PSLG Final Report Gap Analysis Tool v0_2 sflb by O0i1oX

VIEWS: 8 PAGES: 63

									UK Petroleum Industry Association Ltd.


              Gap Analysis Tool

          PSLG FINAL REPORT


 Document Reference:       PSLG Final Report Gap Analysis Tool
 Document Revision:        0.2


 Completed For:   <Enter Facility>
                                                                                                                                                                                                                     Page 2 of 65




Overview

Foreword
This tool has been produced by UKPIA, and provides a methodology that may be used for the performance of gap analysis against the final report of the Process Safety Leadership Group.

This gap analysis tool was developed by UKPIA and its member companies to provide a methodology that may be used for gap analysis against the final report of the Process Safety Leadership Group. It is not the
intention that this gap analysis tool should replace any existing corporate assessment or audit activities. The intent of this tool is to provide an additional means that organisations may use in the pursuit of excellence
in process safety.

There are no limitations on further distribution of this gap analysis tool to other organisations outside of UKPIA, provided that:
1. It is understood that the tool represents UKPIA‟s view only of how gap analysis should be performed
2. UKPIA owns all rights to the guidance
3. UKPIA accepts no responsibility in terms of the use or misuse of this tool
4. It is understood that no warranty is given in relation to the accuracy or completeness of information contained in the tool except that it is believed to be substantially correct at the time of publication

Gap analysis is against current levels of implementation at individual operators sites. Completion of the gap analysis is not risk based, and therefore comparisons between levels of implementation at different
facilities should not be drawn.

Scope of the gap analysis
For Parts 1, 2, 3, 5, 6 and Appendices 4, 5 and 6, Gap analysis should be performed against 'in-scope' tanks as defined by paragraph 24 of the report:

In-scope gasoline tanks are defined as:

those storing gasoline (petrol) as defined in Directive 94/63/EC European Parliament and Council Directive 94/63/EC of 20 December 1994 on the control of volatile organic compound emissions resulting from the
storage of petrol and its distribution from terminals to service stations;
vertical, cylindrical, non-refrigerated, above-ground storage tanks typically designed to standards BS 2654, BS EN 14015, API 620, API 650 (or equivalent codes at the time of construction);
with side walls greater than 5 m in height; and
filled at rates greater than 100 m 3 /hour (this is approximately 75 tonnes/hour of gasoline).

The quantity of in-scope tanks should be entered into the orange cell in Part 1 Gap analysis

Part 4 gap analysis is assessed against bund quantity, enter the quantity of bunds in the orange cell in Part 4 Gap Analysis

Notes and guidance
Where appropriate, the text included within the gap analysis tables has been adapted from the original PSLG paragraph, structuring the text as a question, more fitting to gap analysis tools. In case of confusion
however, reference should be made to the original PSLG report text

No gap analysis is offered for appendices, 1, 2, 3, 7, 8, 9 or 10

Where paragraphs indicate 'Noted', reference should be made to the text within the final PSLG report for supporting guidance and clarification

Data should be entered into ORANGE cells only. All other cells have been locked.

When completing each analysis table, be aware of the information provided in the 'table guidance', this provides additional information for how to complete the gap analysis.

Where the table guidance indicates that assessment is against individual tanks, enter the quantity of tanks that are either:
Not Implemented: The number of in scope tanks that do not meet the requirement
Partially Implemented: The number of in scope tanks that partially meet the requirement, there is a need/intent to carry out further work
Fully Implemented: The number of in scope tanks that fully meet the requirement
Implemented SFAIRP: The number of in scope tanks that meet the requirement so far as is reasonably practicable, no intent to carry out further work - not justified on the grounds of reasonable practicability
Not Applicable: The number of in scope tanks for which this requirement is not applicable

Where the table guidance indicates that assessment is not against individual tanks, but instead against management systems, enter a '1' in the appropriate column (one column only):
Not Implemented: The management system or process does not meet the requirement
Partially Implemented: The management system or process partially meets the requirement, there is a need/intent to carry out further work
Fully Implemented: The management system or process fully meets the requirement
Implemented SFAIRP: The management system or process meets the requirement so far as is reasonably practicable, no intent to carry out further work - not justified on the grounds of reasonable practicability
Not Applicable: The management system or process for this requirement is not applicable

Where the table guidance indicates that assessment is against bund quantity (Part 4 only), enter the quantity of bunds that are either:
Not Implemented: The number of bunds that do not meet the requirement
Partially Implemented: The number of bunds that partially meet the requirement, there is a need/intent to carry out further work
Fully Implemented: The number of bunds that fully meet the requirement
Implemented SFAIRP: The number bunds that meet the requirement so far as is reasonably practicable, no intent to carry out further work - not justified on the grounds of reasonable practicability
Not Applicable: The number of bunds for which this requirement is not applicable

Use the 'Status' column at the end of each table to ascertain errors/incomplete gap analysis:
RED indicates that there is an error in the quantity of tanks specified
YELLOW indicates that analysis is not complete for all in-scope tanks
GREEN indicates that analysis has been completed for all in-scope tanks

The priority column is provided for operators to record perceived implementation priorities to assist in preparing an implementation plan

NOTE: The Proposed Completion Date column represents a best estimate for the anticipated completion date for closing the gap. This is based on best knowledge at the time of the gap analysis and
is subject to change once detailed implementation plans are developed in the three months after Gap Analysis. Therefore it is not appropriate for the proposed completion dates listed here to be




Process Safety Leadership Group
Final Report Gap Analysis                                                                                   Overview                                                                                               Revision: 0.2
                                                                                                   Page 3 of 65



Summary
           Recommendation         Implemented        Partially Implemented       Not Implemented
                  1               Not Calculated         Not Calculated           Not Calculated
                  2               Not Calculated         Not Calculated           Not Calculated
                  3
                  4               Not Calculated         Not Calculated           Not Calculated
                  5
                  6                                   Refer to Appendix 5
                  7                                   Refer to Appendix 5
                  8               Not Calculated         Not Calculated           Not Calculated
                  9               Not Calculated         Not Calculated           Not Calculated
                 10                                   Refer to Appendix 5
                 11               Not Calculated         Not Calculated           Not Calculated
                 12                                   Refer to Appendix 6
                 13                                Refer to Recommendation 8
                 14               Not Calculated         Not Calculated           Not Calculated
                 15               Not Calculated         Not Calculated           Not Calculated
                 16               Not Calculated         Not Calculated           Not Calculated
                 17
                                  Not Calculated         Not Calculated           Not Calculated
                 18
                 19                                   Refer to Appendix 5
                 20                                   Refer to Appendix 5
                 21               Not Calculated        Not Calculated            Not Calculated
                 22                                 Competent Authority Action
                 23
                 24               Not Calculated         Not Calculated           Not Calculated
                 25
              Appendix 1                           Provided for information only
              Appendix 2                         Provided for supporting guidance
              Appendix 3                         Provided for supporting guidance
              Appendix 4          Not Completed          Not Completed            Not Completed
              Appendix 5          Not Calculated         Not Calculated           Not Calculated
              Appendix 6          Not Calculated         Not Calculated           Not Calculated
              Appendix 7                           Provided for information only
              Appendix 8                           Provided for information only
              Appendix 9                           Provided for information only
             Appendix 10                           Provided for information only




Process Safety Leadership Group
Final Report Gap Analysis                          Summary                                         Revision 0.2
                                                                                                                                                                                                                                                                                                                                                                Page 4 of 66




Statistical Summary
Recommendation 1

                                                                                     PSLG Part 1, Recommendation 1 Implementation

            100%

             80%

             60%                                                                                                                                                                                                                                                                                                                        Implemented
                                                                                                                                                                                                                                                                                                                                        Partially Implemented
             40%
                                                                                                                                                                                                                                                                                                                                        Not Implemented
             20%

             0%
                           R.1.1
                                      R.1.2
                                               R.1.3
                                                          R.1.4
                                                                   R.1.5
                                                                             R.1.6
                                                                                         R.1.7
                                                                                                 R.1.8




Recommendation 2

                                                                                                                               PSLG Part 2, Recommendation 2
                                                                                                                                      Implementation
     100%

      80%

      60%
                                                                                                                                                                                                                                                                                                                                        Not Implemented
      40%
                                                                                                                                                                                                                                                                                                                                        Partially Implemented
      20%
                                                                                                                                                                                                                                                                                                                                        Implemented
       0%
              R.2.1
                         R.2.2
                                     R.2.3
                                               R.2.4
                                                           R.2.5
                                                                     R.2.6
                                                                               R.2.7
                                                                                            R.2.8
                                                                                                       R.2.9
                                                                                                                    R.2.10
                                                                                                                              R.2.11
                                                                                                                                           R.2.12
                                                                                                                                                     R.2.13
                                                                                                                                                               R.2.14
                                                                                                                                                                          R.2.15
                                                                                                                                                                                       R.2.16
                                                                                                                                                                                                      R.2.17
                                                                                                                                                                                                                R.2.18
                                                                                                                                                                                                                            R.2.19




Recommendation 3, 4 and 5

                                                                                                       PSLG Part 2, Recommendations 3, 4 and 5
                                                                                                                    Implementation
     100%

