specific content of the safety report ike van der putte [email protected]

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

This project is funded by the European Union

Projekat finansira Evropska Unija

SPECIFIC CONTENT OF THE SAFETY REPORT

Ike van der [email protected]



SPECIFIC CONTENT SAFETY REPORT (REF. SEVESO I AND II, WITH ADDITIONAL NOTESCONSIDERING SEVESO III)



SECTIONS OF THE DIRECTIVESRELEVANT TO THIS PRESENTATION96/82/EC DIRECTIVE (SEVESO II) AS AMENDED BY 2003/1005/CE

ARTICLE 9/ ARTICLE 10 - SAFETY REPORT ANDANNEX II – MINIMUM DATA TO BE CONSIDERED IN THE SAFETY REPORT

Additional Notes based on SEVESO III ANNEX II minimum data Safety Report andANNEX III – Safety Management System



General obligations of the operator

A clear general requirement is imposed on the operatorof a Seveso-type establishment (article 5 of the Directive). More specifically:“…the operator is obliged to take all necessary measures to prevent majoraccidents and, in the case of such an accident, to limit its consequences forman and the environment”“…the operator is required to prove, at any time, to the public authorityresponsible for carrying out the duties under the Directive (so-calledCompetent Authority) that he has taken all the necessary measures asspecified in the Directive”.



• a major accident prevention policy (MAPP) and a safety management system (SMS) have been put into effect;• major-accident hazards are identified and necessary measures have been taken to prevent such accidents and to limit their consequences for man and the environment;• adequate safety & reliability have been incorporated into the design, construction, operation and maintenance of any installation;• internal emergency plans have been drawn up, supplying information to enable the external emergency plan to be drawn up;• information for land-use planning decisions has been given.

Member states shall require the operator of an Upper Tier establishment to produce a safety report for the purpose of demonstrating that

Obligations of the operator – Safety report UT article 9/ 10



TASK OF THE COMPETENT AUTHORITY IN RELATIONTO SAFETY REPORTS (1)

• The Competent Authority is required to examine the safety report and tocommunicate the conclusions of its examination to the Operator.

• Before finalizing these conclusions, the Competent Authority may requestfurther information from the Operator; in addition an inspection of theestablishment, in accordance with Article 18, “Inspections” may be carriedout to verify whether the information contained in the safety reportcorresponds with the situation as it is in reality.• The conclusions should generally be in written form, and they should makereference to the date of the safety report in question and any othersupplementary documentation reviewed for this purpose.

A pro forma statement by the Competent Authority that the safety report has beenreceived and seems complete will not be sufficient.



TASK OF THE COMPETENT AUTHORITY IN RELATION TO SAFETY REPORTS (2)

The conclusions should make reference to general conclusions based on the safety report in general and to specific cases of accuracy where individual examples havebeen examined in detail. Deficiencies and inaccuracies must be describedwhere identified, however it is not expected that the competent authorityshould identify every single inaccuracy.

Note:a large number of deficiencies and inaccuracies may lead the competent authority to reject the safety report and require that a revised document is submitted.



IN SUMMARY

The Competent Authority

• examines the Safety Report • requests further information from the operator (if necessary) • decides to allow or • prohibit (Art. 17/ art 19) the bringing into use or continued use of the establishment • communicates conclusions to the operator.



Article 9/ 10: Safety Reports

This article of the Directive requires that an operator of an upper-tierSeveso type establishment produce a safety report

In the Seveso II Directive(96/82/EC) significant additional requirements (including the MAPP and SMS) were introduced as part of a more comprehensive “safety report”.



THRESHOLDS

Annex I

Two categories based on quantities stored

Lower TierUpper Tier

Upper Tier has more responsibilities



REQUIREMENTS

LOWER TIER

General Obligations

Notification

Major Accident Prevention Policy

Modifications

Accident Reports

Cooperation with Authorities



OBLIGATIONS

UPPER TIER

Lower Tier Obligations

and

Safety Report (incl. MAPP & SMS)

Internal Emergency Plans

Information to Public



The requirements for policies and management systems which apply to a lower tier establishment are:

similar to those for an upper tier establishment except that:• the Directive states that the requirements should be proportionate to the major-accident hazards presented by the establishment, • it is not necessary to prepare a detailed report for demonstrating how the Safety Management System has been put into effect;• the document setting out the MAPP must be ‘made available’ but need not necessarily be sent to the competent authorities.



