In the other ATEX articles in this Knowledge Center series, we have mostly covered 2014/34/EU (ATEX 114) scope, which is primarily the equipment manufacturer's responsibility. But ATEX also has a legal obligation on the employer's side: the Explosion Protection Document (EPD). In this article we cover what the EPD is, who it binds, and what elements it should contain.
What Is the EPD, and What Legislation Is It Based On?
The Explosion Protection Document is an official document that the employer is obligated to prepare in workplaces where an explosive atmosphere may occur, systematically assessing risks and documenting the measures taken and to be taken. This obligation is based, in the EU, on Workplace Directive 1999/92/EC (ATEX 137), and in Türkiye, on the national regulation transposing this directive ("Regulation on the Protection of Employees from the Dangers of Explosive Atmospheres"). At this point it is important to clarify the distinction between ATEX 114 (2014/34/EU), the equipment manufacturer's responsibility, and ATEX 137, the employer's responsibility; we covered this distinction in our article What Is ATEX?.
For Which Workplaces Is the EPD Mandatory?
Every workplace where an explosive atmosphere may occur due to flammable gas, vapor, mist or dust is obligated to prepare an EPD, regardless of business size. Chemical and petrochemical facilities, flour and feed mills, paint and coating workshops, woodworking facilities, pharmaceutical manufacturing facilities, and fuel filling stations are typical examples. Even a small workshop with solvent vapor or fine dust accumulation risk is subject to this obligation.
Fundamental Elements the EPD Must Contain
- Explosion risk identification and assessment: Systematic identification of which processes, substances and equipment at the workplace could create an explosive atmosphere.
- Zone classification: Classification of areas as Zone 0/1/2 (gas) or Zone 20/21/22 (dust) based on identified risks.
- Equipment conformity assessment: Checking whether existing or planned equipment in zone-classified areas holds Ex certification appropriate to the relevant category.
- Measures taken and to be taken: Documenting protective measures such as ventilation, grounding, static electricity control and cleaning regimes.
- Emergency procedures: Evacuation and response plans to be applied in the event of a possible explosion or fire.
- Coordination provisions: Allocation of responsibilities in situations where more than one employer (for example, main contractor and subcontractors) operates in the same area.
See our articles What Are Zones 0, 1 and 2? and What Are Zones 20, 21 and 22? for the technical details of zone classification.
Does the EPD Replace Equipment Certification?
No. The EPD is a document that assesses the workplace's environmental risk and determines which category of equipment should be used in that environment; the equipment itself being designed ATEX-compliant and carrying the Ex mark is a separate process and the manufacturer's responsibility. Even if a company has prepared an excellent EPD, if it is not using certified equipment appropriate to the category determined in that EPD, the risk is not actually managed. For this reason, the EPD and equipment certification are two separate processes that complement, but do not replace, each other.
When Should the EPD Be Updated?
The EPD is not a document to be prepared once and shelved. When new equipment is installed at the workplace, a production process changes, building or facility layout is renovated, or the substances used change, the EPD needs to be reviewed and updated. Although no fixed legal renewal period is defined, confirming the currency of the EPD through a regular (for example, annual) internal audit is good practice.
Common Challenges in EPD Preparation
The most common problem encountered in the field is the EPD being prepared only once, usually before an audit, and never updated afterward. Another common problem is that the zone classification determined in the EPD is not reflected in procurement and maintenance processes; in this case, even if the EPD is correct on paper, equipment in the field can remain effectively non-conforming. A third challenge is doing zone classification superficially without sufficient engineering experience; this can lead to the risk being shown as lower than it actually is.
