP burning and det Environmental.pdf   1.46MB   290 downloads