INTRODUCTION
Motor vehicle repair shops are extremely diverse ranging from a small mechanical servicing and repair workshop employing less than five persons, through to main dealerships with modern, purpose built showrooms, workshops and full body repair facilities. Specialist facilities are also commonly encountered, such as MOT centres and specialist body repair shops.
As with most trades, standards of risk awareness and management evidenced in motor vehicle repair shops varies dramatically, from quality risk and safety conscious companies, down to “back street” enterprises to whom the management of risk is not a high priority. Serious fires and explosions occur each year in motor vehicle repair workshops, commonly caused by the misuse of petrol and other flammable liquids, “hot work” repairs, rubbish burning, inappropriate or poorly used space heaters and arson.
Health and safety in motor vehicle repair and associated industries, including fire precautions, is fully covered in the HSE Health and Safety Guidance document HSG261 which is an essential source of reference for all Consultants.
RISK ASSESSMENT AND CONTROL
The following represent some of the key fire and explosion assessment and control features for consideration when conducting surveys of motor vehicle repair shops:
1. Flammable Liquids
The type and quantities of flammable liquids used and stored on the premises requires to be identified, together with confirmation that a risk assessment has been conducted in accordance with the Dangerous Substances and Explosive Atmosphere Regulations 2002 (DSEAR). Employers of five or more persons must record the significant findings of the DSEAR risk assessment in writing. Technical Bulletin 21 refers. (The storage of petrol and petroleum products in a workplace no longer requires a licence from the Petroleum Licensing Authority, except for the storage of petrol in a fixed tank for dispensing into vehicles via a pump - i.e. a petrol filling station.)
Control measures in connection with flammable liquids include:
Storage of flammable liquids to be kept to a minimum
Highly flammable liquids (defined as with a flash point of less than 23⁰C) to be contained in a proprietary, steel flammables cabinet designed to contain spills, or where in excess of 50 litres, in a purpose designed flammable liquid store.
Empty containers and waste oil to be handled and disposed of in a safe manner.
Substitution of highly flammable liquids with less volatile materials – e.g. use of “Safetykleen” parts washers employing cleaning solvents with flash points of 23⁰C or above (www.safetykleen.co.uk).
Extreme care to be exercised with the removal of petrol from all or part of the fuel system. A proprietary fuel retriever should be employed which should be used by a competent person in accordance with the manufacturer’s instructions.
Under no circumstances shall unwanted or contaminated petrol or petrol/diesel mixtures be added to waste oils or burnt, but rather they are consigned to waste and disposed of in a safe manner.
2. Inspection Pits
Whilst most modern vehicle repair facilities will employ vehicle hoists, inspection pits are often encountered particularly in older premises. The following fire safety measures regarding inspection pits should be observed:
Under no circumstances shall pit work on non-diesel tanks or fuel lines be conducted where there is a risk of fuel release.
Under no circumstances shall any hot work be conducted on or near any fuel line or tank, including diesel systems.
Fixed lighting and other electrical equipment (including hand lamps) to be suitably protected in accordance with the Equipment and Protective Systems Intended for the Use in Potentially Explosive Atmospheres Regulations (EPS Regulations) and BSEN 60079 – 10: Explosive Atmospheres – Classification of Areas. It should be noted that low voltage hand lamps do not afford protection unless specifically designed for use in explosive atmospheres.
3. Flame cutting and Welding
A common feature in virtually all vehicle repair shops for which precautions include:
Flame cutting and welding to be carried out by trained, competent persons.
Under no circumstances should any hot work be conducted on tanks or drums that may contain flammable residues before ensuring that they have been cleaned and gas purged.
Combustible trim adjacent to where hot work is to be conducted should be removed or shielded as necessary. Also check for the presence of plastic foam in body cavities.
Where hot work is to be conducted in close proximity to fuel lines and tanks, these will need to be correctly drained or shielded in an appropriate manner.
Full and empty gas cylinders to be stored in a safe, well-ventilated position, preferably externally, clear of any oil storage facility.
Gas cylinders to be chained secure in the upright position.
Oxyacetylene cylinders to be fitted with flashback arrestors, and flexible hoses regularly checked for damage and replaced as necessary. For long lengths of hose, flashback arrestors should be fitted on both the blow pipe and the regulator - Technical Bulletin 53 refers.
4. Electrical Installation
Attention to the correct maintenance of the electrical installation is a key risk control consideration in vehicle repair shops, with IET guidance recommending that periodic inspection and testing is carried-out at a maximum of once every three years (classed as “Industrial”). Where the premises include a petrol filling station falling under a Petroleum Licence, a condition of the licence is that an electrical inspection and test should be carried out annually. However, it is important to note that this applies to the forecourt installation only and does not extend to the rest of the site.
Depending on the extent of the facilities, parts of the premises may be deemed to present a hazardous atmosphere in respect of DSEAR/ATEX Directive, for which protected electrical equipment on the principles of zoning will be required to be installed (Technical Bulletin 23 refers). Typically, these would include:
Areas in which highly flammable liquids are stored, mixed or sprayed
Body preparation areas where organic fillers are sanded
Inspection pits
Battery charging areas
As regards battery charging, latest battery technology is such that the traditional requirement for large scale overnight charging has been significantly reduced. Nevertheless, where this is encountered, the time honoured requirement for batteries to stand on a non-combustible, heat resistant base in a well-ventilated area continue to apply.
Portable appliance testing (PAT) should be conducted regularly at intervals as prescribed by the HSE.
