Guide to application of the ATEX 2014/34/UE directive - ANNEX II ESSENTIAL HEALTH AND SAFETY REQUIREMENTS

§ 139  Essential health and safety requirements

Annex II to the ATEX Directive 2014/34/EU provides an overview of the essential health and safety requirements (EHSRs) to be adopted to avoid the risk of explosion. Although direct application of the EHSRs is possible, it is envisaged that the normal route to demonstrate conformity with the EHSRs will be to conform to the requirements given in one or more European harmonised standards (see section § 62). If European harmonised standards are not used, it is incumbent on the person declaring conformity to state the technical basis for such a declaration, including evidence of any research that might have been undertaken in order to prove the equivalence of the protective measures undertaken.

§ 140  Preliminary observations

Preliminary observation “A” is often referred to as requiring conformity with the “state of the art”. Although the generalised text of the EHSRs does not change, the European harmonised standards interpreting the EHSRs are subject to a continuous process of revision to take into account developments in technology and further developments in knowledge about explosion protection.

Therefore, the relevant current harmonised standards would be regarded as demonstrating “state of the art” for a particular type of protection. Use of a non-harmonised standard may be possible, but its use must be justified.

Further information on issues relating to “state of the art” and EU-type examination certificates can be found in the Clarification Sheet ExNB/10/397/CS issued by the European Coordination of ATEX Notified Bodies Group (ExNBG), available on http://ec.europa.eu/DocsRoom/documents/9568/attachments/1/translations/en/renditions/native.

Preliminary observation “B” indicates that safety devices, controlling devices and regulating devices – referenced in Article 1(1)(b) – need only to comply with a restricted range of EHSRs and that conformity to the remaining EHSRs will be ascertained when the conformity of the complete equipment, incorporating the component, is assessed.

§ 141  General requirements

In general terms, it can be stated that compliance with the essential health and safety requirements of Directive 2014/34/EU is imperative in order to ensure the explosion proofing of equipment and protective systems. The requirements are intended to take account of existing or potential hazards deriving from the design and construction. However, following the philosophy of the ATEX Directive 2014/34/EU within the New Approach and New Legislative Framework, the notion of intended use is of prime importance too. It is also essential that manufacturers supply full information.

§ 142  Principles of integrated explosion safety. Risk assessment for ATEX products

To meet the requirements of Directive 2014/34/EU it is necessary to conduct a risk assessment process. According to Annex II, 1.0.1 manufacturers are under an obligation to design equipment and protective systems from the point of view of integrated explosion safety. Integrated explosion safety is conceived to prevent the formation of explosive atmospheres as well as sources of ignition and, should an explosion nevertheless occur, to halt it immediately and / or to limit its effects. In this connection, the manufacturer must take measures with respect to the risks of explosion. However, in most cases he will not be in the position to understand the possible extent of the adverse consequences of an explosion (as part of the overall explosion risk) since this is solely dependent on the particular circumstances at the users` premises. So the manufacturer's risk assessment will in general be restricted to and be focussed on the assessment of the ignition hazard (again part of the explosion risk) or the explosion control function for a protective system and safety devices. In addition, as required in Annex II, 1.0.2 to the Directive, equipment and protective systems must be designed and manufactured after due analysis of possible technical and operating faults in order as far as possible to preclude dangerous situations.

Bearing in mind the commitments resulting from the relevant requirements of Directive 2014/34/EU, a methodology on risk assessment, i.e. here ignition risk assessment, should not only deal with designing and construction aspects but also provide a common format or language between designers and users.

Methods and/or techniques that could be applied

There are many possible methods and/or techniques for risk assessment, especially for hazard identification. They can easily be adopted for the ignition risk assessment explained above as follows.

A good identification technique has the following attributes:

- it is systematic, i.e. it guides the parties concerned so that all parts of the system, all phases of use and all reasonably anticipated hazards are considered;

- it employs brainstorming.

By using more than one technique the possibility of overlooking any relevant hazard is minimised. However, the additional time employed in using more than one technique needs to be balanced against the increased confidence in the results. The main output from the hazard identification stage is a numbered listing of hazardous events, which could result from the products involved as an input to the risk estimation stage.

