Health and Safety Executive

Health and Safety Executive

Changes to Public Information Culture

SIESO, 13 May 2013

Pauline Nash, Chemical Industries Policypauline.nash@hse.gsi.gov.uk

Purpose of session

• To outline key differences in the public information requirements between Seveso II and Seveso III

• Look at the key issues

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

• Return to a plenary session to present your views for discussion

Setting the context

• EC desire for openness

• UK Government agenda for openness /transparency

• Balancing the conflict between the public ‘right to know’ and national security issues

• Major Hazards work moving in same direction

• Plan to take forward

• Secretary of State Direction

Key differences

1. Public info on safety measures for all establishments - not just TT sites as present

2. Annex 5 – details of public info to be made available - Part 1 for all establishments, Part 2 for TT only

3. Information to be held electronically and permanently available

4. Information to be kept up to date

What are the key issues?

1. Ensuring that the public has access to relevant information which is current

2. How to achieve this?

3. Safety Report v NTS?

4. Confidentiality and security issues

Definitions in Seveso III

• More than in Seveso II

• ‘the public’ – means ‘natural’ or ‘legal persons’, ‘associations’, ‘organisations’ or ‘groups’

• ‘the public concerned’ – relates to the public who would have an interest in planning matters

Public information requirements for LT and TT sites

• Annex V, Part I info permanently electronically available and kept up to date i.e.

Name/trade name of operator and address

Confirmation that the Regs apply

Simple explanation of activities

Common names/generic names of dangerous substances

Public information requirements for LT and TT sites (2)

How the public will be warned and how they should behave in the event of a major accident

Date of last site visit or ref to where the info can be found electronically

Advice where more detailed information about inspection plan and the inspection can be found

Public information requirements for TT sites – Article 14

• Info on safety measures to anyone likely to be affected by a major accident – at least every 5 years

• A copy of Safety Report upon request or NTS if there are confidentiality/security issues

• An inventory of dangerous substances unless confidentiality/security issues

Public information requirements for TT sites – Annex 5

• In addition to the Part 1 requirements, TT sites to also comply with Part 2 requirements:

• …but first 3 requirements same as Seveso II

• The new requirement – operator to indicate if an incident at a site is likely to affect another member state

Taking the Public Information requirements forward

• HSE is currently scoping a project to set up a CA website for the public information requirements

• Potential to form a one-stop shop for information and notifications

• Further down the line - Intervention reports and letters

Non-technical summaries of COMAH Safety Report

• Daniel Gaskarth to provide an overview of the project

• At the end of both presentations there will be an opportunity to explore what has been said.

Thank you.

Daniel GaskarthEnvironment Agency secondee to HSE

SIESO conference, Manchester 13 May 2013

Non-Technical Summaries of COMAHSafety Reports Project

Seveso III requirements

• Balance the conflicting requirements of:– The EC and UK Govt. for openness and the

public “right to know”, and– The Home Office for national security and

restricted access to information

Non-technical summaries of SRs project

• The UK Government Seveso III implementation group set up a project to investigate the feasibility of NTSs

• Project team includes: COMAH regulators, Home Office and Public Health England (PHE)

Non-technical summaries of SRs project

• Objectives:

– Satisfy Seveso III directive requirements– Provide useful information in simple terms– Minimise burden on operators and regulators– Not significantly increase security risk

Annexes II and V and articles 14 and 22

Minimum data in safety report (Article 14.2 and Annex II)

Non technical summary

(Article 14.2 and Article 22)

Permanently available information (Article 14.1 and Annex V)

1. information on management system and on organisation of the establishment with a view to major- accident prevention

2. Presentation of the environment of the establishment

3. Description of the installation

Description of dangerous substances and their characteristics

4. Identification and accidental risks analysis and prevention methods

General information on major accident hazards and potential effects

Summary details of major accident scenarios

5. Measures of protection and intervention to limit consequences of a major accident

Summary details of control measures

NTS project – progress so far•Produced a template (max. 8 sides of A4)

– Includes COMAH named substances and categories (toxic, flammable etc), not every substance

•Presented the idea to industry at a Seveso III seminar in Leeds, October 2012 and launched pilot

•Meeting with Home Office in Feb. 2013 reviewed and approved version 1 of the exemplars

•Reviewed version 2 of the exemplars with pilot companies in May 2013

Sites of non-technical summary exemplars

Map for fictitious example LECC

Detail in full safety report vs NTS and Annex V

•Provision of accurate information at a required level– Technical assessment vs informing the public

•Access to the information– Available on request vs permanently available– Efficiency of response– Resource requirements

Conclusions

• Seveso III requires– more information to be provided to the public– information to be provided electronically

• The CA is considering implementation options in this informal consultation stage

• NTS template being developed virtually reflects the requirements in Annex V

Syndicate work

• Question sheets on tables

• Mixed Groups

• Spokesperson to be appointed to provide feedback