Health
Healthand
andSafety
Safety
Executive
Executive
Energy Division’s Proposed
Policy on Targeting and
Prioritisation
WIG Conference
18 September 2013
Susan Mackenzie
[2013/326517]
HSE’s Intervention Policy
•
Enforcement Policy Statement
– Targeting, Proportionality, Consistency,
Transparency, Accountability
•
HID guiding principle (2012)
– Major hazard intervention programme
should be based on a systematic
approach based on
• inherent hazard and
• performance of duty holder in
controlling risk
Major Hazard Sites in UK
288 operational installations +
800 “COMAH” Sites
500 Biohazard Laboratories
500 Licensed Explosive Sites
300 Major Hazard Pipelines
50 Gas Distribution Networks
6 Major Hazard Mines
Priority for Intervention
Risk
Ranking
Inherent
Hazard
Operator
Performance
Other
Intelligence
Examples of onshore Inherent hazard
models
EXAMPLE INTRINSIC HAZARD FACTORS
COMAH
Mines
Pipelines
Biological agents
Nature of substance
Flammable atmosphere
Length of pipeline
Agent
Installation type
Toxic gases
Nature of fluid
Nature of work
On & offsite population
Inrush
Flammability
Complexcity
Societal risk factor
Rock fall
Toxicity
High containment work
Safety
Shafts
Major accident hazard
Environment
Mass transport
U/G population
Escape distance
Inherent Hazard Model Offshore
Offshore Working Group (March 2013)
Principles
•
•
•
Broad classification
•
Major hazard focussed
Information readily available
Preferably based on industry’s own
information
Broad Classifications on Inherent
Hazard
•
•
•
•
•
•
High
Medium
Low
Pictorial view
Not based on a mathematical algorithm
Will require some professional judgement
Example – Draft 5
Inherent Hazard based on PLL
Operator Performance
•
Operator’s performance in complying
with the law to control Major Hazard
risk will influence the depth and
frequency of regulatory scrutiny.
•
Operator Performance against single
inspection topics
– Strategic areas
– Key risk control systems
– Based on standards
Offshore inspection rating topics
Inspection guides
•
•
•
Cover strategic and sector topics
•
•
•
Performance score
Define what we look at
The standard/benchmark against we rate
performance
Enforcement expectations
How we record (COIN requirements)
Operator Performance
Overall Operator Performance
•
•
Work in progress across HID
•
Do not intend to “average” out
compliance gaps.
•
A full picture of performance will be
built up over a number of years
•
We will continue to feedback
performance at each inspection in
usual way
Individual scores of 30-60 are
compliance gaps
Other intelligence may include
[Nothing New]
•
•
Time since last inspection
•
•
Incident data
Issues arising out of other regulatory
contact such as
– safety case assessment
– incident investigations
– complaints
Emerging issues
The concept of
Indicative Resource Levels
Inspection plan progress report
Any further questions