Risk assessment methodology should comprise the hazard profiles including the accidental parameters that can reasonably be anticipated. These aspects become subject to a risk assessment as a “series of logical steps to enable, in a systematic way, the examination of the hazards associated with products”.

In principle the risk assessment comprises of four steps^[1]:

1. Hazard identification: a systematic procedure for finding all of the hazards, which are associated with the products. Once a hazard has been recognized, the design can be changed to minimise it, whether or not the degree of risk has been estimated. Unless the hazard is recognized it cannot be addressed in the design.
2. Risk estimation: determination of the probability of occurrence of the identified hazards (and of the levels of severity of the possible harm of the considered hazards)[2].
3. Risk evaluation: comparison of the hazards estimated with criteria in order to decide whether the risk is acceptable or whether the product design must be modified in order to reduce the risk.
4. Risk reduction option analysis: the final step of risk assessment is the process of identifying, selecting and modifying design changes which might reduce the overall risk from products. Although risks can always be reduced further they can seldom be reduced to zero except by eliminating the activities.

Options, which address the hazardous events that make the greatest contributions to the total risk, have the greatest potential to reduce risk. Effectiveness in reducing risk always starts with changes to the design concept, i.e. inherently safe design.

See also §§ 4.1.1 "Definition of essential requirements", 4.1.2.2. "Role of harmonised standards" and 4.3 "Technical documentation" in “The 'Blue Guide' on the implementation of EU product rules”.

 

§ 143  Special conditions: checking, maintenance, surrounding area

Special conditions on checking, maintenance and the surrounding area for ATEX products are usually related to their intended use. In this sense it would be useful to ensure good communication between the manufacturer and the intended user of the product, in order to take into due consideration such conditions in the design and construction phases and to inform the users accordingly in terms of health and safety.

The surrounding area conditions may include:

• ambient temperature range;
• the effect of additional sources of heat or cooling (such as mounting on a heated process vessel);
• exposure to known chemical agents (including a salt atmosphere);
• exposure to vibration or other physical forces (including impact);
• exposure to light (particularly relevant for plastic materials).

§ 144  Marking

As these ATEX Guidelines have been especially drafted to facilitate the application of Directive 2014/34/EU, the following explanations refer only to this Directive. If other directives are applicable in parallel, their provisions have to be taken into account in addition to those of Directive 2014/34/EU.

The ATEX Directive prescribes, within the essential health and safety requirements, a set of markings for equipment and protective systems, including in particular CE marking and other supplementary/specific marking.

See also § 4.5 “Marking requirements” in “The ‘Blue Guide’ on the implementation of EU product rules”.

§ 145  CE Marking

See also section § 67 on CE marking.

Regulation (EC) No 765/2008 lays down the definition, the format and the general principles governing the CE marking.

CE marking is used by the manufacturer as a declaration that he considers that the product in question has been manufactured in conformity with all applicable provisions and requirements of the ATEX Directive 2014/34/EU and that the product has been the subject of the appropriate conformity assessment procedures.

The CE marking is mandatory and must be affixed before any equipment or protective system is placed on the market or put into service. As stated in Article 13(3) components are excluded from this provision. Instead of being CE marked, components have to be delivered with a written attestation stating the conformity with the provisions of the Directive, stating their characteristics and indicating how they must be incorporated into equipment or protective systems. This separate statement goes along with the definition of components, which have as structural parts no autonomous function.

In general the CE marking must be affixed during the production control phase by the manufacturer or his authorised representative established within the European Union. In certain cases it is possible to affix the CE marking earlier, e.g. during the production phase of a complex product (e.g. a vehicle). It is then necessary that the manufacturer formally confirms the compliance of this product with the requirements of the Directive in the production control phase.

The CE marking must consist of the initials "CE" taking the form described in Regulation (EC) No 765/2008. In general the CE marking must be affixed to the product or to its data plate. However, although it is not a requirement in Directive 2014/34/EU, it is considered reasonable to affix the CE marking to the packaging and to the accompanying documents if it is not possible to affix it to the product because of the product's size or nature.

