In some countries, regions and the facility itself there are directives, laws, guidelines, guidances, standards, whitepapers, inhouse policies which shall address Ex compliance as a mandatory step.

On the other hand as we see this is not the reality. We have all experienced sites, operation where nothing related to Ex was in place.

As long as nothing happens, all we smile.

I have already attended to meetings, where my counter partner said – see there is a (red) phone. And I can make a call here if needed and all shall be fine. I told him, if there is an explosion, this phone will be silent. He quitted in 2 weeks.

So let us make a reverse engineering (not a legal term), and see in case of an incident how we come up with results of any investigation.

Certainly we shall look for non-compliances. BUT where we start?! Has the designer, installation team been Ex competent? Has his Ex personnel competency been validated by client? URS (user requirement specification) has been precise enough? Lifetimetracking in place? All assets are with ID? Do we have all DOCs in place and available? All Ex docs (HAC, EPD, …) in a 3 yrs circle control happened (re-validation, etc.)? Ex design chapter has been considered a basic lead to all other disciplines? Ex onsite meets the legal requirements according to country’s legislation? … IF all these are not valid, how we can define the right route cause assessment for any incident.

We all know it is not an easy topic.

Ex compliance engineering shall be the basic lead to all hazardous area projects and operation incl maintence and repair.

Keep up the good work!

Arpad
veress@exprofessional.com
exprofessional.com

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