      80%

      60%
                                                                                                                                                                                                                                                                                                                                        Not Implemented
      40%
                                                                                                                                                                                                                                                                                                                                        Partially Implemented
      20%
                                                                                                                                                                                                                                                                                                                                        Implemented
        0%
               R.345.1

                           R.345.2

                                         R.345.3

                                                       R.345.4

                                                                   R.345.5

                                                                               R.345.6

                                                                                             R.345.7

                                                                                                          R.345.8

                                                                                                                         R.345.9

                                                                                                                                       R.345.10

                                                                                                                                                    R.345.11

                                                                                                                                                               R.345.12

                                                                                                                                                                            R.345.13

                                                                                                                                                                                           R.345.14

                                                                                                                                                                                                           R.345.15

                                                                                                                                                                                                                         R.345.16

                                                                                                                                                                                                                                     R.345.17

                                                                                                                                                                                                                                                R.345.18

                                                                                                                                                                                                                                                           R.345.19

                                                                                                                                                                                                                                                                      R.345.20

                                                                                                                                                                                                                                                                                 R.345.21

                                                                                                                                                                                                                                                                                            R.345.22

                                                                                                                                                                                                                                                                                                       R.345.23

                                                                                                                                                                                                                                                                                                                  R.345.24

                                                                                                                                                                                                                                                                                                                             R.345.25




Recommendation 6 and 7
Refer to Appendix 5




Process Safety Leadership Group
Final Report Gap Analysis                                                                                                                                                                             Statistical Summary                                                                                                                                       Revision 0.2
                                                                                                Page 5 of 66




Recommendation 8

                                      PSLG Part 2, Recommendation 8
                                             Implementation
     100%

      80%

      60%
                                                                        Not Implemented
      40%                                                               Partially Implemented
      20%                                                               Implemented

       0%
            R.8.1
                      R.8.2
                              R.8.3




Recommendation 9

                                      PSLG Part 2, Recommendation 9
                                             Implementation
     100%

      80%

      60%
                                                                        Not Implemented
      40%                                                               Partially Implemented
      20%                                                               Implemented

       0%
              R.9.1




Process Safety Leadership Group
Final Report Gap Analysis                         Statistical Summary                           Revision 0.2
                                                                                                                                                                 Page 6 of 66




Recommendation 10
Refer to Appendix 5



Recommendation 11

                                                                                            PSLG Part 3, Recommendation 11
                                                                                                    Implementation
     100%

      80%

      60%
                                                                                                                                         Not Implemented
      40%
                                                                                                                                         Partially Implemented
      20%
                                                                                                                                         Implemented
       0%
             R.11.1




Recommendation 12
Refer to Appendix 6



Recommendation 13
Refer to Recommendation 8



Recommendation 14

                                                                                            PSLG Part 3, Recommendation 14
                                                                                                    Implementation
     100%

      80%

      60%
                                                                                                                                         Not Implemented
      40%
                                                                                                                                         Partially Implemented
      20%
                                                                                                                                         Implemented
       0%
             R.14.1

                       R.14.2

                                    R.14.3

                                                 R.14.4

                                                           R.14.5

                                                                    R.14.6




Recommendation 15

                                                                                            PSLG Part 3, Recommendation 15
                                                                                                    Implementation
     100%

      80%

      60%
                                                                                                                                         Not Implemented
      40%
                                                                                                                                         Partially Implemented
      20%
                                                                                                                                         Implemented
       0%
              R.15.1

                           R.15.2

                                             R.15.3

                                                          R.15.4

                                                                     R.15.5

                                                                              R.15.6

                                                                                       R.15.7

                                                                                                R.15.8

                                                                                                         R.15.9


                                                                                                                  R.15.1

                                                                                                                  R.15.1

                                                                                                                  R.15.1

                                                                                                                  R.15.1

                                                                                                                  R.15.1

                                                                                                                  R.15.1

                                                                                                                  R.15.1

                                                                                                                  R.15.1

                                                                                                                  R.15.1

                                                                                                                  R.15.1
                                                                                                                    0

                                                                                                                    1

                                                                                                                    2

                                                                                                                    3

                                                                                                                    4

                                                                                                                    5

                                                                                                                    6

                                                                                                                    7

                                                                                                                    8

                                                                                                                    9




Process Safety Leadership Group
Final Report Gap Analysis                                                                                          Statistical Summary                           Revision 0.2
                                                        Page 7 of 66




Process Safety Leadership Group
Final Report Gap Analysis         Statistical Summary   Revision 0.2
                                                                                                                                                                                                                                                                                                                                                                                                                                                                        Page 8 of 66




Recommendation 16

                                                                                                                                                                         PSLG Part 3, Recommendation 16
                                                                                                                                                                                 Implementation
     100%

      80%

      60%
                                                                                                                                                                                                                                                                                                                                                                                                                                                Not Implemented
      40%
                                                                                                                                                                                                                                                                                                                                                                                                                                                Partially Implemented
      20%
                                                                                                                                                                                                                                                                                                                                                                                                                                                Implemented
       0%
              R.16.1

                              R.16.2

                                                   R.16.3

                                                                        R.16.4

                                                                                            R.16.5




Recommendation 17 and 18

                                                                                           PSLG Part 4, Recommendations 17 and 18
                                                                                     Implementation (Requirements R.17.18.1 to R.17.18.26)
     100%

      80%

      60%
                                                                                                                                                                                                                                                                                                                                                                                                                                                Not Implemented
      40%                                                                                                                                                                                                                                                                                                                                                                                                                                       Partially Implemented

      20%                                                                                                                                                                                                                                                                                                                                                                                                                                       Implemented


       0%
            R.17.18.1
                         R.17.18.2
                                          R.17.18.3
                                                            R.17.18.4
                                                                              R.17.18.5
                                                                                                R.17.18.6
                                                                                                                   R.17.18.7
                                                                                                                                      R.17.18.8
                                                                                                                                                        R.17.18.9
                                                                                                                                                                         R.17.18.…
                                                                                                                                                                                         R.17.18.…
                                                                                                                                                                                                        R.17.18.…
                                                                                                                                                                                                                     R.17.18.…
                                                                                                                                                                                                                                 R.17.18.…
                                                                                                                                                                                                                                              R.17.18.…
                                                                                                                                                                                                                                                             R.17.18.…
                                                                                                                                                                                                                                                                             R.17.18.…
                                                                                                                                                                                                                                                                                              R.17.18.…
                                                                                                                                                                                                                                                                                                                R.17.18.…
                                                                                                                                                                                                                                                                                                                                   R.17.18.…
                                                                                                                                                                                                                                                                                                                                                      R.17.18.…
                                                                                                                                                                                                                                                                                                                                                                        R.17.18.…
                                                                                                                                                                                                                                                                                                                                                                                         R.17.18.…
                                                                                                                                                                                                                                                                                                                                                                                                         R.17.18.…
                                                                                                                                                                                                                                                                                                                                                                                                                        R.17.18.…
                                                                                                                                                                                                                                                                                                                                                                                                                                    R.17.18.…




                                                                                      PSLG Part 4, Recommendations 17 and 18
                                                                                Implementation (Requirements R.17.18.27 to R.17.18.52)
     100%

      80%

      60%
                                                                                                                                                                                                                                                                                                                                                                                                                                                Not Implemented
      40%                                                                                                                                                                                                                                                                                                                                                                                                                                       Partially Implemented

      20%                                                                                                                                                                                                                                                                                                                                                                                                                                       Implemented


       0%
            R.17.18.…
                        R.17.18.…
                                       R.17.18.…
                                                      R.17.18.…
                                                                         R.17.18.…
                                                                                          R.17.18.…
                                                                                                            R.17.18.…
                                                                                                                          R.17.18.…
                                                                                                                                            R.17.18.…
                                                                                                                                                             R.17.18.…
                                                                                                                                                                             R.17.18.…
                                                                                                                                                                                            R.17.18.…
                                                                                                                                                                                                         R.17.18.…
                                                                                                                                                                                                                     R.17.18.…
                                                                                                                                                                                                                                 R.17.18.…
                                                                                                                                                                                                                                             R.17.18.…
                                                                                                                                                                                                                                                          R.17.18.…
                                                                                                                                                                                                                                                                         R.17.18.…
                                                                                                                                                                                                                                                                                         R.17.18.…
                                                                                                                                                                                                                                                                                                          R.17.18.…
                                                                                                                                                                                                                                                                                                                            R.17.18.…
                                                                                                                                                                                                                                                                                                                                          R.17.18.…
                                                                                                                                                                                                                                                                                                                                                            R.17.18.…
                                                                                                                                                                                                                                                                                                                                                                             R.17.18.…
                                                                                                                                                                                                                                                                                                                                                                                             R.17.18.…
                                                                                                                                                                                                                                                                                                                                                                                                            R.17.18.…




Recommendation 19
Refer to Appendix 5



Recommendation 20
Refer to Appendix 5




Process Safety Leadership Group
Final Report Gap Analysis                                                                                                                                                                                                                                 Statistical Summary                                                                                                                                                                                           Revision 0.2
                                                                                                      Page 9 of 66




Recommendation 21

                                       PSLG Part 5, Recommendation 21
                                               Implementation
     100%

      80%

      60%
                                                                              Not Implemented
      40%
                                                                              Partially Implemented
      20%
                                                                              Implemented
       0%
              R.21.1