It would be sensible, but it is not mandatory, to affix the CE marking to more than one place, for example, marking the outer packaging as well as the product inside, would mean that the marking can be ascertained without opening the package.

The CE marking shall be affixed distinctly, visibly, legibly and indelibly. It is prohibited to affix any marks or inscriptions that are likely to mislead third parties as to the meaning and form of the CE marking. The requirement for visibility means that the CE marking must be easily accessible for market surveillance authorities as well as visible for customers and users. For reasons of legibility a minimum height of 5 mm of the CE marking is required. This minimum dimension may be waived for small-scale products. The requirement for indelibility means that the marking must not be removed from the product without leaving traces noticeable under normal circumstances.

Depending on the conformity assessment procedure applied, a notified body may be involved in the design phase (Annex III), the production phase (Annexes IV, V, VI, VII, IX) or in both phases. The identification number of the notified body only has to accompany the CE marking if the body is involved in the production control phase. It is necessary to avoid any misleading information on equipment, for example the number of the notified body, where this is not foreseen by the Directive. Hence, the product should not have the number of a notified body affixed, if falling under category 3 (other than Unit verification), as well as some category 2 equipment, and for any voluntary certification.

The CE marking and the identification number of the notified body do not necessarily have to be affixed within the territory of the EU. These can be affixed in a third country if the product, for example, is manufactured there and the notified body either performed tests on the product type or assessed the quality assurance system of the manufacturer in that country. The CE marking and the identification number can also be affixed separately, so long as the CE and body-number remain combined. In case of components only the identification number of the notified body has to be affixed.

Where equipment that has already been placed on the market is incorporated into a product (e.g. an assembly – see section § 45), the integrated equipment must bear the CE marking and, if appropriate, the identification number of the notified body.

Whilst it is recognised that sub-assemblies may have CE marking affixed in their own right these might not be visible following construction of the final product. This is acceptable as this information can be found elsewhere. However, the final product must have a single label clearly relating to its final assembly prior to it being placed on the market and/or taken into service. In affixing the CE marking to the final product the manufacturer or his authorised representative accepts full responsibility for the conformity of the final product to the applicable essential health and safety requirements of Directive 2014/34/EU and all other relevant European legislation.

§ 146  Supplementary/specific marking

It is the intention of Directive 2014/34/EU that the design of the specific marking of explosion protection  follows the design, as specified in the old Directive 84/47/EEC (see page 229). This marking has to be followed by the symbol of the group and category (on devices according to Article 1(1)(b) of Directive 2014/34/EU the category should be indicated in brackets) and, relating to group II, the letter ‘G’ (concerning explosive atmospheres caused by gases, vapours or mists) and/or D (concerning explosive atmospheres caused by dust).

User instructions shall explain in detail the meaning of the marking on the product. However it is recommended to use the format provided in the following examples, as in Tables 6 and 7, where

" .. / .. " means the product has two different categories, and

".. - .. " means that a part of the product is not conforming to the Directive and not intended to be used in a potentially explosive atmosphere.

Moreover, devices according to Article 1(1)(b) of the Directive, and separately placed on the market, shall be marked with the category of the equipment under control in round brackets, and such devices which contain an own potential ignition source intended for use in a potential explosive atmosphere shall be marked as equipment according to Annex II clause 1.0.5.

 

Table 6: examples for marking of equipment

	I	M2	Mining products, group I, category M2
	II	1 G	Non-mining products, group II, category 1 for use in gas/vapour/mist atmospheres
	II	1 D	Non-mining products, group II, category 1 for use in dust atmospheres
			Protective system, for use in gas/vapour/mist/dust atmospheres
	II	(1) G D	Device according to Article 1(1)(b) of Directive 2014/34/EU in the non-hazardous area with intrinsically safe circuits of category "Ex ia", which can be connected e.g. to category 1 equipment
	II	2 GD	Category 2 equipment for use in potentially explosive atmosphere containing gases or dust
	II	(2)/2 (1)/1 G	An assembly, such as a gas detection system with more than one detection head, that is partly category 1 and partly category 2 formed by a safety device and an equipment. The safety device is intended for use outside the hazardous area and the equipment is intended for use inside hazardous area
	II	2(1) G	Category 2 equipment containing a safety device for a category 1 equipment
	II	2(1) GD	Same equipment for gas or dust potentially explosive atmospheres
	II	(2) G (1) G	A safety device alone which ensures the safety against explosion for category 1 equipment and for another category 2 equipment
	II	3/3 D	A blower exhausting out of zone 22 and to be installed in zone 22

