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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: – – – – 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 2 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