Health and Safety Executive Health and Safety Executive Seveso III Directive Moving from Seveso II...

Health and Safety Executive

Health and Safety Executive

Seveso III DirectiveMoving 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/index.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

• Seveso III will continue to ensure high levels of protection

• Inspection – maintained flexible risk/hazard based

inspection frequencies – BUT need to think about how they can

be linked to other inspections under EU legislation

What are the main changes?

• Scope – some changes eg new named substances, HFOs

• Information to the Public

• Emergency Plans – because of scope, and– Requirement to consult

• Notifications – who will need to re-notify

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!

• Available electronically and kept up to date

• More requirements than before

• Public info on safety measures for all establishments (not just top tier as present)

• Confidentiality & security issues

• 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