 

Table 7: examples for marking of equipment having different categories

	II	1/2 G	Level gauge installed in the tank wall between zone 0 and zone 1
	II	(2) 3 G	An electrical field bus device affecting category 2 equipment installed in zone 2
	II	2/- G	A ventilator exhausting out of zone 1 but to be installed outside potentially explosive atmospheres. The Directive has no provisions for marking in case of installation outside potentially explosive atmospheres
	II	2/3 G	A ventilator extracting out of zone 1 but to be installed in zone 2
	II	3/- D	A screw conveyor conveying dust out of a zone 22 but installed outside potentially explosive atmospheres. The Directive has no provisions for marking in case of installation outside potentially explosive atmospheres
	II	-/2 D	Blower conveying no explosive atmosphere but to be installed in zone 21

Note: In the above examples, where a zone is indicated, the “normal” correspondence between zone and category is assumed according to the ATEX “workplace” Directive 1999/92/EC, i.e.

• category 1 - zone 0 or 20
• category 2 - zone 1 or 21
• category 3 - zone 2 or 22

 

 

All products must be marked with the registered name (or registered trade mark) and address of the manufacturer, designation of series or type, serial number (if any) and the year of construction. The year of construction and serial number may be combined or in a conventional coded format, in which case the explanation of the code shall be given in the instructions accompanying the product.

Where more than one category is given in the marking, the product must be accompanied with written information explaining the different categories, where they apply, and the consequences for the intended use.

Where a product is covered by more than one New Approach / New Legislative Framework legal act (European Regulation or Directive), CE marking denotes compliance with the appropriate provisions of all relevant directives. However, where one or more of these directives are in their transitional period and, as a consequence, allow the manufacturer to choose which arrangements to apply, the CE marking indicates conformity only to those directives where application is mandatory and others which are so applied. In the case of these latter directives particulars must be given in the documents, notices or instructions accompanying the product or, where appropriate, on the data plate.

§ 147  Additional marking for standards

Because of the special importance for the safety of products intended for use in potentially explosive atmospheres and in order to avoid any misunderstandings, Directive 2014/34/EU provides for additional markings (see Annex II 1.0.5.).

Equipment, protective systems and components must furthermore be marked with all necessary information essential to the safe use. According to this requirement European standards for electrical and non-electrical products for potentially explosive atmospheres foresee a supplementary marking. For detailed and complete information about this marking it is necessary to use these standards.

It is a requirement that the standard marking should not be used in a way that can allow it to be confused with the mandatory marking. Therefore, it is recommended in the standards that the legal marking of the directive and the additional marking required by the standards remain separate in order to avoid possible confusion.

Further, the standards often recommend that marking for protection against gas hazards and against dust hazards should be presented separately, to avoid confusion, whereas the directive recommends that a single legal marking, incorporating the letters “GD” be applied.

§ 148  Marking of small products

In accordance with the general guidance given to the CE marking of products, it is considered reasonable to affix all other marking to the packaging and the accompanying documents if it is not possible to affix it to the product because of the product's size or nature. The marking on the product may not be reduced or moved to the packaging purely on aesthetic grounds.

On very small products where a reduction in the marking is unavoidable, the following information is nevertheless required:

- CE marking (not for components),

- ex marking (epsilon-x, within the hexagon), and

- the name or registered trade mark of the manufacturer.

Where possible, at least a simplified address should also be given, sufficient for mail to reach the company. An internet address is not sufficient but the postal address has to be given. In some countries a unique postal code identifies an address. The use of this postal code is sufficient with the country.

