One of the most practical aspects of the DSEAR framework – and one that’s often overlooked – is the way it categorises different types of work activity according to their risk level.
This isn’t just a theoretical exercise.
The risk level of an activity directly determines what kind of safety controls and documentation are legally required before that work can take place.
For anyone responsible for managing, maintaining, or commissioning refrigeration, air conditioning or heat pump systems in Surrey or beyond, understanding these categories is essential.
The Three Tiers of Control
DSEAR, as interpreted through the HSE’s Approved Code of Practice, recognises three broad levels of control that correspond to the risk associated with a given activity: operating procedures for low-risk work, safety method statements for medium-risk work, and permit-to-work systems for high-risk work.
Getting the level of control right matters.
Under-controlling a high-risk activity creates obvious dangers.
But over-engineering controls for routine low-risk tasks can create unnecessary bureaucracy that actually undermines compliance in practice.
Low-Risk Activities: Operating Procedures
Low-risk activities are those that don’t introduce ignition sources into a work area or create any meaningful risk of releasing dangerous substances.
Under DSEAR, these can typically be managed through supervision and written operating procedures rather than formal safety method statements.
Examples include routine cleaning operations, minor adjustments to equipment during normal operation, and dealing with small spills of non-hazardous materials.
For facilities managers, day-to-day operation of correctly installed and maintained refrigeration or air conditioning equipment generally falls into this category, as long as the system is operating normally and within its design parameters.
Medium-Risk Activities: Safety Method Statements
Maintenance, repair, and service activities, particularly those carried out within or near hazardous areas, or on equipment containing dangerous substances, are typically classified as medium risk.
These activities may involve the release of small quantities of dangerous substances but should not have the potential to release significant quantities that could create explosive atmospheres beyond already designated hazardous areas.
For medium-risk work, DSEAR requires a safety method statement: a written procedure that describes the task, identifies the hazards, specifies the control precautions, and outlines the sequence of work.
It should include details of any isolations required, the tools and equipment to be used, and the condition in which the plant will be left on completion.
For repetitive tasks, a generic method statement can be used and adapted for specific jobs as needed.
Routine leak testing of pipework and systems is a typical medium-risk activity in the refrigeration and air conditioning sector.
Hot work in areas where only small quantities of dangerous substances are present – and where those substances don’t give rise to hazardous zones – may also fall into this category.
High-Risk Activities: Permit to Work
Where foreseeable consequences of an error could result in immediate and serious injury – an explosion or fire that directly affects or traps people, a permit-to-work system is required.
This is a documented, formally authorised process that specifies who may carry out the work, what precautions must be in place, and the timeframe within which it must be completed.
In the refrigeration, air conditioning and heat pump sector, high-risk activities typically include brazing on parts of systems that have previously contained refrigerant, hot work or the introduction of ignition sources in areas designated as hazardous, work in confined spaces, and breaking into refrigeration plant.
A permit-to-work must be authorised by a responsible, competent person who understands the materials, processes, and equipment involved.
It requires affirmations from both the person authorising the work and the person carrying it out, and a formal sign-off once the work is complete confirming the plant is ready to return to normal use.
Hot Work Deserves Special Mention
Brazing and other hot work processes should be eliminated wherever reasonably practicable under DSEAR.
Where that isn’t possible, the requirements are stringent. A specific risk assessment must be carried out before work begins.
All refrigerant must be removed from the area where heat will be applied.
The system must be purged with a suitable inert gas, and that purge gas discharged safely.
A flammable gas detector must be in use throughout, and the work must only be carried out by trained, competent persons under a strict permit-to-work system.
Why Getting the Risk Level Right Matters
Misclassifying a high-risk activity as medium risk — and issuing a safety method statement where a permit to work is required — is a compliance failure that could have serious consequences in the event of an incident.
Equally, if your business doesn’t have a clear, documented system for determining which level of control applies to which activities, you are likely to be non-compliant with DSEAR regardless of what other measures are in place.
At Fire Risk Assessment Surrey, we help businesses establish clear, workable systems of work that meet DSEAR requirements across all activity types, from day-to-day operations through to high-risk maintenance and commissioning work.
Further Reading:
- HSE Permit-to-Work Guidance (HSG250): https://www.hse.gov.uk/safemaintenance/permits.htm
- HSE DSEAR Approved Code of Practice: https://www.hse.gov.uk/pubns/books/l138.htm
- HSE DSEAR Overview: https://www.hse.gov.uk/fireandexplosion/dsear.htm