Recommendation 22
Competent Authority Action



Recommendation 23, 24 and 25

                                  PSLG Part 5, Recommendation 23, 24 and 25
                                                Implementation
     100%

      80%

      60%
                                                                              Not Implemented
      40%
                                                                              Partially Implemented
      20%
                                                                              Implemented
       0%
             R.23.2
             4.25.1




Process Safety Leadership Group
Final Report Gap Analysis                           Statistical Summary                               Revision 0.2
                                                                                                                                                                                                                                                                                                                                                            Page 10 of 66




Appendix 4

                                                                                  PSLG Appendix 4
                                                                   Implementation (Requirements R.A4.1 to R.A4.24)
     100%

      80%

      60%
                                                                                                                                                                                                                                                                                                                                    Not Implemented
      40%
                                                                                                                                                                                                                                                                                                                                    Partially Implemented
      20%                                                                                                                                                                                                                                                                                                                           Implemented

       0%
             R.A4.1

                       R.A4.2

                                 R.A4.3

                                            R.A4.4

                                                       R.A4.5

                                                                   R.A4.6

                                                                               R.A4.7

                                                                                            R.A4.8

                                                                                                          R.A4.9

                                                                                                                        R.A4.10

                                                                                                                                       R.A4.11

                                                                                                                                                       R.A4.12

                                                                                                                                                                           R.A4.13

                                                                                                                                                                                           R.A4.14

                                                                                                                                                                                                           R.A4.15

                                                                                                                                                                                                                          R.A4.16

                                                                                                                                                                                                                                        R.A4.17

                                                                                                                                                                                                                                                      R.A4.18

                                                                                                                                                                                                                                                                   R.A4.19

                                                                                                                                                                                                                                                                               R.A4.20

                                                                                                                                                                                                                                                                                           R.A4.21

                                                                                                                                                                                                                                                                                                      R.A4.22

                                                                                                                                                                                                                                                                                                                R.A4.23

                                                                                                                                                                                                                                                                                                                          R.A4.24
                                                                                   PSLG Appendix 4
                                                                   Implementation (Requirements R.A4.25 to R.A4.47)
     100%

      80%

      60%
                                                                                                                                                                                                                                                                                                                                    Not Implemented
      40%
                                                                                                                                                                                                                                                                                                                                    Partially Implemented
      20%                                                                                                                                                                                                                                                                                                                           Implemented

       0%
             R.A4.25

                       R.A4.26

                                  R.A4.27

                                             R.A4.28

                                                         R.A4.29

                                                                     R.A4.30

                                                                                  R.A4.31

                                                                                                R.A4.32

                                                                                                              R.A4.33

                                                                                                                             R.A4.34

                                                                                                                                             R.A4.35

                                                                                                                                                                 R.A4.36

                                                                                                                                                                                     R.A4.37

                                                                                                                                                                                                     R.A4.38

                                                                                                                                                                                                                     R.A4.39

                                                                                                                                                                                                                                    R.A4.40

                                                                                                                                                                                                                                                  R.A4.41

                                                                                                                                                                                                                                                                R.A4.42

                                                                                                                                                                                                                                                                             R,A4.43

                                                                                                                                                                                                                                                                                         R.A4.44

                                                                                                                                                                                                                                                                                                     R.A4.45

                                                                                                                                                                                                                                                                                                                R.A4.46

                                                                                                                                                                                                                                                                                                                          R.A4.47

                                                                                   PSLG Appendix 4
                                                                   Implementation (Requirements R.A4.48 to R.A4.59)
     100%

      80%

      60%
                                                                                                                                                                                                                                                                                                                                    Not Implemented
      40%
                                                                                                                                                                                                                                                                                                                                    Partially Implemented
      20%                                                                                                                                                                                                                                                                                                                           Implemented

        0%
             R.A4.48

                       R.A4.49

                                 R.A4.50

                                            R.A4.51

                                                       R.A4.52

                                                                   R.A4.53

                                                                               R.A4.54

                                                                                            R.A4.55

                                                                                                          R.A4.56

                                                                                                                         R.A4.57

                                                                                                                                        R.A4.58

                                                                                                                                                        R.A4.59




Process Safety Leadership Group
Final Report Gap Analysis                                                                                                                                                                      Statistical Summary                                                                                                                                           Revision 0.2
Page 11 of 66




                                                                                                                                                                                                                                                                                                                                      Revision 0.2
                                                                                                                     Partially Implemented




                                                                                                                                                                                                                                                                   Partially Implemented
                                                                                                  Not Implemented




                                                                                                                                                                                                                                                Not Implemented
                                                                                                                                             Implemented




                                                                                                                                                                                                                                                                                           Implemented




                                                                                                                                                                R.A5.30                                                                                                                                       R.A5.59
                                                                                                                                                                          Implementation (Requirements R.A5.31 to R.A5.59)
                             Implementation (Requirements R.A5.1 to R.A5.30)




                                                                                                                                                                R.A5.29                                                                                                                                       R.A5.58
                                                                                                                                                                R.A5.28                                                                                                                                       R.A5.57
                                                                                                                                                                R.A5.27                                                                                                                                       R.A5.56
                                                                                                                                                                R.A5.26                                                                                                                                       R.A5.55
                                                                                                                                                                R.A5.25                                                                                                                                       R.A5.54
                                                                                                                                                                R.A5.24                                                                                                                                       R.A5.53
                                                                                                                                                                R.A5.23                                                                                                                                       R.A5.52




                                                                                                                                                                                                                                                                                                                                      Statistical Summary
                                                                                                                                                                R.A5.22
                                            PSLG Appendix 5




                                                                                                                                                                                          PSLG Appendix 5



                                                                                                                                                                                                                                                                                                              R.A5.51
                                                                                                                                                                R.A5.21
                                                                                                                                                                                                                                                                                                              R.A5.50
                                                                                                                                                                R.A5.20
                                                                                                                                                                                                                                                                                                              R.A5.49
                                                                                                                                                                R.A5.19
                                                                                                                                                                                                                                                                                                              R.A5.48
                                                                                                                                                                R.A5.18
                                                                                                                                                                                                                                                                                                              R.A5.47
                                                                                                                                                                R.A5.17
                                                                                                                                                                                                                                                                                                              R.A5.46
                                                                                                                                                                R.A5.16
                                                                                                                                                                                                                                                                                                              R.A5.45
                                                                                                                                                                R.A5.15
                                                                                                                                                                                                                                                                                                              R.A5.44
                                                                                                                                                                R.A5.14
                                                                                                                                                                                                                                                                                                              R.A5.43
                                                                                                                                                                R.A5.13
                                                                                                                                                                                                                                                                                                              R.A5.42
                                                                                                                                                                R.A5.12
                                                                                                                                                                                                                                                                                                              R.A5.41
                                                                                                                                                                R.A5.11
                                                                                                                                                                                                                                                                                                              R.A5.40
                                                                                                                                                                R.A5.10
                                                                                                                                                                R.A5.9                                                                                                                                        R.A5.39
                                                                                                                                                                R.A5.8                                                                                                                                        R.A5.38
                                                                                                                                                                R.A5.7                                                                                                                                        R.A5.37
                                                                                                                                                                R.A5.6                                                                                                                                        R.A5.36




                                                                                                                                                                                                                                                                                                                        Process Safety Leadership Group
                                                                                                                                                                R.A5.5                                                                                                                                        R.A5.35
                                                                                                                                                                R.A5.4                                                                                                                                        R.A5.34




                                                                                                                                                                                                                                                                                                                        Final Report Gap Analysis
                                                                                                                                                                R.A5.3                                                                                                                                        R.A5.33
                Appendix 5

                                                                                                                                                                R.A5.2                                                                                                                                        R.A5.32
                                                                                                                                                                R.A5.1                                                                                                                                        R.A5.31




                                                                               100%

                                                                                      80%

                                                                                            60%

                                                                                                                    40%

                                                                                                                                             20%

                                                                                                                                                           0%




                                                                                                                                                                                                                             100%

                                                                                                                                                                                                                                    80%

                                                                                                                                                                                                                                          60%

                                                                                                                                                                                                                                                                  40%

                                                                                                                                                                                                                                                                                           20%

                                                                                                                                                                                                                                                                                                         0%
Page 12 of 66




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    Revision 0.2
                                                                                                                                                                                                                                                                   Partially Implemented




                                                                                                                                                                                                                                                                                                                                                                                                                 Partially Implemented
                                                                                                                     Partially Implemented




                                                                                                                                                                                                                                                Not Implemented




                                                                                                                                                                                                                                                                                                                                                                                              Not Implemented
                                                                                                  Not Implemented




                                                                                                                                                                                                                                                                                           Implemented




                                                                                                                                                                                                                                                                                                                                                                                                                                         Implemented
                                                                                                                                             Implemented




                                                                                                                                                                R.A6.32                                                                                                                                                                                                                                                                                     R.A6.82
                                                                                                                                                                          Implementation (Requirements R.A6.33 to R.A6.57)




                                                                                                                                                                                                                                                                                                                        Implementation (Requirements R.A6.58 to R.A6.82)
                             Implementation (Requirements R.A6.1 to R.A6.32)