§ 149  Marking of components

The ATEX Directive 2014/34/EU explicitly requires marking in Annex II, clause 1.0.5., only for equipment and protective systems. The question, whether components should nevertheless be marked in order to facilitate the implementation to the Directive, has particular practical relevance in cases

- where it is difficult to recognise the difference between ATEX components and standard components, and

- where a manufacturer who wanted to use a component might have serious problems undertaking his risk assessment, if there is no indication about the category of the component.

Apart from the question of marking, the Directive requires a written attestation of conformity for components. The latter shall give all the necessary information stating the characteristics. This normally occurs assigning to the component an explosion classification according to relevant harmonised standards, which looks like a marking (e.g. Ex II 1/2 GD cb Tx or Ex II 1 GD c Tx).

For components having an own potential ignition source or which are clearly correlated (with respect to the properties of the component) to equipment with a given category, it has been considered that without the definition of group and category, the necessary conformity procedure of the equipment, which the component will be incorporated to, cannot be performed.

In some cases the conformity procedure can only be performed, if the equipment, which the component will be incorporated to, is defined, and if this incorporation is a matter of the conformity procedure.

Therefore, it is recommended to mark components, as long as these can be assessed with respect to a certain category and group of equipment, indicating this category and group in the marking.

It should be noted that, in most cases, a component will not be marked with a temperature class as it is not, itself, a source of heat, or the temperature can only be determined when fitted within the final equipment.

Moreover, it is recommended to mark components for autonomous protective systems, which can be assessed with respect to the characteristic properties of the latter, as far as reasonable indicating these characteristics in the marking.

In any case, according to Directive 2014/34/EU, ATEX components shall not bear the CE-marking.

Marking of components with the Notified body's number

It has been discussed whether components subject to NB assessment required by the Directive should be marked with the notified body's identification number.

According to Article 1(1) the ATEX Directive 2014/34/EU applies to equipment, protective systems, safety devices and protective devices, and to components, under the generic denomination of "products". Hence, the provisions of the Directive which apply to "products" apply also to components unless otherwise specified.

The wording of Article 13(3) confirms that it is the intention of the legislator to treat components as products in general, but for those specific cases where explicit exceptions were defined. This is exclusively true for the CE marking (not allowed), and the name of the document by which the conformity is declared (attestation of conformity instead of EU declaration of conformity).

The requirement concerning the marking with the notified body's identification number is addressed in Article 16(3) of the Directive, providing that, where the body is involved in the production control phase, the identification number of the notified body must be affixed following the CE marking. It is clear from the wording of the referred article that CE marking and the marking with the notified body's identification number are two separate requirements.

It is therefore evident that:

- the notified body's identification number shall be placed on components, e.g. when required by the conformity assessment procedures required in Annexes VI or IX;

- although the CE marking requirement does not apply to components due to the specific provisions of Article 13(3), in the absence of an explicit provision to the contrary, Article 38(1)(d) shall be applied also to components;

- Member States shall act on the basis of Article 38(1)(d) against non-compliant components in the same way as against non-compliant equipment or protective systems;

- whenever notified bodies are involved in the production control phase of components, the notified body's identification number should also be placed on that component as required in Article 16(3), but certainly without the CE marking.

§ 150  Marking of assemblies

The marking of assemblies is identical to the marking of equipment, in particular equipment having different categories. An assembly may consist of a large number of assessed and compliant items (equipment, protective systems, safety devices) with their own specific marking, potentially of different categories. In such cases it would not be helpful to show all of these the individual markings in the marking of the complete assembly. Nevertheless, the marking of the assembly has to display all relevant information required by Annex II, 1.0.5, of Directive 2014/34/EU necessary for the intended use of the assembly as a whole. The marking shall be placed in such a way – e.g. on the outer housing of the assembly – so that there is no doubt that it shows the characteristics of the whole assembly and not just one part.

Assemblies may consist of parts of different categories and be intended for potentially explosive atmospheres having different physical characteristics. The marking of the assembly as a whole with group, categories and additional information essential for the safe use of the assembly (temperature class, etc.) may fall under one of the two following scenarios:

Case 1: The assembly as a whole is intended for use in one potentially explosive atmosphere of one specific zone

Where the individual parts of the assembly are marked for potentially explosive atmospheres having different characteristics, the part with the lowest level of safety defines the marking of the whole assembly. That means that the category, temperature class, explosion group etc. with the lowest requirement for the equipment has to be used for the marking of the whole assembly.

