ATEX Knowledge Base – Who does what?
A short, practical overview of who is responsible for what in ATEX – operator, designer, manufacturer, installer, expert and authorities. This is not legal advice, but a practical engineering translation into everyday plant language.
What is ATEX? – Two main EU directives
ATEX is the European Union’s framework for explosion protection (from the French ATmosphères EXplosives). It is built around two main directives:
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2014/34/EU – “ATEX Equipment Directive” (ATEX 114)
Applies to manufacturers, importers and distributors. It defines how equipment and protective systems intended for use in explosive atmospheres must be designed and certified. -
1999/92/EC – “ATEX Workplace Directive” (ATEX 137 / ATEX 153)
Applies to the employer / operator. It sets requirements for explosion risk assessment, zoning, selection of suitable equipment, explosion protection documentation and training.
In ATEX there are two major responsibility areas:
- the manufacturer / distributor is responsible for the properly certified Ex equipment,
- the operator is responsible for using it in the right place and in the right way, safely.
Employer / operator obligations (Hungary – Decree 3/2003. (III. 11.) FMM–ESzCsM)
In Hungary, the 1999/92/EC ATEX Workplace Directive is implemented by Decree 3/2003. (III. 11.) FMM–ESzCsM on the minimum safety requirements for workplaces where explosive atmospheres may occur.
Practical translation: as soon as a plant stores or uses any flammable gas, vapour, mist (aerosol) or combustible dust, the employer is obliged to assess whether an explosive atmosphere may be present – i.e. whether the workplace qualifies as a “potentially explosive atmosphere” under this decree. If the answer is yes, the decree becomes fully applicable and explosion protection is not optional, but a legal requirement.
- assessment of explosion risks,
- classification of zones (0/1/2, 20/21/22),
- preparation of an Explosion Protection Document (EPD – in Hungarian practice often called RVD) before first commissioning,
- definition and implementation of the necessary technical and organisational measures (ventilation, earthing, procedures, permit-to-work, training, etc.),
- keeping the RVD/EPD up to date (whenever technology changes and, in practice, reviewing it at least every 3 years).
The RVD/EPD and the associated zoning drawings may be requested by the authorities (labour inspection, disaster management) at any time during an inspection, and they may also verify on site whether the measures described in the document are actually in place.
Typical introductory sentence in an Explosion Protection Document:
“This document constitutes the Explosion Protection Document (hereinafter: RVD/EPD) for the potentially explosive areas of the plant, prepared in accordance with Decree 3/2003. (III. 11.) FMM–ESzCsM.”
How does the process start in practice?
- A flammable substance appears – e.g. solvent, alcohol, flour dust, sugar dust, biogas, dusty process.
- A risk assessment is carried out to determine whether an explosive atmosphere may form and where.
- If yes, the workplace is considered a potentially explosive atmosphere, the 3/2003 decree applies, and the RVD/EPD becomes a mandatory safety document.
- The employer – typically with the help of an expert – prepares the RVD/EPD and ensures that training, permit-to-work, maintenance and modifications are aligned with what is written in the document.
Note: the information above does not constitute legal advice. The aim is to provide a clear, practical overview of the main obligations for operators dealing with explosive atmospheres.
ATEX vs IECEx – Similarities and differences
ATEX (EU)
- EU legal framework – mandatory in the European Economic Area.
- Based on directives 2014/34/EU (equipment) and 1999/92/EC (workplace).
- Goal: harmonised CE + Ex marking and free movement of Ex equipment inside the EU.
- It covers not only equipment, but also operation and documentation at the workplace.
IECEx (international)
- International certification scheme, not a law.
- Based on the IEC 60079 series of standards.
- Goal: make it easier for equipment to be accepted globally by different authorities and operators.
- It is common to see equipment with both ATEX and IECEx certificates.
From an operator’s point of view the key message is: both systems try to answer the same technical question – how to ensure safe operation of equipment in explosive atmospheres. Markings and documents may differ, but the physics is the same.
Who does what in ATEX?
Operator / employer
- Responsible for workers’ safety and legal compliance in explosive atmospheres.
- Arranges the explosion risk assessment, zoning and Explosion Protection Document (EPD/RVD).