                                                                                                                                                                R.A6.31
                                                                                                                                                                                                                                                                                                                                                                                                                                                            R.A6.81
                                                                                                                                                                R.A6.30
                                                                                                                                                                                                                                                                                                              R.A6.57                                                                                                                                       R.A6.80
                                                                                                                                                                R.A6.29
                                                                                                                                                                                                                                                                                                              R.A6.56
                                                                                                                                                                R.A6.28                                                                                                                                                                                                                                                                                     R.A6.79
                                                                                                                                                                R.A6.27                                                                                                                                       R.A6.55
                                                                                                                                                                                                                                                                                                                                                                                                                                                            R.A6.78
                                                                                                                                                                R.A6.26                                                                                                                                       R.A6.54
                                                                                                                                                                                                                                                                                                                                                                                                                                                            R.A6.77
                                                                                                                                                                R.A6.25                                                                                                                                       R.A6.53
                                                                                                                                                                R.A6.24                                                                                                                                                                                                                                                                                     R.A6.76




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    Statistical Summary
                                                                                                                                                                                                                                                                                                              R.A6.52
                                                                                                                                                                                          PSLG Appendix 6




                                                                                                                                                                                                                                                                                                                                        PSLG Appendix 6
                                            PSLG Appendix 6




                                                                                                                                                                R.A6.23                                                                                                                                                                                                                                                                                     R.A6.75
                                                                                                                                                                                                                                                                                                              R.A6.51
                                                                                                                                                                R.A6.22
                                                                                                                                                                                                                                                                                                                                                                                                                                                            R.A6.74
                                                                                                                                                                R.A6.21                                                                                                                                       R.A6.50
                                                                                                                                                                                                                                                                                                              R.A6.49                                                                                                                                       R.A6.73
                                                                                                                                                                R.A6.20
                                                                                                                                                                R.A6.19                                                                                                                                       R.A6.48                                                                                                                                       R.A6.72
                                                                                                                                                                R.A6.18                                                                                                                                       R.A6.47                                                                                                                                       R.A6.71
                                                                                                                                                                R.A6.17
                                                                                                                                                                                                                                                                                                              R.A6.46                                                                                                                                       R.A6.70
                                                                                                                                                                R.A6.16
                                                                                                                                                                                                                                                                                                              R.A6.45                                                                                                                                       R.A6.69
                                                                                                                                                                R.A6.15
                                                                                                                                                                R.A6.14                                                                                                                                       R.A6.44                                                                                                                                       R.A6.68
                                                                                                                                                                R.A6.13                                                                                                                                       R.A6.43                                                                                                                                       R.A6.67
                                                                                                                                                                R.A6.12                                                                                                                                       R.A6.42
                                                                                                                                                                                                                                                                                                                                                                                                                                                            R.A6.66
                                                                                                                                                                R.A6.11
                                                                                                                                                                                                                                                                                                              R.A6.41
                                                                                                                                                                R.A6.10                                                                                                                                                                                                                                                                                     R.A6.65
                                                                                                                                                                                                                                                                                                              R.A6.40
                                                                                                                                                                R.A6.9                                                                                                                                                                                                                                                                                      R.A6.64
                                                                                                                                                                R.A6.8                                                                                                                                        R.A6.39
                                                                                                                                                                                                                                                                                                                                                                                                                                                            R.A6.63
                                                                                                                                                                R.A6.7                                                                                                                                        R.A6.38
                                                                                                                                                                                                                                                                                                                                                                                                                                                            R.A6.62




                                                                                                                                                                                                                                                                                                                                                                                                                                                                      Process Safety Leadership Group
                                                                                                                                                                R.A6.6                                                                                                                                        R.A6.37
                                                                                                                                                                R.A6.5                                                                                                                                                                                                                                                                                      R.A6.61
                                                                                                                                                                                                                                                                                                              R.A6.36
                                                                                                                                                                R.A6.4




                                                                                                                                                                                                                                                                                                                                                                                                                                                                      Final Report Gap Analysis
                                                                                                                                                                                                                                                                                                              R.A6.35                                                                                                                                       R.A6.60
                                                                                                                                                                R.A6.3
                Appendix 6

                                                                                                                                                                                                                                                                                                              R.A6.34                                                                                                                                       R.A6.59
                                                                                                                                                                R.A6.2
                                                                                                                                                                R.A6.1                                                                                                                                        R.A6.33                                                                                                                                       R.A6.58




                                                                                                                                                                                                                                                                                                                                                                                  80%
                                                                                                                                                                                                                             100%

                                                                                                                                                                                                                                    80%

                                                                                                                                                                                                                                          60%

                                                                                                                                                                                                                                                                  40%

                                                                                                                                                                                                                                                                                           20%




                                                                                                                                                                                                                                                                                                                                                                           100%



                                                                                                                                                                                                                                                                                                                                                                                        60%

                                                                                                                                                                                                                                                                                                                                                                                                                40%

                                                                                                                                                                                                                                                                                                                                                                                                                                         20%
                                                                                                                                                                                                                                                                                                         0%




                                                                                                                                                                                                                                                                                                                                                                                                                                                       0%
                                                                               100%

                                                                                      80%

                                                                                            60%

                                                                                                                    40%

                                                                                                                                             20%

                                                                                                                                                           0%
                                                                                                                                                                                                                                                                                                                                       Page 13 of 65




Part 1 - Systematic assessment of safety integrity level requirements

                 Gap Analysis Completion Date:                                                                                                             In-Scope Tank Quantity:             0



Recommendation 1

             MIIB Design and Operations Report Recommendation 1:
             The Competent Authority and operators of Buncefield-type sites should develop and agree a common methodology to determine safety integrity level (SIL) requirements for overfill prevention systems in line with the principles set out in Part 3 of BS EN 61511. This methodology should take account of:
                                 (a) the existence of nearby sensitive resources or populations
                                 (b) the nature and intensity of depot operations
                                 (c) realistic reliability expectations for tank gauging systems; and
                                 (d) the extent/rigour of operator monitoring
             Application of the methodology should be clearly demonstrated in the COMAH safety report submitted to the Competent Authority for each applicable site. Existing safety reports will need to be reviewed to ensure this methodology is adopted


             Table guidance:                                                                                                                                                                                                                                                                                    Green = Complete
                           (a) For this table, level of implementation is gauged on compliance for each individual tank                                                                                                                                                                                         Yellow = Incomplete
                           (b) Enter the tank quantity in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable                                                                                                              Red = Error
                           (c) The total in-scope tanks can be found on the Part 1 Gap Analysis worksheet

                                                                                                                                                                                         In-Scope Tanks (Meeting Paragraph 24)
                                                                                                                                                                                                       %
                 MIIB D&O                          PSLG or BSTG        Requirement                                                                                                                      C Fully Meets     Meets
   Section                            Paragraph                                             Requirement                                                         Priority       Not          Partially                                                  Reference                         Comments               Status
              Recommendation                        Reference[1]         Number                                                                                                                      Compliant          Requirement   Not Applicable
                                                                                                                                                                           Implemented    Implemented oRequirements
                                                                                                                                                                                                        m                 SFAIRP
                                                                                                                                                                                                        p
                                          29             PSLG                               Noted
                                          30             PSLG                               Noted
                                                                                            Has a risk assessment[2] been completed for each in-scope
                                        31, 32           BSTG               R.1.1                                                                                              0               0              0              0              0                                                                      1
                                                                                            tank to determine the necessary layers of protection required?
                                                                                            Where LOPA (or an equivalent technique) has been used as
                                          33             PSLG               R.1.2           the risk assessment technique, has the guidance in Appendix                        0               0              0              0              0                                                                      1
                                                                                            2 been followed?
                                          34             BSTG                               Refer to Part 2 Gap Analysis
                                                                                            Do systems providing a risk reduction of less than 10, which
                                                                                            provide a layer of protection considered in the risk
                                          35             BSTG               R.1.3                                                                                              0               0              0              0              0                                                                      1
                                                                                            assessment, comply with good practice in design and
                                                                                            maintenance so far as reasonably practicable?
                                                                                            For tanks which receive product from a remote location, does
   Part 1              1                  36             BSTG               R.1.4           the receiving site have control of tank filling by means of local                  0               0              0              0              0                                                                      1
                                                                                            systems and valves?
                                          37             BSTG                               Refer to Part 2 Gap Analysis
                                                                                            Do tank instrumentation and information display systems
                                          38             BSTG               R.1.5           have appropriate accuracy and clarity to ensure safe planning                      0               0              0              0              0                                                                      1
                                                                                            and control of product transfer?
                                                                                            Are the risk assessments completed for each tank
                                        39, 40           BSTG               R.1.6           periodically reviewed to take account of new knowledge and                         0               0              0              0              0                                                                      1
                                                                                            standards development?
                                                                                            Are the findings of the risk assessment for each in-scope tank
                                          41             BSTG               R.1.7                                                                                              0               0              0              0              0                                                                      1
                                                                                            included within the COMAH safety report?
                                          42             BSTG                               Noted
                                                                                            Have you considered the probability of human error when
                                          43             BSTG               R.1.8                                                                                              0               0              0              0              0                                                                      1
                                                                                            completing the risk assessment?




