Health
Healthand
andSafety
Safety
Executive
Executive
Changes to emergency planning
requirements
SIESO, 13 May 2013
Christina Roberts, Chemical Industries Policy
Nic 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 gather delegate responses
To discuss how best to implement the
requirements (syndicate work)
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
•
Information to the public
Timescales for preparation of emergency plans
Public concerned given early opportunity to give
opinion on off site emergency plan
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!