Health and Safety Executive

Health and Safety Executive

Changes to emergency planning requirements

SIESO, 13 May 2013

Christina Roberts, Chemical Industries PolicyNic Butcher, HM Specialist Inspector

Purpose of session

• To outline key differences in emergency planning requirements between COMAH Regs 1999 and Seveso III Directive

• To address some key issues

• To discuss how best to implement the requirements (syndicate work)

• To gather delegate responses

What stays the same?

• Top tier operators required to draw up onsite emergency plan and provide sufficient information to offsite emergency planners

• Local emergency planning authority to draw up offsite emergency plans

• Train, test, review etc

• Lower tier requirements

What are the key differences? Issues?

Differences:

• Content of off site emergency plan

• Timescales for preparation of emergency plans

• Public concerned given early opportunity to give opinion on off site emergency plan

• Information to the public

Issues to consider:

• Link to civil contingencies

• Lower tier establishments

Differences between COMAH Regs 1999 and Seveso III requirements

1. Content of off site emergency plans• Extra info required for off site emergency plans

– Arrangements for off site mitigatory action to include:• Responses to major accident scenarios from the

safety report• Considering possible domino effects • Including environmental impact of above

– Arrangements for providing neighbouring establishments – not just defined ‘domino’ ones - and other neighbouring sites with information on accidents and actions to be taken.

• Will this make much of a difference?

Seveso III Directive types of establishment

Before looking at timescales for emergency plan preparation, need to understand establishment definitions:

• New– Comes into scope after 31 May 2015– Operating prior to 1 June 2015, but comes into scope or

changes tier due to voluntary modifications leading to changes in inventory.

• Existing– In scope on 31 May 2015 and is still in scope on 1 June 2015

with no changes in tier.

• Other– Comes into scope or changes tier due to involuntary

modifications e.g. substance category change

Differences between COMAH Regs 1999 and Seveso III requirements

2. Timescales for provision of information by operator for offsite emergency planning– ‘New’ establishments – reasonable period of time

prior to operation.– ‘Existing’ establishments – by 1 June 2016 for

additional info (unless already provided).– ‘Other’ establishments – will have 2 yrs to provide

information.

• Plus a further 2 yrs to produce off site emergency plan from when information received i.e. up to 4 yrs in total for ‘other’ establishments!

• Concerns???

Differences between COMAH Regs 1999 and Seveso III requirements

3. ‘Public concerned’ given early opportunity to give opinion on external emergency plans

• Who is ‘public concerned’?

• How do we deal with a transient population?

• How can we best contact the ‘public concerned’?

Differences between COMAH Regs 1999 and Seveso III requirements

4. Information to the public• More on this later today… but with respect to emergency

planning:• Requirement for information to be permanently available,

including electronically. Includes:– How the public concerned is warned– Appropriate behaviour in the event of an accident / or

where they can find this information• Applies to lower tier sites – how will we do this?• Also for top tier sites:

– Appropriate information from off site emergency plan – what should this information be?

Issues to consider

1. Link to civil contingencies

• What are the current links?

• Are the current arrangements working?

Issues to consider

2. Lower tier establishments

• No specific requirements to draw up a onsite or offsite plan under article 12

• However, within the requirements for safety management systems:

Planning for emergencies - adoption and implementation of procedures to identify foreseeable emergencies by systematic analysis, to prepare, test and review emergency plans to respond to such emergencies and provide specific training for the staff concerned... Etc.

• Note – there is no change from Seveso II

• But are existing arrangements adequate??

Others???

• Are there any other key differences?

Syndicate work

• How best to implement the requirements

Staying in touch

• Seveso website http://www.hse.gov.uk/seveso/

• Seveso ebulletin http://www.hse.gov.uk/seveso/ebulletin.htm

• Consultation – informal & formal

• Guidance including recent COMAH CA information

Thanks!