                                                                                            PSLG Part 1, Recommendation 1 Implementation

                                                                           100%

                                                                            80%

                                                                            60%                                                                                             Implemented
                                                                                                                                                                            Partially Implemented
                                                                            40%
                                                                                                                                                                            Not Implemented
                                                                            20%

                                                                             0%
                                                                                    R.1.1

                                                                                             R.1.2

                                                                                                     R.1.3

                                                                                                             R.1.4

                                                                                                                     R.1.5

                                                                                                                             R.1.6

                                                                                                                                     R.1.7

                                                                                                                                             R.1.8




Process Safety Leadership Group
Final Report Gap Analysis                                                                                                                                                  Part 1 Gap Analysis                                                                                                                                        Revision: 0.2
                                                                                                                                                                                                                                                                                                                        Page 14 of 64




Part 2 - Protecting against loss of primary containment using high integrity systems
Recommendation 2

           MIIB Design and Operations Report Recommendation 2:
           Operators of Buncefield-type sites should, as a priority, review and amend as necessary their management systems for maintenance of equipment and systems to ensure their continuing integrity in operation. This should include, but not be limited to reviews of the following:
                      (a) the arrangements and procedures for periodic proof testing of storage tank overfill prevention systems to minimise the likelihood of any failure that could result in loss of containment; any revisions identified pursuant to this review should be put into immediate effect;
                      (b) the procedures for implementing changes to equipment and systems to ensure any such changes do not impair the effectiveness of equipment and systems in preventing loss of containment or in providing emergency response.


           Table guidance:
                       For this table, level of implementation is not gauged against the quantity of individual tanks, but instead implementation of the management system processes as a
                   (a)
                       whole
                   (b) Enter '1' in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable

                                                                                                                                                                                                              Level of Implementation
                                                                                                                                                                                                                  C%
                               MIIB D&O                            PSLG or BSTG        Requirement                                                                                                                                  Meets
              Section                               Paragraph                                            Requirement                                                         Priority       Not         Partially  C
                                                                                                                                                                                                                  o Fully Meets                                             Reference                        Comments
                            Recommendation                          Reference[1]         Number                                                                                         Implemented   Implemented mRequirements
                                                                                                                                                                                                                   o              Requirement   Not Applicable
                                                                                                                                                                                                                  pm                SFAIRP
                                                                                                                                                                                                                  lp
                                                         44             PSLG                             Noted
                                                         45             PSLG                             Noted
                                                         46             PSLG                             Noted
                                                   Management of instrumented systems for fuel storage tank installations
                                                         47             PSLG                             Noted
                                                         48             PSLG                             Refer to Appendix 4 Gap Analysis
                                                                                                         Is there a management system in place in place for the whole
                                                                                                         lifecycle of the SIS for all SIF of SIL1 or higher which is
                                                         49             PSLG                R.2.1                                                                                           0             0             0              0              0
                                                                                                         compliant to BS EN 61511? (Refer to specific requirements
                                                                                                         R.2.3 to R.2.18 for details)
                                                                                                         For systems providing a risk reduction of less than 10 that
                                                                                                         contribute to the overall safety function, is there a
                                                                                                         management system in place in place for the whole lifecycle of
                                                         50             PSLG                R.2.2                                                                                           0             0             0              0              0
                                                                                                         the system which is compliant to BS EN 61511 so far as
                                                                                                         reasonably practicable? (Refer to specific requirements R.2.3
                                                                                                         to R.2.18 for details)
                                                         51             PSLG                             Refer to Appendix 5 Gap Analysis
                                                         52             PSLG                             Refer to R.2.3 to R2.18
                                                                                                         Does the management system safety planning elements
                                                                                                         identify all the required tasks that need to be performed at
                                                         53             PSLG                R.2.3        various stages and allocate roles and responsibilities of people                   0             0             0              0              0
                                                                                                         (departments, individuals, staff or contractors) to perform
                                                                                                         those tasks?
                                                                                                         Are the organisation and planning elements documented and
                                                         54             PSLG                R.2.4        reviewed as necessary when changes occur throughout the                            0             0             0              0              0
                                                                                                         operational life of the system?
                                                                                                         Are the roles and responsibilities associated with the SIS (such
                                                                                                         as design, operation, maintenance, testing etc) documented
                                                         55             PSLG                R.2.5                                                                                           0             0             0              0              0
                                                                                                         and communicated, including a description of the tasks and
                                                                                                         who is responsible for performing the tasks?

                                                                                                         Are the people with responsibilities competent to perform their
                                                                                                         tasks consistently to the required standard? The required
                                                                                                         knowledge, understanding and skills for competences can be
                                                         56             PSLG                R.2.6        wide ranging and depend on the role and type of task, and                          0             0             0              0              0
                                                                                                         these may be for design, engineering, system technology,
                                                                                                         hazard and safety engineering, regulations, management,
                                                                                                         leadership, maintenance and testing
                                                                                                         Are arrangements in place to evaluate the performance and
                                                                                                         validation of a safety instrumented system? This should
                                                         57             PSLG                R.2.7        include validation that the system design meets the                                0             0             0              0              0
                                                                                                         requirements of BS EN 61511 and the system operation fulfils
                                                                                                         this design intent
                                                                                                         Are failures of the system or of any component of the system
                                                         58             PSLG                R.2.8        investigated and recorded, together with any modifications and                     0             0             0              0              0
                                                                                                         maintenance performed?
                                                                                                         Are the details of any demands on the system, and system
                                                                                                         performance on demand recorded, including data on any
                                                         59             PSLG                R.2.9        spurious trips, revealed failures of the system and its                            0             0             0              0              0
                                                                                                         components, and in particular any failures identified during
                                                                                                         proof testing?
                                                                                                         Are records of all these events [R.2.9] kept for future analysis?
                                                         60             PSLG               R.2.10                                                                                           0             0             0              0              0
                                                                                                         (Records may be paper or electronic)




                 2                   2



Process Safety Leadership Group
Final Report Gap Analysis                                                                                                                                   Part 2 Gap Analysis                                                                                                                                          Revision 0.2
                                                                                                                                                                          Page 15 of 64




                                                                             Are arrangements in place for the operation, maintenance and
                                                                             system testing and inspection for the whole system and
                                                                             subcomponents? Written procedures should be agreed by
                                                                             those the dutyholder has identified as responsible and
                                                                             competent for these functions [R.2.5, R.2.6]. Procedures and
                                          61         PSLG          R.2.11                                                                             0   0   0   0   0
                                                                             competency arrangements should be based on adequate
                 2                2
                                                                             consideration of human failure potential in carrying out
                                                                             inspection, maintenance and testing activities. Reference
                                                                             should be made to Appendix 5 for general guidance on
                                                                             procedures and competence assurance
                                                                             Has the initial test interval been determined by the calculation
                                                                             of the probability of failure on demand during the design
                                          62         PSLG          R.2.12                                                                             0   0   0   0   0
                                                                             phase, and is this assessed and amended periodically based
                                                                             on real operational data?
                                                                             Are procedures for functional safety assessment and auditing
                                                                             in place? Functional safety is the part of the overall safety
                                                                             arrangements that depends on a system or equipment
                                          63         PSLG          R.2.13    operating correctly in response to its inputs (BS EN 61508) - a          0   0   0   0   0
                                                                             functional safety assessment is an independent assessment
                                                                             and audit of the functional safety requirements and the safety
                                                                             integrity level achieved by the SIS.

                                                                             Has at least one functional safety assessment been performed
                                                                             on each system (typically at the design stage before the
                                                                             system is commissioned)? The functional safety assessment
                                                                             process should be performed by an assessment team which
                                                                             includes at least one competent person independent of the
                                                                             project design team [R.2.5, R.2.6]. A functional safety
                                                                             assessment should be performed and revalidated after any
                                          64         PSLG          R.2.14    modifications, mal-operation or failure to deliver the required          0   0   0   0   0
                                                                             safety function (a spurious trip which caused the safety system
                                                                             to action its functions successfully would not be considered a
                                                                             failure). The depth and scope of the functional safety
                                                                             assessment should be based on the specific circumstances,
                                                                             including the size of the project, complexity, SIL and the
                                                                             consequences of failure. Further guidance is given in BS EN
                                                                             61511 Section 5
                                                                             Where changes or modifications to an SIS are planned, are
                                                                             these changes subject to a management of change process?
                                          65         PSLG          R.2.15                                                                             0   0   0   0   0
                                                                             The procedure should identify and address any potential safety
                                                                             implications of the modification
                                                                             Are software changes and system configuration changes also
                                          66         PSLG          R.2.16                                                                             0   0   0   0   0
                                                                             subject to a management of change process?
                                                                             Is all associated documentation maintained, accurate and up
                                          67         PSLG          R.2.17    to date with all necessary information available to allow                0   0   0   0   0
                                                                             operation and lifecycle management?
                                                                             The documentation [R.2.17] should include but not be limited
                                                                             to process and instrumentation diagrams, system design and
                                                                             testing requirements, and a description of maintenance
                                                                             activities for the various components of the SIS from sensors
                                          68         PSLG          R.2.18                                                                             0   0   0   0   0
                                                                             to final elements inclusive. Documentation of the design should
                                                                             include risk assessment for SIL determination, design
                                                                             specification, factory acceptance testing, installation
                                                                             specification, and commissioning tests
                                      Probabilistic preventative maintenance for atmospheric bulk storage tanks
                                                                             EEMUA 159 probabilistic preventative maintenance approach,
                                                                             or a suitable and demonstrable risk-based system, when
                                                                             referenced together with the standards signposted for integrity
                                                                             management of atmospheric bulk storage tanks, provides the
                                                                             benchmark standard which will enable the dutyholder to have
                                          69         PSLG          R.2.19                                                                             0   0   0   0   0
                                                                             a suitable maintenance strategy and policy underpinning their
                                                                             systems and procedures. Have current tank integrity
                                                                             management systems been assessed against EEMUA 159, or
                                                                             equivalent, and an improvement plan drawn up, as necessary,
                                                                             to ensure arrangements meet this standard?




