Seveso II ReviewStakeholder Consultation Meeting

EPSC PositionRichard Gowland Technical Director

Manchester March 10 2010

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European Process Safety Centre (EPSC)

• Network funded by about 40 mainly European based (petro)chemical multinationals to develop best practice in major accident prevention/process safety

• Objectives:– Information/know how exchange– Legislation (esp. Seveso II & ATEX) – participation & co-ordination of EU funded projects

• Outputs: – Internal reports & books– User groups & public conferences – EU projects & working groups

• Major topics 2009: – Process Safety Indicators– Post Buncefield Activities– Process Safety Competence– Fostering Senior Management Involvement in Process Safety (with

European Federation of Chemical Engineers)– LOPA Experience & Development

www.epsc.org

Background

• EPSC has captured the experience of its members with requirements of Seveso II at a workshop on April 27, 2009

• At that time from the studies commissioned by the EC for Seveso II revision only F-Seveso was available

• The results of this workshop have been documented in a EPSC Position Paper for the Revision of Seveso II which was published on www.epsc.org in July 2009 and shared with the Commission

• This presentation highlights the main results

Scope of the Directive (Art. 2)

• EPSC strongly suggests not to dilute the focus of Seveso II– obligation for lower tier establishments to prepare a

Safety Report and the provision of a Safety Management System• Is not in line with risk-based approach• Is not justified by the frequency of major accidents• Will consume valuable resources and add additional

paperwork both for SMEs and authorities• The MAPP is a suitable instrument for major accident

scenarios, LUP and an outline of the SMS– Pipelines, railway stations, harbours and security issues

• Are covered by other existing regulations which could be amended if necessary

• Clarifying the links to other regulations is supported by EPSC

• EPSC input to revision of Annex 1 has been given in TWG on GHS

Domino Effect; Safety Report

• Domino effect (art. 8) –Cooperation between neighbouring

sites generally works well regardless of Art. 8–This may be due to existing personal

relations, Art. 8 should be retained–For industrial parks cooperation could

be further strengthened by an option to have a single aggregated Safety Report for the park

Safety Report

• Safety Report (art. 9)– Very significant differences in type, quality and

requirements (costs for preparing SRs differ up to 1 magnitude across EU)

– Excessive paperwork distracts resources of operators and authorities

– Use of 3rd parties leads to ‘mind set’ that the Report is not really representative of daily life

– EPSC suggests an improved guidance for consistent implementation• No “one size fits all” uniform format, but e.g.• “toolbox” with approved methods for risk

analysis– Environmental aspects may be included– Security issues should be covered elsewhere

Emergency Plans, LUP

• Internal/external emergency plans (art. 11) – No need to change the requirements for internal emergency

plans

– Should remain restricted to upper tier as even non-Seveso sites have emergency plans due to other regulations

– Implementation of external emergency plans by competent authorities need more attention

• Land Use Planning (art. 12) – EPSC position has been comprehensively presented in TWG 5

– Any revision of art. 12 has to allow for different approaches (little chance of harmonisation)

Communication to/participation of Public (art. 13)

• No need to change art. 13(1) as participation of public is anyway covered by Responsible Care®

• Availability of safety report to public (art. 13(4)) should be “on demand” only

• Very limited interest from public• Major parts of safety reports have to be confidential

for security reasons• Publication via internet should not be encouraged as

users are not identifiable

Accident Info/Prohibition/Inspections/Confidentiality

• Information following a major accident (art. 14, 15) – No need to change requirements– Delays in transfer of information generally not caused

by industry

• Prohibition of use (art. 17): no need to change

• Quality and frequency of inspections (art. 18) should be better harmonised– Significant differences in time and effort for operator

and authority– Definition of minimum frequency both for upper and

lower tier– Justification of higher frequency by authority– Definition of a “lead authority” to avoid duplication

• Confidentiality (art. 20): no need to change