Context card
The explosion protection document after a conversion
When does the explosion protection document have to be updated?
The short answer
Whenever the plant changes significantly. § 6(9) of the German Ordinance on Hazardous Substances (GefStoffV) requires hazards from explosive mixtures to be shown separately in the documented risk assessment, and § 6(10) requires the assessment to be updated promptly when significant changes require it; Directive 1999/92/EC names changes, extensions and conversions. An extension or a moved spray booth is such a change.
For: Plant operators, explosion protection specialists, occupational safety specialists and documentation managers
Key points
- Legal basis in Germany: § 6(9) and (10) GefStoffV, transposing Article 8 of Directive 1999/92/EC.
- The document shows the assessed explosion hazards, the protection concept, the zones, the measures and the required inspections.
- Outdated documents are rarely noticed at the conversion, but years later when someone compares the zones with the hall.
- A document that did not grow with the plant protects formally, not against the actual hazard.
- Make "does the explosion protection document have to change?" a fixed, assigned step of every conversion.
The context
What the document is
The explosion protection document is the part of the operator's risk assessment that shows the hazards from explosive atmospheres separately: assessment, protection concept, Ex zones, measures and inspections. In Germany it rests on § 6 of the GefStoffV.
Why it drifts
A document from 2010 often describes a plant that no longer exists in that form: an extension was added, a paint booth was moved, the ventilation was changed. On paper the old state remains. Nobody did anything wrong — nobody updated it. The gap appears years later, in an inspection that lays the zone classification over the hall.
What follows
- The plant has no grandfathering for an outdated assessment, and the document has none at all.
- Every retrofit and conversion needs the check whether zones, measures and equipment selection still match — as a step of management of change with a named person responsible.
- Correct Ex marking on equipment does not make an outdated zone drawing correct; explosion protection depends on the zones being right.
Questions readers ask next
- Who in the company has to check the document after a conversion?
- The employer is responsible; the task should be assigned to a named person or role in the change process, so that the check is not left to the next inspection.
- Is a regular review enough without a conversion?
- The assessment is reviewed regularly anyway. A conversion is an additional trigger that requires a prompt update, not the next scheduled review.
Sources
- Gefahrstoffverordnung (GefStoffV) § 6 — Bundesministerium der Justiz
- Directive 1999/92/EC on minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres — Official Journal of the European Communities, 16 December 1999
Review log and changes
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Reviewed
No corrections or additions since publication.