Process Safety Leadership Group
Final Report Gap Analysis                                                                                                       Part 2 Gap Analysis                        Revision 0.2
                                                                                                                                                                                                                                   Page 16 of 64




                                                                                 PSLG Part 2, Recommendation 2
                                                                                        Implementation
                                  100%

                                  80%

                                  60%
                                                                                                                                                                                                           Not Implemented
                                  40%
                                                                                                                                                                                                           Partially Implemented
                                  20%
                                                                                                                                                                                                           Implemented
                                   0%




                                         R.2.1
                                                 R.2.2
                                                         R.2.3
                                                                 R.2.4
                                                                         R.2.5
                                                                                 R.2.6
                                                                                         R.2.7
                                                                                                 R.2.8
                                                                                                         R.2.9
                                                                                                                 R.2.10
                                                                                                                          R.2.11
                                                                                                                                   R.2.12
                                                                                                                                            R.2.13
                                                                                                                                                     R.2.14
                                                                                                                                                              R.2.15
                                                                                                                                                                       R.2.16
                                                                                                                                                                                R.2.17
                                                                                                                                                                                         R.2.18
                                                                                                                                                                                                  R.2.19




Process Safety Leadership Group
Final Report Gap Analysis                                                                                                                               Part 2 Gap Analysis                                                         Revision 0.2
                                                                                                                                                                                                                                                                                                                            Page 17 of 64




Recommendations 3, 4 and 5

           MIIB Design and Operations Report Recommendation 3:
           Operators of Buncefield-type sites should protect against loss of containment of petrol and other highly flammable liquids by fitting a high integrity, automatic operating overfill prevention system (or a number of such systems, as appropriate) that is physically and electrically separate and independent from the
           tank gauging system
           Such systems should meet the requirements of Part 1 of BS EN 61511 for the required safety integrity level, as determined by the agreed methodology (see Recommendation 1). Where independent automatic overfill prevention systems are already provided, their efficacy and reliability should be reappraised in
           line with the principles of Part 1 of BS EN 61511 and for the required safety integrity level, as determined by the agreed methodology (see Recommendation 1)

           MIIB Design and Operations Report Recommendation 4:
           The overfill prevention system (comprising means of level detection, logic/control equipment and independent means of flow control) should be engineered, operated and maintained to achieve and maintain an appropriate level of safety integrity in accordance with the requirements of the recognised industry
           standard for ‘SIS’, Part 1 of BS EN 61511


           MIIB Design and Operations Report Recommendation 5:
           All elements of an overfill prevention system should be proof tested in accordance with the validated arrangements and procedures sufficiently frequently to ensure the specified safety integrity level is maintained in practice in accordance with the requirements of Part 1 of BS EN 61511


           Table guidance:
                   (a) For this table, level of implementation is gauged on compliance for each individual tank
                      (b) Enter the tank quantity in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable
                      (c) The total in-scope tanks can be found on the Part 1 Gap Analysis worksheet

                                                                                                                                                                                                                Level of Implementation
                                                                                                                                                                                                                   C%
                                MIIB D&O                           PSLG or BSTG        Requirement                                                                                                                 oC                  Meets
              Section                                Paragraph                                          Requirement                                                           Priority       Not         Partially     Fully Meets                                       Reference                              Comments
                             Recommendation                         Reference[1]         Number                                                                                                                    mo                Requirement   Not Applicable
                                                                                                                                                                                         Implemented   Implemented    Requirements
                                                                                                                                                                                                                   pm                  SFAIRP
                                                                                                                                                                                                                   lp
                                                   Automatic overfill protection systems for bulk gasoline storage tanks
                                                         70             PSLG                            Refer to Appendix 4 Gap Analysis
                                                         71             PSLG                            Noted
                                                         72             PSLG                            Noted
                                                                                                        Are in-scope tanks fitted with a high integrity overfill prevention
                                                                                                        system that complies with BS EN 61511-1 (Refer to Appendix
                                                                                                        4 Gap Analysis for details)? Has a risk assessment to
                                                                                                        determine the appropriate SIL to meet the requirements of BS
                                                         73             PSLG              R.345.1                                                                                            0              0              0              0              0
                                                                                                        EN 61511-1 been performed? [R.1.1]. The outcome of that
                                                                                                        risk assessment should demonstrate that the risk arising from
                                                                                                        a tank overfilling in a way that may give rise to a major
                                                                                                        accident is ALARP.
                                                                                                        Does the high integrity overfill prevention system, as a
                                                                                                        minimum, provide a level of SIL 1 as defined in BS EN 61511-
                                                                                                        1? To reduce risk as low as reasonably practicable the overfill
                                                                                                        prevention system should preferably be automatic and should
                                                         74             PSLG              R.345.2                                                                                            0              0              0              0              0
                                                                                                        be physically and electrically separate from the tank gauging
                                                                                                        system. Automatic overfill prevention may include, but not be
                                                                                                        restricted to, measures such as automatic shutdown of the
                                                                                                        supply line or automatic diversion of the flow to another tank
                                                         75             PSLG                            Refer to R.345.3 and R345.4
                                                                                                        Where [R.345.2] has not been met (as categorised in
                                                                                                        paragraph 75), is there a robust demonstration that alternative
                                                                                                        measures are capable of achieving an equivalent ALARP
                                                         76             PSLG              R.345.3                                                                                            0              0              0              0              0
                                                                                                        outcome to an overfill prevention system that is automatic and
                                                                                                        physically and electrically separate from the tank gauging
                                                                                                        system?
                                                                                                        Where [R.345.2] has not been met (as categorised in
                                                         77             PSLG              R.345.4       paragraph 75), have appropriate measures as defined by                               0              0              0              0              0
                                                                                                        paragraph 77 been adopted?
                                                         78             PSLG                            Refer to Appendix 4 Gap Analysis




Process Safety Leadership Group
Final Report Gap Analysis                                                                                                                                    Part 2 Gap Analysis                                                                                                                                              Revision 0.2
                                                                                                                                                                                     Page 18 of 64




                                            Tank overfill prevention: Defining tank capacity
                                                79          BSTG                    Noted
                                                                                    Is there a clear definition of the maximum capacity of the
                                                                                    vessel? This is the maximum level consistent with avoiding
                                                                                    loss of containment (overfilling or overflow) or damage to the
                                                80          BSTG          R.345.5                                                                                0   0   0   0   0
                                                                                    tank structure (eg due to collision between an internal floating
                                                                                    roof and other structures within the tank, or for some fluids,
                                                                                    overstressing due to hydrostatic loading)
                                                                                    Has the level below maximum capacity been specified such
                                                                                    that it will allow time for any action necessary to prevent the
                                                                                    maximum from being reached/exceeded? This is termed the
                                                81          BSTG          R.345.6   „tank rated capacity‟, which will be lower than the actual                   0   0   0   0   0
                                                                                    physical maximum. Reference should be made to Appendix
                                                                                    3, „Guidance on defining tank capacity‟ for a definition of these
                                                                                    terms
                                                                                    Has the required separation between the maximum capacity
                                                                                    and the tank rated capacity taken account of the time needed
                                                                                    to detect and respond to an unintended increase in level
                                                82          BSTG          R.345.7   beyond the tank rated capacity? The response in this case                    0   0   0   0   0
                                                                                    may require the use of alternative controls, eg manual valves,
                                                                                    which are less accessible or otherwise require longer time to
                                                                                    operate than the normal method of isolation
                                                                                    In some cases, it will be necessary to terminate the transfer in
                                                                                    a more gradual fashion, eg by limiting the closure rate of the
                                                                                    isolation valve, to avoid damaging pressure surges in
                                                                                    upstream pipelines. Has due allowance been made for the
                                                83          BSTG          R.345.8   delay in stopping the transfer when establishing the tank rated              0   0   0   0   0
                                                                                    capacity? For some fluids, the tank rated capacity may also
                                                                                    serve to provide an allowance for thermal expansion of the
                                                                                    fluid, which may raise the level after the initial filling operation
                                                                                    has been completed
                                                                                    Is there a high-high level device (LAHH) which provides an
                                                                                    independent means of determining the level in the tank, that is
                                                                                    part of an overfill protection system? This should provide a
                                                84          BSTG          R.345.9                                                                                0   0   0   0   0
                                                                                    warning that the tank rated capacity has been (or is about to
                                                                                    be) reached/exceeded and triggers a response (Refer to the
                                                                                    full text of paragraph 84 for definition).
                                                                                    Is there a high level alarm (LAH) providing the means of
                                                                                    warning that the intended level has been exceeded, reducing
                                                                                    the demand on the high-high level device? It is anticipated
                                                85          BSTG         R.345.10                                                                                0   0   0   0   0
                                                                                    that the LAH will be derived from the system used for
                                                                                    determining the contents of the tank ATG (Refer to the full text
                                                                                    of paragraph 85 for definition).
                                                                                    Has the Normal Fill Level been defined - the level to which the
                                                                                    tank will intentionally be filled on a routine basis, using the
                                                                                    normal process control system? The normal fill level will be
                                                86          BSTG         R.345.11                                                                                0   0   0   0   0
                                                                                    dependent on the preceding levels and should be sufficiently
                                                                                    far below the LAH to avoid spurious activation, eg due to level
                                                                                    surges during filling or thermal expansion of the contents

