Formulation and blending sites are often treated as lower risk than reaction plant, on the reasoning that nothing is being chemically transformed. That reasoning does not hold. What these sites do is hold large inventories of flammable and hazardous materials and move them, frequently, between containers. The hazard is not reaction; it is inventory and handling.

Projex Solutions provides engineering design, DSEAR support and project delivery for formulation and blending operations handling solvents, resins, additives and speciality ingredients.

What makes this work different

High inventory, no reaction, real COMAH exposure. Aggregate quantities of flammable liquids in bulk tanks, IBCs and drums routinely place blending operations into COMAH scope. Because there is no reactor on site, it is not always the first thing anyone checks.

Transfer is the operation that matters. Pumping, gravity transfer, drum decanting and IBC filling generate the flammable atmospheres that classification has to address, and the electrostatic charge that ignition control has to manage. Non-conductive liquids in plastic containers are a recognised and frequently overlooked case.

Additive powders bring dust risk. Where powdered additives are charged into solvent, both a flammable vapour and a combustible dust may be present in the same operation.

Batch records and flexibility work against fixed assessment. A blending plant designed for flexibility will, over time, run formulations nobody assessed. The DSEAR assessment needs to cover the operating envelope, not one recipe.

Where we help

  • DSEAR assessment and hazardous area classification to BS EN IEC 60079-10-1:2021 and EI 15 (5th edition), covering the full operating envelope rather than a single formulation
  • Electrostatic hazard assessment, earthing, bonding and container selection
  • Transfer and pumping system design, including inerting where the basis of safety requires it
  • Bulk storage, bunding and containment design, with firewater containment assessed against CIRIA C736
  • Dust explosion protection where powdered additives are handled
  • COMAH tier determination and safety report engineering support
  • HAZOP facilitation, LOPA and SIL determination
  • Layout and materials handling design, including IBC and drum logistics within the building
  • Feasibility, FEED, detailed design and EPCM delivery under ISO 9001:2015

Typical reasons clients get in touch

  • The site has grown and nobody has re-checked COMAH status
  • Manual decanting needs to be engineered out or made demonstrably safe
  • A DSEAR assessment covers one product and the plant now runs twenty
  • Firewater containment has been raised by the regulator or an insurer
  • Powder addition into flammable solvent has never been properly assessed
  • Throughput has to rise without new buildings

Related

Part of our work across the chemical sector. See also coatings, paints, inks and surface treatments, and adhesives, sealants and construction chemicals.

Standards and regulations we work to

  • DSEAR 2002, with ACOP L138 (second edition, 2013)
  • BS EN IEC 60079-10-1:2021 and EI 15 (5th edition, October 2024)
  • COMAH 2015, where aggregate inventory crosses threshold
  • HSG51, The storage of flammable liquids in containers (third edition, 2015)
  • HSG140, Safe use and handling of flammable liquids
  • CIRIA C736 for containment and firewater retention design
  • COSHH 2002, with ACOP L5 (sixth edition, 2013)
  • PUWER 1998, with ACOP L22 (fourth edition, 2014, amended 2018)
  • Environmental Permitting (England and Wales) Regulations 2016 (as amended)
  • CDM 2015 and ISO 9001:2015

Frequently asked questions

We do not run any reactions. Can COMAH really apply to us?
It can, and it frequently does. COMAH is determined by the quantity of dangerous substances present on site, not by whether a chemical transformation takes place. Bulk tanks, IBCs and packaged stock all count towards the aggregate. Blending and distribution operations are among the sites most likely to be unaware of their status.

Our DSEAR assessment covers our main product. Is that enough?
Not if the plant runs others. A flexible blending facility will, over time, be asked to run formulations that nobody assessed. The assessment should describe the envelope the plant is designed and permitted to handle.

What is the most common problem you find on blending sites?
Incomplete earthing and bonding on transfer operations, and containment that was sized for a spill rather than for firewater. Both are straightforward to design correctly and awkward to retrofit.

Can you help reduce manual decanting?
Yes. Closed transfer, automated dosing and improved container handling all reduce exposure and ignition risk, and usually improve throughput and batch consistency at the same time.

How long does a COMAH tier determination take?
The assessment itself is quick once inventory data is reliable. Gathering that data is usually the slow part, particularly where packaged stock is held across several locations on site and no single record covers all of it.

We are moving to larger IBCs. Does that change anything?
Potentially quite a lot. Container size affects aggregate inventory, transfer method, static generation and manual handling, and a change that looks purely logistical can move the site’s regulatory position.

Is inerting always necessary?
No. It is one basis of safety among several, and it carries its own asphyxiation risk. Whether it is the right answer depends on the substances, the operation and what else is available as a control.

Talk to us about your operation. Request a call