5. Space Heating
Fixed methods of gas or oil fired heating will always be the preferred option in vehicle repair shops, with all appliances kept clear of combustible materials, guarded as required and operated and maintained in accordance with the manufacturer’s instructions. The following call for special mention:
Waste Oil Heaters. Becoming increasingly popular in vehicle repair shops owing to savings in running costs – (Technical Bulletin 6 refers).
Transportable, fan-assisted Paraffin and LPG Heaters. Commonly employed in vehicle repair shops the reasons for which are obvious. These have tended to be frowned upon by Insurers, many of whom have required removal, or heaters to be fixed in position and guarded. However, we have grounds to suspect that some companies are starting to adopt a more pragmatic approach to the acceptance of these appliances for business that is otherwise of sound quality.
RSS’s stance is that we should approach the use of this form of heating with caution, paying attention to the type of appliance and the method in which it is used, its age and condition, whether it is operated and maintained in accordance with manufactures’ instructions and the extent of fuel storage. In the event of serious concerns, these are to be highlighted in the report and a requirement made for the heater to be removed and a more acceptable method of heating provided. Alternatively, a requirement calling for permanent fixing and guarding may be submitted where concerns relate mainly to the hazards of portability only.
In circumstances where the heating of the workshop owing to its size, height and need for constant access are particularly challenging and local heating in the form of the type described is the only feasible option, providing the heater is correctly maintained and managed, there may good reason to suggest that Underwriters may consider the arrangement tolerable. In these circumstances, acceptance is a matter for the Underwriter, based on the information in the report, and not the Consultant.
When considering portable heating irrespective of the type, Consultants need to be aware that a portable heating warranty or condition may apply.
6. General Housekeeping and Waste Control
Key considerations include:
Premises maintained in clean and tidy order and that storage and combustibles are kept clear of electrical switchgear, heaters, compressors and other plant.
All oily rags and wipes placed in metal lidded, metal bins and all waste removed from the building to external metal bins and skips at frequent intervals, preferably at the end of the working day and/or or to comply with policy waste conditions.
External yards to be kept free of accumulated rubbish, old tyres etc and waste bins located in a safe area, secured as required.
Oil spillages to be treated with proprietary oil absorbent granules and not sawdust.
7. Spray Painting/Body Repairs
Apart from occasional minor touch-up work, all spray painting should be carried out in accordance with RISCAuthority RC31 – Recommendations for fire safety in automotive refinishing and spraying processes, which will require a separate purpose built spray shop. Consultants should be aware of the contents of RC31, against which the facilities should be assessed. RC31 applies to the spraying of both flammable and highly flammable liquids with flash points below 55⁰C (under CLP Regulations 60⁰C or less).
Recent years have seen major advances made in automotive refinishing and spraying processes with the result that this activity commonly tends to be concentrated in specialist paint shop facilities containing sophisticated spraying and curing units such as those manufactured by Spraybake Ltd, details of which by illustration are available at www.spraybake.co.uk. Nevertheless, many substandard facilities in “back street” operations remain and, in these circumstances, Consultants should exercise caution.
Proprietary paint-mixing facilities are a common feature in modern body shops. Where encountered in a hazardous area it is essential to check that the integral electrical installation to the paint mixer is of a suitably protected design in accordance with the EPS Regulations and BSEN 60079 –10. Experience has shown that this may not always be the case.
A key requirement of DSEAR, which has particular relevance to paint spraying facilities, is that all areas in which hazardous explosive atmospheres may be present and which have come into operation after 30 June 2003 must be confirmed as being safe (verified) by a person (or organisation) competent in the field of explosion protection.
Another important fire safety management consideration when dealing with proprietary spraying and curing units is that of ensuring that the equipment is operated and maintained at all times in accordance with the manufacturer’s instructions. This should include routine cleaning programmes, and arrangements for checking the electrical installation, explosion relief panels, the heating installation and temperature controls.
Finally, recognition should be given to the fact that fibreglass repairs may be undertaken and Consultants should refer to Technical Guidance Note - (2) The Plastics Industry.
SUMMARY
This Technical Guidance Note is intended to provide a précis of the main risk assessment control considerations relating to the fire and explosion risk in vehicle repair shops and to motor garages in general.
From time to time, RSS will be involved in surveys which are part of a Motor Garages scheme, commonly targeting small repair and servicing facilities. In these circumstances, situations will often arise where surveys are conducted of poorly managed, high risk premises with little scope for any long-term, meaningful improvement. In these situations, it is essential that Consultants describe the risk “as surveyed” on which an underwriting decision can be made. The fact that such risks may on occasions be “accommodated” is not an RSS concern and should not cloud our judgement. It is also important that Consultants avoid becoming complacent when exposed to a string of small poor quality risks which, understandably, can start to be seen as the norm.
FURTHER REFERENCE
HSE 803/71 – Guidance on the Application of the Dangerous Substances and Explosive Atmosphere Regulations (DSEAR) 2002 to Motor Vehicle Repair.
RISCAuthority RC30 – Recommendations for the selection of electrical and non-electrical equipment for use in atmospheres containing flammable or explosive gases.
RISCAuthority RC15 - Recommendations for the use of portable and transportable heaters in commercial and industrial premises.
RISCAuthority RC57 – RC59 – Recommendations for fire safely in the storage and use of highly flammable and flammable liquids.
RISCAuthority RC8 – Recommendations for the storage, use and handling of common industrial gases in cylinders including LPG.
HSE ACOP L138 – DSEAR - approved code of practice and guidance.
HSE INDG370 - A short guide to DSEAR for small and medium sized businesses. Free download as above.