Case 2: Parts of the assembly are intended for use in potentially explosive atmospheres having different physical characteristics and/or different zones

If it is essential for that intended use, the marking of the assembly shall contain all groups, categories and additional markings (temperature class, etc.) necessary for the intended atmospheres. In this case, the instructions for use, installation etc. will indicate the different atmospheres/zones intended (and/or provided by constructional measures) in or around different parts of the equipment.

Examples (only categories and additional markings essential for safe use are given in these examples):

For case 1:

• An assembly consisting of parts marked with T3 and other parts with T6 shall be marked T3 to indicate, that it is, as a whole, intended for use in T3 atmospheres.
• A pump unit consisting of a liquid pump (non-flammable liquid) and driving electric motor. The pump is marked II 2 G T6, the motor II 2 G IIB T4. The whole assembly shall be marked II 2 G IIB T4, as the motor is the part that meets the lower requirements.
• A similar pump unit with a pump conveying hot liquid (non-flammable). The pump is marked II 2 G T3, the motor II 2 G IIB T4. In this case the assembly shall be marked II 2 G IIB T3.

For case 2:

• A fan conveying an occasional IIA T3 explosive atmosphere (zone 1) in normal operation, the fan fitted with an electric motor and some control devices placed in a zone 2, the fan accordingly marked II 2/3 G IIA T3. The motor is marked II 3 G T3, the intrinsically safe control device II 2 G IIC T6. As the intrinsically safe control device is placed in the same atmosphere as the motor, the part meeting the lower requirements (in this case the motor) is the decisive item. Accordingly the marking of the whole assembly is II 2/3 G IIA T3.
• A similar fan assembly, but with the motor placed outside the hazardous area. The marking of the whole assembly is II 2/3/- G IIA T3.

§ 151  Instructions

The ATEX Directive 2014/34/EU prescribes that equipment and protective systems must be accompanied by instructions, covering a wide range of contents. The manufacturer shall provide to the user written instructions that include the necessary information for safe use, repair, maintenance and/or overhaul of the equipment concerned, etc. The manufacturer does not have to provide the full technical file.

EHSR 1.0.6 does not specify the form of the instructions. It is generally agreed that all health and safety related instructions must be supplied in paper form, since it cannot be assumed that the user has access to the means of reading instructions supplied in electronic form or made available on an Internet site. This is particularly relevant for instructions that might need to be read whilst the plant is operational, in the presence of a potentially explosive atmosphere. However, it is often useful for the instructions to be made available in electronic form and on the Internet as well as in paper form, since this enables the user to download the electronic file if he so wishes and to recover the instructions if the paper copy has been lost. This practice also facilitates the updating of the instructions when this is necessary.

The user takes into account the instructions issued by the manufacturer to carry out repair, maintenance and/or overhaul on the basis of the requirements of the applicable directives (such as 2009/104/EC - Use of work equipment by workers at work and 1999/92/EC - Protection of workers potentially at risk from explosive atmospheres) and of relevant specific national legislation that regulates the repair, maintenance and overhaul of used equipment. The instructions must contain drawings and diagrams necessary for repair of the equipment. Applicable and technically accepted standards can also be used, for example EN 60079-19 - Explosive atmospheres - Equipment repair, overhaul and reclamation, which provides for identifying equipment that has been repaired to the manufacturer’s information separately from equipment that has been repaired “to standard”, i.e. the repairer’s “best guess” fit using the certification standard applicable to the equipment, but without access to the manufacturer’s instructions.

However, where necessary, the manufacturer can include in his documentation a statement that specific repair, maintenance and/or overhaul of the equipment shall only be conducted by the manufacturer himself, or by a repairer he has qualified or authorized.

With respect to assemblies, it is important to the safe installation, operation and maintenance of the assembled unit that all relevant information is passed to the end user. The manufacturer of the assembled unit should do this by including all related information in a package supplied to the end user.

With respect to instructions for components, see section § 47.