Risk Assessment

Iterative Process

Fine tuning of scenario

definition based on risk evaluation

results and impacts of risk

reduction measures

Risk Reduction

Collation of Information on process/activity

Hazard Identification

Hazard Screening

Scenario Definition (High Risk Hazards

Only)

Risk Evaluation

Risk assessment



Risk Reduction

Review Existing Preventative/Control

Measures

Identify Further Preventative/ Control

Measures

Risk Assessment

Review for Acceptability – As

Low As Reasonably Practicable (ALARP)

Accept or Implement Preventative/ Control

Measures

Carry out Cost/Benefit

Analysis

Risk reduction



ANNEX IIMINIMUM DATA AND INFORMATION TO BE CONSIDERED IN THESAFETY REPORT SPECIFIED IN ARTICLE 9/ 10

I. Information on the management system and on the organization of theestablishment with a view to major accident prevention (ref article 7 and Annex III: MAPP & SMS)

II. Presentation of the environment of the establishment

III. Description of the installation

IV. Identification and accidental risks analysis and prevention methods

V. Measures of protection and intervention to limit the consequences of anaccident



I. INFORMATION ON THE MANAGEMENT SYSTEM AND ON THE ORGANIZATION OF THE ESTABLISHMENT WITH A VIEW TO MAJOR ACCIDENT PREVENTIONTHIS INFORMATION SHALL CONTAIN THE ELEMENTS GIVEN IN ANNEX III.

(a) the major accident prevention policy (MAPP) should be established in writing andshould include the operator's overall aims and principles of action withrespect to the control of major-accident hazards;

(b) the safety management system (SMS) should include the part of the generalmanagement system which includes the organizational structure, responsibilities,practices, procedures, processes and resources for determining andimplementing the major-accident prevention policy (7 SMS issues described in detail);

• organization and personnel• identification and evaluation of major hazards• operational control• management of change• planning for emergencies• monitoring performance• audit and review



II. PRESENTATION OF THE ENVIRONMENT OF THE ESTABLISHMENT

A. description of the site and its environment including the geographicallocation, meteorological, geological, hydrographic conditions and, ifnecessary, its history;

B. identification of installations and other activities of the establishmentwhich could present a major-accident hazard;

C. description of areas where a major accident may occur.



III. DESCRIPTION OF THE INSTALLATION

A. description of the main activities and products of the parts of the establishmentwhich are important from the point of view of safety, sourcesof major-accident risks and conditions under which such a major accidentcould happen, together with a description of proposed preventivemeasures;B. description of processes, in particular the operating methods;C. description of dangerous substances:

1. inventory of dangerous substances including:— the identification of dangerous substances: chemical name, CASnumber, name according to IUPAC nomenclature,— the maximum quantity of dangerous substances present or likelyto be present;2. physical, chemical, toxicological characteristics and indication of hazards, both immediate and delayed for man and the environment;3. physical and chemical behaviour under normal conditions of use or under foreseeable accidental conditions.



IV. IDENTIFICATION AND ACCIDENTICAL RISK ANALYSISAND PREVENTION METHODS

A. detailed description of the possible major-accident scenarios and theirprobability or the conditions under which they occur including asummary of the events which may play a role in triggering each of thesescenarios, the causes being internal or external to the installation;

B. assessment of the extent and severity of the consequences of identifiedmajor accidents including maps, images or, as appropriate, equivalentdescriptions, showing areas which are liable to be affected by such accidentsarising from the establishment, subject to the provisions ofArticles 13(4) (SR public info) and 20 (confidentiality);

C. description of technical parameters and equipment used for the safety ofinstallations.

NOTE SEVESO III: also review of past accidents and lessons learnedto prevent these



V. MEASURES OF PROTECTION AND INTERVENTIONTO LIMIT THE CONSEQUENCES OF AN ACCIDENT

A. description of the equipment installed in the plant to limit the consequencesof major accidents;

B. organization of alert and intervention;

C. description of mobilizable resources, internal or external;

D. summary of elements described in A, B, and C above necessary fordrawing up the internal emergency plan prepared in compliance withArticle 11 (Emergency plans).