- Ensures ATEX-compliant equipment is selected, maintained and that staff is trained.
Facility and process designers
- Architectural, mechanical, electrical, automation and fire-protection designers.
- They must make sure that process, infrastructure and explosion protection work together as a system.
- This includes storage, ventilation, earthing, emergency shutdown, cabling, HVAC, fire detection, etc.
Equipment and machinery manufacturers
- Design and manufacture equipment and protective systems certified according to the ATEX Equipment Directive.
- Responsible for CE + Ex marking, category, EPL, and the instructions for use.
- They do not decide where the equipment is installed – they guarantee that it can be used under the specified conditions.
Installers and contractors
- Implement process piping, electrical systems, mechanical installations, etc. according to the design.
- Ensure that the way of installation (cabling, glands, junction boxes, earthing) complies with ATEX and relevant standards.
- It is not their job to design zones or perform risk assessments – that is a design / expert task.
Independent ATEX / explosion protection expert
- Concept development, zoning, Explosion Protection Document – preparation and review.
- ATEX-focused project management – technical coordination of designers and contractors.
- Pre-commissioning inspections, site visits, punch lists and recommendations.
- Training for operations and maintenance personnel.
Authorities (overview)
- They do not design and they do not take over engineering responsibility.
- They mainly verify whether the operator and the engaged experts have done their job properly,
- and whether the required documents, approvals and inspections are available and consistent with reality.
What documents does an operator usually see?
Core documents
- Explosion Protection Document (EPD / RVD) – the complete ATEX picture of the site: zoning drawings, process description, risk assessment and mitigation measures.
- Zoning drawings – which areas are classified as Zone 0/1/2, 20/21/22 and with what extent.
- Declarations of conformity – manufacturer / distributor statements on ATEX compliance.
- Training records – evidence that relevant staff has received ATEX-related training.
Equipment-related documents
- ATEX (and possibly IECEx) certificates – for equipment and protective systems.
- Installation and operating instructions – how to install, operate and maintain the equipment.
- Periodic ATEX inspection reports – proof that the equipment has retained its safety characteristics during service.
Role of authorities – a practical view
In Hungary, explosion safety involves several authority areas – fire protection, occupational safety, industrial safety, environmental protection, etc. In practice, it is important to understand that authorities do not design and do not make technical decisions for us. Instead, they verify whether the operator and the engaged experts:
- have carried out the required risk assessments and zoning,
- have a current Explosion Protection Document in place,
- operate and maintain certified equipment in line with legal and standard requirements,
- and whether all this is documented and traceable.
National Directorate General for Disaster Management
From an explosion safety point of view the Hungarian disaster management authority plays a key role. Within this system, the main professional areas are fire protection, industrial safety and civil protection. In a plant this typically means:
- fire safety regulations, fire protection compliance, handling of hazardous substances,
- in some cases “Seveso” / major accident hazard obligations and industrial safety permits,
- site inspections focusing on documents and the actual technology.
Occupational safety
The occupational safety authority (within the government offices) mainly looks at whether:
- the working environment is safe for employees,
- instructions, training, PPE and procedures are adequate for work in explosive atmospheres,
- the Explosion Protection Document and the real-life operation are consistent.
- have a transparent, step-by-step improvement plan for ATEX compliance,
- and treat this not as a “necessary evil”, but as part of their safety culture.
Where does FullCare come in?
In practice, operators rarely maintain a full in-house ATEX expert team. This is where FullCare comes in:
- ATEX concepts and zoning for new projects or modifications.
- Explosion Protection Document preparation and updates.
- ATEX-focused project management – coordinating designers, contractors and suppliers.
- Technical supervision during installation, site visits and punch lists.
- Pre-commissioning checks and support for start-up.
- Training for engineers, maintenance and operations – on site or online.
My goal is to help operators run their explosive atmospheres at a transparent and acceptable level of risk, while also staying compliant with legal requirements.
I also find it crucial that operators understand their own ATEX gaps realistically and that we jointly develop a medium–long term (1–2 year) improvement plan. We then implement the necessary measures in a cost-optimised and phased way, so that the steps are manageable from a business perspective.
Such a documented improvement plan is usually viewed very positively by authorities – whether during a routine inspection or in the investigation of an incident.