§ 152  Selection of materials

Guidance on selection of materials for the construction of ATEX equipment and protective systems is usually given in European harmonised standards, for example in relation to:

- avoidance of electrostatic ignition risks

- thermite reactions with aluminium, magnesium, titanium and zirconium

- light resistance

- thermal degradation resistance

- avoiding the use of copper in conjunction with acetylene

etc.

§ 153  Design and construction

The current state of technological knowledge is presumed to be given by using the relevant European harmonised standards.

§ 154  Enclosed structures and prevention of leaks

Although prevention of leaks is ideal, there are certain situations, for example in relation to the gassing of a battery during charging, where it is safer to securely vent the produced hazard rather than contain it.

§ 155  Dust deposits

The relevant European harmonised standards providing protection against igniting an explosive dust atmosphere also address the relevant issues related to the ignition of dust layers.

§ 156  Additional means of protection

Additional means of protection for ATEX products are required in case of exposure to "certain types of external stresses", in principle distinct (and more severe) from general external stresses, according to the foreseeable conditions of use and operation. In any case, ATEX equipment must be able to resist against relevant stresses with no adverse effects on the required explosion protection.

§ 157  Safe opening

Relevant European harmonised standards give guidance on the use of fasteners and the tools that may be used to open them, as well as the use of interlocks as an alternative.

Even though there is now only "special fastenings", the three historic levels of "safe opening" are not precluded by this essential health and safety requirement 1.2.6 and it is not the intention of Directive 2014/34/EU to require a level of safety higher than that required by the EN 60079 series of standards for the equivalent zone of risk.

Level 1, the use of "Special Tools" e.g. on fasteners with hexagonal socket heads can still be used as specifically described by EHSR 1.2.6.

Level 2, the use of fasteners which require some form of tool to open the door e.g. a simple screwdriver, an adjustable spanner, or a key, are allowed in EHSR 1.2.6 where the additional "appropriate protection measure" would be the presence of a warning label requiring the operator to "De-energise before opening" or similar text.

Note: To qualify for Level 2 a "key" operated fastener (if used) should be used in conjunction with a lock mechanism that automatically locks the door in the closed position when the door is closed. The use of a lock which requires the use of a key to lock it in the closed position is not allowed for Level 2 since the operator may choose not to lock the door again when the door is closed and the additional protection required is no longer provided.

Level 3, the use of a door fastener which would allow the operator to open the door of the enclosure without the use of any tool i.e. with the "bare hands", is also not prevented by EHSR 1.2.6. However because of the increased personal and explosion risk additional measures have to be applied e.g. the use of an electrical or mechanical interlock to de-energise automatically the interior of the enclosure as well as the conspicuous presence of the warning label used in Level 2 above.

§ 158  Protection against other hazards

Among other hazards, those related to the Low Voltage Directive (LVD) are particularly relevant.

The relationships between the ATEX Directive 2014/34/EU and other Union legislation can be found in sections §§ 231-240.

§ 159  Overloading of equipment

Relevant European harmonised standards provide advice in many cases, but cannot cover all possibilities.

§ 160  Flameproof enclosure systems

There are two specific European harmonised standards applicable to flameproof enclosure systems: EN 13463-3 Non-electrical equipment for use in potentially explosive atmospheres - Part 3: Protection by flameproof enclosure 'd' and EN 60079-1 Explosive atmospheres - Part 1: Equipment protection by flameproof enclosures ‘d’.

§ 161  Potential ignition sources

Paragraph 1.3 details the potential ignition sources that must be considered for ATEX equipment, according to its definition in Article 2(1).

§ 162  Hazards arising from different ignition sources

These ignition sources are considered in outline in the European harmonised standard EN 1127-1 Explosive atmospheres - Explosion prevention and protection - Part 1: Basic concepts and methodology.

§ 163  Hazards arising from static electricity

Electrostatic discharge, as a source of ignition, is often within the control of the design of the installation, rather than the equipment, and comes within the scope of the ATEX “workplace” Directive 1999/92/EC, backed up by standards providing appropriate detailed information.