Relevant Directives and Standards
The legal basis of the EPD obligation in the EU is Workplace Directive 1999/92/EC (ATEX 137); this directive has been implemented in Türkiye through the relevant national regulation. The technical methodology of zone classification is based on EN 60079-10-1 for gas environments and EN 60079-10-2 for dust environments. On the equipment side, the selection of equipment appropriate to the zones determined in the EPD must be made among products certified under Equipment Directive 2014/34/EU (ATEX 114).
| Topic | ATEX 114 (2014/34/EU) | ATEX 137 (1999/92/EC) |
|---|---|---|
| Addressee | Equipment manufacturer | Employer / facility operator |
| Output | CE + Ex mark, declaration of conformity | Explosion Protection Document (EPD) |
| Focus | The equipment itself | Workplace environment and worker safety |
| Renewal | Valid as long as design doesn't change | Updated on condition change |
Step-by-Step Process
- Identify which processes at your workplace carry explosive atmosphere risk.
- Classify risky areas as zones according to EN 60079-10-1/10-2.
- Check whether equipment present or to be installed in these areas has an Ex category appropriate to the zone.
- Document protective measures such as ventilation, grounding and static electricity control.
- Add emergency and evacuation procedures to the EPD.
- Share the EPD with all relevant employees and subcontractors to ensure coordination.
- Review and update the EPD when workplace conditions change or at regular intervals.
Most Common Mistakes
- Preparing the EPD only before an audit and never updating it afterward.
- Doing zone classification superficially without sufficient technical experience.
- Not reflecting the equipment category determined in the EPD into the procurement process.
- Thinking the EPD replaces equipment certification.
- Forgetting to review the EPD after a facility renovation or process change.
- Not informing subcontractor employees within the scope of the EPD.
Frequently Asked Questions
Who is responsible for the Explosion Protection Document?
The Explosion Protection Document is the legal responsibility not of the equipment manufacturer, but of the employer operating the facility that carries explosive atmosphere risk. The manufacturer produces Ex equipment compliant with ATEX, while the employer assesses the environment that equipment is installed in through the document.
For which workplaces is the document mandatory?
It is mandatory for every workplace where an explosive atmosphere may occur due to flammable gas, vapor, mist or dust; chemical and petrochemical facilities, flour/feed production, paint and woodworking workshops are typical examples.
Is the document the same thing as zone classification?
No, zone classification is a sub-component of the document. The document is a broader document that, in addition to zone classification, also covers risk assessment, measures taken, equipment conformity and emergency procedures.
How often should the document be updated?
The document should be reviewed and updated when there is a significant change at the workplace (new equipment, process change, building renovation) or when workplace conditions change; although no fixed legal renewal period is defined, regular review is recommended.
Can a workplace with explosive atmosphere risk operate without the document?
No, failing to prepare the document is a violation of a legal obligation and can lead to administrative sanctions in occupational health and safety inspections; also, without the document, risks are not managed systematically, which brings serious accident risk.
Who can prepare the document?
While the document is the employer's responsibility, it is generally prepared together with occupational safety specialists and engineering consultancy firms with technical experience in ATEX; technical elements such as zone classification require specialized expertise.
Are small-scale businesses exempt from this requirement?
No, the obligation is determined not by business size but by the presence of explosive atmosphere risk; even a small workshop can be subject to this requirement if there is a risk from combustible dust or solvent vapor.
Which equipment is assessed within the document?
All electrical and mechanical equipment present or planned in zone-classified areas is assessed within the document for conformity to the required Ex category for those areas.
Is the document the same as a general OHS risk assessment?
No, a general OHS risk assessment covers all hazards at the workplace, while the document is a separate, more detailed document specifically focused on explosive atmosphere risk; the two complement but do not replace each other.
Is the document requested during inspections?
Yes, the presence and currency of the document is directly queried in occupational health and safety inspections and in investigations following a workplace accident.
Does the document replace the equipment's Ex certificate?
No. The document is the workplace side's obligation; the equipment itself holding an Ex certificate and CE/Ex marking is a separate requirement and is the manufacturer's responsibility.
Conclusion
The Explosion Protection Document is a legal obligation that complements equipment certification, enabling the employer to systematically manage explosive atmosphere risk. An EPD prepared with a holistic approach — from zone classification to equipment conformity, from emergency procedures to regular updates — ensures both legal compliance and strengthens real safety in the field.
Let's assess your facility's EPD needs together. For more information, see our ATEX consultancy service or get in touch.
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