What ATEX Directive 2014/34/EU asks is "what are you placing on the market?" What ATEX 153 asks is far more personal: Who are you inside the hazardous workplace — and what are you responsible for every day?
ATEX 153 – The Self-Knowledge Directive (Formally: Directive 1999/92/EC - minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres)
ATEX 153 does not define economic operators. It defines functional responsibilities inside the workplace.
Which positions are identified by ATEX 153?
ATEX 153 deliberately avoids job titles. Instead, it assigns duty obligations, which can be translated into real positions within the organisation.
1. Employer (or Operator / Duty Holder)
The unavoidable role. The Employer is the primary responsible person. Self-knowledge question:
If yes → you are the ATEX 153 duty holder, even if every activity is outsourced. ATEX 153 assumes:
2. Persons responsible for explosion protection measures
These are the people who:
They may be:
Self-knowledge question:
If yes → you hold Ex safety authority.
3. Persons preparing and maintaining the Explosion Protection Document (EPD)
ATEX 153 requires a written Explosion Protection Document. Whoever:
…is exercising formal responsibility, regardless of job title. Self-knowledge test:
Note: That person is never "just a consultant". In some countries it has been defined by the national law who can prepare and maintain it, but in many not at all.
And now the critical one: the Ex Coordinator
Is "Ex Coordinator" defined in ATEX 153?
No — and that is the key insight (but the duty of coordination is defined in Article 6).
The Ex Coordinator is not a legal role in the directive. It is a guideline-driven, best-practice role, described in:
What is the Ex Coordinator in reality?
The Ex Coordinator exists because ATEX 153 responsibilities are aligned. The Ex Coordinator:
Self-knowledge question:
That person is the Ex Coordinator, whether named or not.
Just saying...
Many organisations think: "We don't have an Ex Coordinator."
ATEX 153' reality
Then several people are acting as one — without knowing it. That is one of the most common root causes of explosion incidents.
ATEX 153 Roles – A Self-Knowledge Map
|
Reality |
Legal status |
|
Employer / Operator |
Explicitly defined |
|
Explosion protection decision-maker |
Implicitly required |
|
EPD author / owner |
Explicit obligation |
|
Ex Coordinator |
Not named, but functionally unavoidable |
The ATEX 153 Self-Knowledge Test
Ask yourself:
That person exists in every hazardous plant concerned. ATEX 153 simply assumes you know who it is.
Key Insight (very important)
Explosion protection fails most often not because Ex equipment is wrong, but because ATEX 153 roles are unclear, not well defined.
Note: the same content and definition of role (Ex Coordinator) is valid in any other Ex scheme and regime. Ex compliance has to be co-ordinated and well managed.
Keep up the good work!
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