                                                                                    In other applications, the primary means of determining the
                                                                                    level may not involve an ATG. In these instances, have
                                                87          BSTG         R.345.12   alternative measures for determining level been adopted? For                 0   0   0   0   0
                                                                                    example, depending on the detailed circumstances, the LAH
                                                                                    may be a separate device, eg a switch
                                                                                    Where an ATG system includes the facility for the operator to
                                                                                    set system prompts to notify them when a particular level has
                                                                                    been reached or exceeded, typically the same level instrument
                                                88          BSTG         R.345.13                                                                                0   0   0   0   0
                                                                                    drives these prompts and the LAH. Have operator prompts
                 2                3, 4, 5                                           been excluded when determining the overall integrity of the
                                                                                    system?
                                                                                    Having defined generically the minimum set of action levels,
                                                                                    has consideration been given to the factors that determine the
                                                                                    spacing between action levels in particular cases? In all cases,
                                                89          BSTG         R.345.14                                                                                0   0   0   0   0
                                                                                    the spacing should be directly related to the response time
                                                                                    required to detect, diagnose and act to stop an unintentional
                                                                                    and potentially hazardous increase in level.

                                                                                    Care is needed when estimating the likely time for operators to
                                                                                    respond to an incident. Has consideration been given to the
                                                90          BSTG         R.345.15                                                                                0   0   0   0   0
                                                                                    detection, diagnosis, and action stages of response? (Refer to
                                                                                    the full text of paragraphs 91-93 for a definition of these terms)




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                                      91          BSTG                   Refer to R.345.15
                                      92          BSTG                   Refer to R.345.15
                                      93          BSTG                   Refer to R.345.15
                                                                         A „walk-through‟ of the physical aspects of the task with
                                                                         operators can provide useful information on the minimum time
                                                                         needed to detect and respond to an overfilling incident.
                                      94          BSTG        R.345.16   However, due allowance needs to be made for additional                     0   0   0   0   0
                                                                         delays due to uncertainty, hesitation or communications
                                                                         problems. has this been added to the minimum time to
                                                                         produce a realistic estimate of the time to respond?
                                      95          BSTG                   Noted
                                                                         Response time 3: LAHH to overfill/damage level
                                                                         (maximum capacity): This is the response time between the
                                                                         LAHH and the overfill level (or maximum capacity – at which
                                                                         loss of containment or damage results). When calculating
                                      96          BSTG        R.345.17                                                                              0   0   0   0   0
                                                                         response time 3, has it been assumed that the action taken to
                                                                         respond to the LAH has not been successful, eg the valve did
                                                                         not close or the wrong valve closed, and so corrective or
                                                                         alternative contingency action is now urgently required?

                                                                         Has the response time considered to do this been identified as
                                                                         the worst combination of filling rate and time taken to travel
                                      97          BSTG        R.345.18   from the control room to the tank and positively stop the flow?            0   0   0   0   0
                                                                         This may be an alternative valve and may need additional time
                                                                         to identify and close it if not regularly used

                                                                         This could be done per tank or, more conservatively,
                                      98          BSTG        R.345.19   standardised at the longest margin time for a group of or all              0   0   0   0   0
                                                                         tanks. In all cases, however, has this been recorded in writing?
                                                                         Response time 2: LAH to LAHH: Has the response time
                                                                         between the LAH and the independent LAHH again been
                                                                         defined based on the worst combination of filling rate and time
                                      99          BSTG        R.345.20                                                                              0   0   0   0   0
                                                                         taken to activate and close a remotely operated valve (ROV) if
                                                                         installed, or to get from the control room to the tank manual
                                                                         valve if not?
                                                                         This could be done per tank or, more conservatively,
                                      100         BSTG        R.345.21   standardised at the longest margin time for a group of or all              0   0   0   0   0
                                                                         tanks. In all cases, however, has this been recorded in writing?
                                                                         Response time 1: Normal fill level to LAH: Is the normal fill
                                                                         level close enough to the LAH to enable overfilling to be
                                                                         rapidly detected (and to maximise the usable capacity of the
                                      101         BSTG        R.345.22   tank), but set an adequate margin below the LAH to prevent                 0   0   0   0   0
                                                                         spurious operation of the alarm, eg due to liquid surge or
                                                                         thermal expansion at the end of an otherwise correctly
                                                                         conducted transfer?
                                      102         BSTG                   Noted
                                      103         BSTG                   Noted
                                  Fire-safe shut-off valves
                                                                         Each pipe connected to a tank is a potential source of a major
                                                                         leak. In the event of an emergency it is important to be able to
                                      104         BSTG        R.345.23   safely isolate the contents of the tank. Are isolation valves fire-        0   0   0   0   0
                                                                         safe, ie capable of maintaining a leak-proof seal under
                                                                         anticipated fire exposure?
                                                                         Are fire-safe shut-off valves fitted close to the tank on both
                                                                         inlet and outlet pipes? Do valves either conform to an
                                                                         appropriate standard (BS 6755-214 or BS EN ISO 1049715),
                                      105         BSTG        R.345.24   equivalent international standards or be of an intrinsically fire-         0   0   0   0   0
                                                                         safe design, ie have metal-to-metal seats (secondary metal
                                                                         seats on soft-seated valves are acceptable), and not
                                                                         constructed of cast iron and not be wafer bolted?
                                      106         BSTG                   Refer to R.345.25
                                                                         Has 'Remotely operated shut-off valves (ROSOVs) for
                                                                         emergency isolation of hazardous substances: Guidance on
                                                                         good practice', HSG24416, been used to asses the need to
                                                                         provide ROSOVs for emergency isolation. It has been written
                                      107         BSTG        R.345.25                                                                              0   0   0   0   0
                                                                         for a wide range of circumstances and as a result the section
                                                                         dealing with ROSOV failure modes requires additional
                                                                         interpretation (Refer to the full text of paragraphs 108-114
                                                                         when determining if this requirement has been met)




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                                  108   BSTG                              Refer to R.345.25
                                  109   BSTG                              Refer to R.345.25
                                  110   BSTG                              Refer to R.345.25
                                  111   BSTG                              Refer to R.345.25
                                  112   BSTG                              Refer to R.345.25
                                  113   BSTG                              Refer to R.345.25
                                  114   BSTG                              Refer to R.345.25




                                                                                                         PSLG Part 2, Recommendations 3, 4 and 5
                                                                                                                      Implementation
                                               100%

                                               80%

                                               60%
                                                                                                                                                                                                                                                                                                                                Not Implemented
                                               40%
                                                                                                                                                                                                                                                                                                                                Partially Implemented
                                               20%
                                                                                                                                                                                                                                                                                                                                Implemented
                                                0%




                                                      R.345.1
                                                                R.345.2
                                                                          R.345.3
                                                                                    R.345.4
                                                                                              R.345.5
                                                                                                        R.345.6
                                                                                                                  R.345.7
                                                                                                                            R.345.8
                                                                                                                                      R.345.9
                                                                                                                                                R.345.10
                                                                                                                                                           R.345.11
                                                                                                                                                                      R.345.12
                                                                                                                                                                                 R.345.13
                                                                                                                                                                                            R.345.14
                                                                                                                                                                                                       R.345.15
                                                                                                                                                                                                                  R.345.16
                                                                                                                                                                                                                             R.345.17
                                                                                                                                                                                                                                        R.345.18
                                                                                                                                                                                                                                                   R.345.19
                                                                                                                                                                                                                                                              R.345.20
                                                                                                                                                                                                                                                                         R.345.21
                                                                                                                                                                                                                                                                                    R.345.22
                                                                                                                                                                                                                                                                                               R.345.23
                                                                                                                                                                                                                                                                                                          R.345.24
                                                                                                                                                                                                                                                                                                                     R.345.25




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Recommendations 6 and 7

           MIIB Design and Operations Report Recommendation 6:
           The sector should put in place arrangements to ensure the receiving site (as opposed to the transmitting location) has ultimate control of tank filling. The receiving site should be able to safely terminate or divert a transfer (to prevent loss of containment or other dangerous conditions) without depending on the
           actions of a remote third party, or on the availability of communications to a remote location. These arrangements will need to consider upstream implications for the pipeline network, other facilities on the system and refineries

           MIIB Design and Operations Report Recommendation 7:
           In conjunction with Recommendation 6, the sector and the Competent Authority should undertake a review of the adequacy of existing safety arrangements, including communications, employed by those responsible for pipeline transfers of fuel. This work should be aligned with implementing Recommendations
           19 and 20 on high reliability organisations to ensure major hazard risk controls address the management of critical organisational interfaces


           Table guidance:
                   (a) No Gap Analysis is necessary against paragraph 115 of the main report, instead refer to the Gap Analysis performed against Appendix 5