CONTENTS OF UPPER TIER SAFETY REPORTS

Minimum SEVESO requirements for a SR (Upper Tier)1. Description of establishment and neighboring environment2. Dangerous Substances (Quantities vs SEVESO Qualifying quantities ) 3. Hazard Analysis (HA) : safety critical equipment/circuits 4. Major Accident Scenarios (Reference Scenarios), Phenomena with

consequences outside the establishment Worst Case Scenarios (WCSs)5. Consequence Zones (Z1, Z2, Z3)6. Risk Assessment RA (Consequence based or QRA)7. Domino 8. Safety Management System of the company as implemented in the

establishment

__________________________________________________________________________________Ref. G. PAPADAKIS - SEVESO SERBIA 24th June 2013

In Summary



Safety ReportStructure and development



STRUCTURE OF SAFETY REPORT

Introduction - BackgroundSafety Management System

Major Accident (MA) Prevention Policy

MA Organisation MA Planning Risk Control Systems Performance Measurement Audit and Review



STRUCTURE OF SAFETY REPORT(CONTINUED)

Description of the EnvironmentDescription of the InstallationPrincipal InstallationsFacilities for Limiting the Consequences of a Release

Unit Operations Areas with Potential for MAH Hazardous Materials on Site



STRUCTURE OF SAFETY REPORT

Hazard Identification and Risk Assessment

Measures of Prevention, Control and Intervention

ReferencesAttachments - Basis of Safety, Site

Plans, Meteorological Data, Inventory of Hazardous Materials, Extracts from Site Risk Assessments



SAFETY REPORT HAZARDS

Basis for Inclusion in Safety ReportMultiple types - fire, explosion,

toxic gas releaseHighest risksOffsite impactsEnvironmental impactDemonstrate ALARP



SAFETY REPORT HAZARDS (CONTINUED)

Dust ExplosionHydrogen Release - Fire &

ExplosionToxic Gas ReleaseSolvent Tank Farm FireEnvironmental Release



SAFETY REPORT DEVELOPMENT

Collaborative effort with CAWorked through Employers GroupWorked with CA individually

Biggest problem - getting direction on specifics, e.g. modelling end-points.

CA learning also



COMPLIANCE - INTERDEPENDENT EVENTS

Carry out risk assessmentDevelop scenarios and carry out

modelling

Develop internal emergency plans

Supply information for external emergency plans

Inform Community



COMPLIANCE - INTERDEPENDENT EVENTS (CONTINUED)

Submit Safety ReportHSA review and agree report

Specified areas agreed, impact on external emergency plans

Carry out necessary modifications/ implement procedures, e.g. Siren



DISCUSSIONS WITH HSA

DEMONSTRATE acceptable riskWorst Possible vs Worst CredibleEmergency Services need Worst

CaseSpecified Distance vs

Consultation DistanceDangerous Dose vs ERPGLittle credit for good SMS



DISCUSSIONS WITH HSA (CONTINUED)

Consider EscalationUse Quantified Risk

Assessment (QRA) to demonstrate credible

Address hierarchy of Elimination, Reduction, etc.

Specified areas for rivers?



DISCUSSIONS WITH HSA (CONTINUED)

Consider flooding/high water table

Consider Heritage sitesContainment rather than

modelling for Environmental risks

Appropriate data for modelling



RESOURCES

Risk AssessmentConsultant for 9 months

Safety Engineer for 6 months

Process Engineers for 10 weeks

Safety ReportConsultant for 6 months

Safety Engineer for 4 months

Staff for 1 month



REFERENCESCOUNCIL DIRECTIVE 96/82/ECof 9 December 1996 on the control of major-accident hazards involving dangerous substances(OJ L 10, 14.1.1997, p. 13) – consolidated version

DIRECTIVE 2012/18/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 4 July 2012 on the control of major-accident hazards involving dangerous substances, amending and subsequently repealing Council Directive 96/82/EC

Planning for Emergencies Involving Dangerous Substances for Slovenia. Final Report. Contract no: SL-0081.0011.01. 28 February 2012. I.van der Putte: Regional Environment Accession Project (REAP). Nethconsult/BKH Consulting Engineers/RPS. Subcontractors: AEA Technology, URS/Dames & Moore, EPCE, Project Management Group, REC Hungary

specific content of the safety report ike van der putte [email protected]

Documents

european union project

safety report ike

safety report additional

relationto safety reports

safety management system

human dynamics consortiumtask

environmentthe operator

ce article