Health Healthand andSafety Safety Executive Executive Seveso III Directive Moving from Seveso II to Seveso III Sandra Ashcroft, HSE 19 March 2013 Background to Seveso Directive • • • • Seveso I adopted in 1982 to control major accident hazards Current COMAH Regs 1999 and planning legislation implement Seveso II Seveso III necessary as CHIP being replaced by CLP by 2015 Overall purpose & approach to stay the same – Identification of sites, controls and mitigation • European Commission also took opportunity to modernise the Directive – – – – Public info Access to justice Public participation Inspections Current situation • • • Seveso III adopted on 4th July 2012 http://ec.europe.eu/environment/seveso/ind ex.htm New COMAH Regs to be in force from 1June 2015 Key issues: • • • • Scope Public information Inspection Lack of correction system for substances moving in or out of scope What will stay the same? • • Lot of changes but many are subtle • Inspection – maintained flexible risk/hazard based inspection frequencies – BUT need to think about how they can be linked to other inspections under EU legislation Seveso III will continue to ensure high levels of protection What are the main changes? • Scope – some changes eg new named substances, HFOs • • Information to the Public • Notifications – who will need to re-notify Emergency Plans – because of scope, and – Requirement to consult Scope • Early indications – only a small movement of sites coming into/going out of scope • Helpful amendments on named substances • Determining whether the Directive applies will be more complex Public information • • Culture shift! • • More requirements than before • • Confidentiality & security issues Available electronically and kept up to date Public info on safety measures for all establishments (not just top tier as present) Access to justice Transitional arrangements • Notifications – who will need to re-notify – Implications for HSC • • • Safety Reports Emergency plans Confidentiality Question on notifications • Do you accept the need to re-notify under COMAH 2015 with CLP info? • Can see another way of doing it to reduce the burden on operators? • Do you only have on site named substances from the named substance list in COMAH? Timetable • Now – end of 2013 – informal consultation with industry and stakeholders – Research Group for impact assessment • Early 2014 – formal consultation; heavy fuel oils amendment to COMAH Regs 1999 • Early 2015 – lay Regulations & publication of guidance • 1 June 2015 – new COMAH Regs enter into force Government policy • • • • Copy-out Gold-plating Government view on guidance UK influence on original Seveso Directive Question on inspection • Would it be beneficial to your site to link COMAH inspection with environmental inspection where possible – Just with Environmental Permitting Regs & Scottish equivalent? – More general with other environmental inspection regimes? • Do you perceive it to be more burdensome to link COMAH inspections with other regimes? Sources of information • Seveso website www.hse.gov.uk/seveso/ revised and will continue to be updated. Current features include; - information about Seveso III - implications for business - FAQs • Seveso ebulletin http://www.hse.gov.uk/seveso/bulletin.htm • Guidance http://www.hse.gov.uk/comah/index.htm • • Any questions Thank you for listening