However, the design of equipment can help to mitigate such risks and appropriate requirements are detailed in European harmonised standards.

Where equipment is otherwise outside the scope of Directive 2014/34/EU, the potential for a static discharge in use does not bring it into scope.

§ 164  Hazards arising from stray electric and leakage currents

Stray electric currents may flow, for example, in the external frame and enclosure of a large electric motor, as a result of magnetic fluxes not being confined to the magnetic core of the stator and rotor. Such currents can become an ignition source under certain circumstances. Detailed requirements are provided in relevant European harmonised standards.

Other examples of stray electric currents would include those from galvanic corrosion protection circuits.

§ 165  Hazards arising from overheating

Relevant European harmonised standards provide guidance on this kind of hazards.

§ 166  Hazards arising from pressure compensation operations

This essential health and safety requirement aims to prevent ATEX products to cause adverse effects such as ignition when carrying out pressure compensation operations.

§ 167  Hazards arising from external effects

The manufacturer’s instruction document should clearly define which potential external effects have been taken into account.

§ 168  Requirements in respect of safety-related devices

It should be noted that the text of clause 1.5 was written before standards in the EN 61508 series (and its derivatives) were written, which expand considerably on the “fail-safe principle”. European harmonised standard EN 50495 interprets the EN 61508 requirements in the context of clause 1.5 of the EHSRs of 2014/34/EU.

See also section § 37 on safety devices, controlling devices and regulating devices as defined in Article 1(1)(b).

§ 169  Control and display units

In general terms, ergonomic principles are regarded as part of safety integration, or "safety by design", for equipment to be operated by users in specific working conditions. An example of an advanced application of ergonomic principles within safety integration can be found in the Machinery Directive, Annex I, 1.1.6.

The ATEX Directive 2014/34/EU makes an explicit reference to ergonomic design in this essential health and safety requirement 1.5.4. for control and display units. They must take into account these aspects in order to ensure safe operation of the related equipment.

§ 170  Requirements in respect of devices with a measuring function for explosion protection

It is implicit in the wording of these clauses that the measuring device relates to measuring the concentration of gas that may be present. There is a series of European harmonised standards which provide guidance on the performance of gas detection equipment.

§ 171  Risks arising from software

Reference should be made to the various implementations of EN 61508-3 Functional safety of electrical/electronic/programmable electronic safety-related systems - Part 3: Software requirements which specifically deals with software applications in programmable safety related systems. European harmonised standard EN 50495 Safety devices required for the safe functioning of equipment with respect to explosion risks refers directly to EN 61508-3 for software consideration.

§ 172  Integration of safety requirements relating to the system

Consideration must be given to arrangements for a controlled shut-down of a system, should that be necessary to avoid creating additional hazards.

§ 173  Hazards arising from power failure

For some safety related systems, it will be necessary to provide stand-by power to ensure that the process can be safety shut down in the event of a general power failure.

Additional points for consideration could include the performance of an induction generator if it became detached from a stable grid supply and its voltage rose uncontrollably.

§ 174  Hazards arising from connections

The aim of this essential health and safety requirement is prevention of adverse effects from failure in connections (cables, conduit entries…) which can give rise to additional risks.

§ 175  Placing of warning devices as parts of equipment

Adequate availability of instructions is very much related to safe operations of equipment; in this case, concerning warning devices detecting an explosive atmosphere.

See also section §151 on instructions.

§ 176  Supplementary requirements in respect of equipment

Section 2 of Annex II to Directive 2014/34/EU includes a list of supplementary requirements for ATEX equipment, according to equipment-groups and categories and taking into consideration different kinds of potentially explosive atmospheres caused by gases, vapours or mists, as well as possible ignition sources.

Specific guidance on technical solutions to be used to comply with these requirements for ATEX equipment is provided in the relevant European harmonised standards.

§ 177  Supplementary requirements in respect of protective systems

On definition and description of ATEX protective systems, see section § 46.

Section 3 of Annex II to Directive 2014/34/EU includes a list of supplementary requirements for ATEX protective systems.

Specific guidance on technical solutions to be used to comply with these requirements for ATEX protective systems is provided in the relevant European harmonised standards.