Transcript Folie 1

Seveso II Review
Stakeholder Consultation Meeting
EPSC Position
Richard Gowland Technical Director
Manchester March 10 2010
European Process Safety Centre (EPSC)
• Network funded by about 40 mainly European based
(petro)chemical multinationals to develop best practice in major
accident prevention/process safety
• Objectives:
– Information/know how exchange
– Legislation (esp. Seveso II & ATEX)
– participation & co-ordination of EU funded projects
• Outputs:
– Internal reports & books
– User groups & public conferences
– EU projects & working groups
• Major topics 2009:
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Process Safety Indicators
Post Buncefield Activities
Process Safety Competence
Fostering Senior Management Involvement in Process Safety (with
European Federation of Chemical Engineers)
– LOPA Experience & Development
www.epsc.org
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Background
• EPSC has captured the experience of its members
with requirements of Seveso II at a workshop on April
27, 2009
• At that time from the studies commissioned by the EC
for Seveso II revision only F-Seveso was available
• The results of this workshop have been documented
in a EPSC Position Paper for the Revision of Seveso II
which was published on www.epsc.org in July 2009
and shared with the Commission
• This presentation highlights the main results
Scope of the Directive (Art. 2)
• EPSC strongly suggests not to dilute the focus of Seveso II
– obligation for lower tier establishments to prepare a
Safety Report and the provision of a Safety Management
System
• Is not in line with risk-based approach
• Is not justified by the frequency of major accidents
• Will consume valuable resources and add additional
paperwork both for SMEs and authorities
• The MAPP is a suitable instrument for major accident
scenarios, LUP and an outline of the SMS
– Pipelines, railway stations, harbours and security issues
• Are covered by other existing regulations which
could be amended if necessary
• Clarifying the links to other regulations is supported by
EPSC
• EPSC input to revision of Annex 1 has been given in TWG
on GHS
Domino Effect; Safety Report
• Domino effect (art. 8)
– Cooperation between neighbouring
sites generally works well regardless
of Art. 8
– This may be due to existing personal
relations, Art. 8 should be retained
– For industrial parks cooperation could
be further strengthened by an option
to have a single aggregated Safety
Report for the park
Safety Report
• Safety Report (art. 9)
– Very significant differences in type, quality and
requirements (costs for preparing SRs differ up to 1
magnitude across EU)
– Excessive paperwork distracts resources of
operators and authorities
– Use of 3rd parties leads to ‘mind set’ that the Report
is not really representative of daily life
– EPSC suggests an improved guidance for
consistent implementation
• No “one size fits all” uniform format, but e.g.
• “toolbox” with approved methods for risk
analysis
– Environmental aspects may be included
– Security issues should be covered elsewhere
Emergency Plans, LUP
• Internal/external emergency plans (art. 11)
– No need to change the requirements for internal emergency
plans
– Should remain restricted to upper tier as even non-Seveso
sites have emergency plans due to other regulations
– Implementation of external emergency plans by competent
authorities need more attention
• Land Use Planning (art. 12)
– EPSC position has been comprehensively presented in TWG 5
– Any revision of art. 12 has to allow for different approaches
(little chance of harmonisation)
Communication to/participation of Public (art. 13)
• No need to change art. 13(1) as participation of
public is anyway covered by Responsible Care®
• Availability of safety report to public (art. 13(4))
should be “on demand” only
• Very limited interest from public
• Major parts of safety reports have to be confidential
for security reasons
• Publication via internet should not be encouraged as
users are not identifiable
Accident Info/Prohibition/Inspections/Confidentiality
• Information following a major accident (art. 14, 15)
– No need to change requirements
– Delays in transfer of information generally not caused
by industry
• Prohibition of use (art. 17): no need to change
• Quality and frequency of inspections (art. 18) should be
better harmonised
– Significant differences in time and effort for operator
and authority
– Definition of minimum frequency both for upper and
lower tier
– Justification of higher frequency by authority
– Definition of a “lead authority” to avoid duplication
• Confidentiality (art. 20): no need to change