                                                                                                                                                                                                                Level of Implementation
                                                                                                                                                                                                                    C%
                                MIIB D&O                           PSLG or BSTG         Requirement                                                                                                                 o Fully Meets
                                                                                                                                                                                                                     C                 Meets
              Section                                Paragraph                                           Requirement                                                           Priority       Not         Partially                                                         Reference                              Comments
                             Recommendation                         Reference[1]          Number                                                                                          Implemented   Implemented mRequirements
                                                                                                                                                                                                                     o               Requirement   Not Applicable
                                                                                                                                                                                                                    pm                 SFAIRP
                                                                                                                                                                                                                    lp
                 2                   6,7                 115             BSTG                            Refer to Appendix 5 Gap Analysis



Recommendation 8

           MIIB Design and Operations Report Recommendation 8:
           The sector, including its supply chain of equipment manufacturers and suppliers, should review and report without delay on the scope to develop improved components and systems, including but not limited to the following:
                       (a) Alternative means of ultimate high level detection for overfill prevention that do not rely on components internal to the storage tank, with the emphasis on ease of inspection, testing, reliability and maintenance
                       (b) Increased dependability of tank level gauging systems through improved validation of measurements and trends, allowing warning of faults and through using modern sensors with increased diagnostic capability
                       (c) Systems to control and log override actions


           Table guidance:
                   (a) For this table, level of implementation is gauged on compliance for each individual tank
                      (b) Enter the tank quantity in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable
                      (c) The total in-scope tanks can be found on the Part 1 Gap Analysis worksheet

                                                                                                                                                                                                                Level of Implementation
                                                                                                                                                                                                                    C%
                                MIIB D&O                           PSLG or BSTG         Requirement                                                                                                                 oC                 Meets
              Section                                Paragraph                                           Requirement                                                           Priority       Not         Partially m Fully Meets
                                                                                                                                                                                                                     o                                                      Reference                              Comments
                             Recommendation                         Reference[1]          Number                                                                                                                                     Requirement   Not Applicable
                                                                                                                                                                                          Implemented   Implemented p Requirements
                                                                                                                                                                                                                     m                 SFAIRP
                                                                                                                                                                                                                    lp
                                                                                                                                                                                                                    il
                                                    Improved level instrumentation components and systems
                                                                                                         When selecting components and systems for level
                                                                                                         measurement or overfill protection systems do designers
                                                                                                         ensure adequate testability and maintainability to support the
                                                                                                         required reliability and take account of the safety benefits
                                                                                                         available in modern components and systems, such as
                                                         116             PSLG                R.8.1       diagnostics? Have Designers also taken into account the                              0             0              0              0              0
                                                                                                         potential advantages of the use of non-invasive systems
                                                                                                         compared with systems using components inside the tank?
                                                                                                         Data retrieval and display systems with software features
                                                                                                         which assist operator monitoring during tank filling should be
                                                                                                         considered
                                                         117             PSLG                            Noted

                                                                                                         There are currently no standards for use of gas detectors for
                                                                                                         fuel storage installations and no fuel storage installations within
                                                                                                         the UK where gas detectors are installed. Gas detectors are
                                                                                                         available but the dispersion of gasoline vapour is complicated
                                                                                                         and hence effective detection by gas detectors is subject to
                                                                                                         many uncertainties. Open path detection devices are available
                  2                   8
                                                                                                         and could provide boundary detection at bund walls or around
                                                                                                         tanks. Liquid hydrocarbon detectors, however, may offer
                                                                                                         effective detection because it is easier to predict where
                                                         118             PSLG                R.8.2                                                                                            0             0              0              0              0
                                                                                                         escaping liquid will collect and travel. There are a number of
                                                                                                         installations where liquid hydrocarbon detectors are installed.
                                                                                                         Typical locations would be in a bund drain, gutter or sump
                                                                                                         where sensors can detect oil on water using conductivity
                                                                                                         measurement. The detection system may be subject to
                                                                                                         failures or spurious trips resulting from water collecting in the
                                                                                                         bund or sump. Has the installation of liquid hydrocarbon
                                                                                                         sensors at suitable locations connected to alarms in the control
                                                                                                         room been considered?




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                                                                        Has the installation of the correct resolution CCTV with
                                                                        appropriate lighting of tanks and bunds that may assist
                                  119   PSLG            R.8.3           operators in detecting tank overflows, been considered?                    0            0          0            0            0
                                                                        Has the action to take on detection of an overflow been clearly
                                                                        documented, typically as part of an emergency plan?
                                  120   PSLG                            Refer to Appendix 4 Gap Analysis
                                  121   PSLG                            Refer to Appendix 4 Gap Analysis

                                          [Notes]
                                                1 Note that where a BSTG reference is provided, this requirement should have been assessed and completed under the timeframes defined in the BSTG report




                                                                                     PSLG Part 2, Recommendation 8
                                                                                            Implementation
                                                    100%

                                                     80%

                                                     60%
                                                                                                                                                Not Implemented
                                                     40%                                                                                        Partially Implemented
                                                     20%                                                                                        Implemented
                                                      0%




                                                            R.8.1

                                                                    R.8.2

                                                                            R.8.3




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Recommendation 9

           MIIB Design and Operations Report Recommendation 9:
           Operators of Buncefield-type sites should introduce arrangements for the systematic maintenance of records to allow a review of all product movements together with the operation of the overfill prevention systems and any associated facilities. The arrangements should be fit for their design purpose and
           include, but not be limited to, the following factors:
                       (a) The records should be in a form that is readily accessible by third parties without the need for specialist assistance
                       (b) The records should be available both on site and at a different location
                       (c) The records should be available to allow periodic review of the effectiveness of control measures by the operator and the Competent Authority, as well as for root cause analysis should there be an incident
                       (d) A minimum period of retention of one year


           Table guidance:
                   (a) For this table, level of implementation is gauged on compliance for each individual tank
                      (b) Enter the tank quantity in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable
                      (c) The total in-scope tanks can be found on the Part 1 Gap Analysis worksheet

                                                                                                                                                                                                               Level of Implementation
                                                                                                                                                                                                                  C%
                               MIIB D&O                           PSLG or BSTG        Requirement                                                                                                                 oC                  Meets
              Section                               Paragraph                                              Requirement                                                       Priority       Not         Partially     Fully Meets                                     Reference                              Comments
                            Recommendation                         Reference[1]         Number                                                                                          Implemented   Implemented
                                                                                                                                                                                                                  mo
                                                                                                                                                                                                                     Requirements
                                                                                                                                                                                                                                    Requirement   Not Applicable
                                                                                                                                                                                                                  pm                  SFAIRP
                                                                                                                                                                                                                  lp
                                                   Improved level instrumentation components and systems
                                                                                                           Have you identified those records needed for the periodic
                                                                                                           review of the effectiveness of control measures, and for the
                 2                   9                                                                     root cause analysis of those incidents and near misses that
                                                        122             PSLG               R.9.1                                                                                            0              0              0              0              0
                                                                                                           could potentially have developed into a major incident? Are the
                                                                                                           records retained for a minimum period of one year? Refer to
                                                                                                           „Availability of records for periodic review‟ in Appendix 5
                                                        123             PSLG                               Refer to requirements R.2.1 to R.2.18

                                                                           [Notes]
                                                                                 1 Note that where a BSTG reference is provided, this requirement should have been assessed and completed under the timeframes defined in the BSTG report




                                                                                                                        PSLG Part 2, Recommendation 9
                                                                                                                               Implementation
                                                                                      100%

                                                                                        80%

                                                                                        60%
                                                                                                                                                                                         Not Implemented
                                                                                        40%
                                                                                                                                                                                         Partially Implemented
                                                                                        20%                                                                                              Implemented
                                                                                         0%
                                                                                                   R.9.1




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Recommendation 10

           MIIB Design and Operations Report Recommendation 10:
           The sector should agree with the Competent Authority on a system of leading and lagging performance indicators for process safety performance. This system should be in line with HSE’s recently published guidance on Developing process safety indicators HSG254

           Table guidance:
                   (a) No Gap Analysis is necessary against paragraphs 124-125 of the main report, instead refer to the Gap Analysis performed against Appendix 5

                                                                                                                                                                                                    Level of Implementation
                                                                                                                                                                                                         C%
                               MIIB D&O                         PSLG or BSTG        Requirement                                                                                                          oC                  Meets
              Section                              Paragraph                                        Requirement                                                     Priority       Not         Partially                                                      Reference         Comments
                            Recommendation                       Reference[1]         Number                                                                                                             m Fully Meets
                                                                                                                                                                                                          o                Requirement   Not Applicable
                                                                                                                                                                               Implemented   Implemented    Requirements
                                                                                                                                                                                                         pm                  SFAIRP
                                                                                                                                                                                                         lp
                                                                                                                                                                                                         il
                                                       124            BSTG                          Refer to Appendix 5 Gap Analysis
                 2                  10
                                                      125             BSTG                          Refer to Appendix 5 Gap Analysis




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Part 3 - Engineering against escalation of loss of primary containment
Recommendation 11

           MIIB Design and Operations Report Recommendation 11:

           Operators of Buncefield-type sites should review the classification of places within COMAH sites where explosive atmospheres may occur and their selection of equipment and protective systems (as required by the Dangerous Substances and Explosive Atmospheres Regulations 2002). This review should
           take into account the likelihood of undetected loss of containment and the possible extent of an explosive atmosphere following such an undetected loss of containment. Operators in the wider fuel and chemicals industries should also consider such a review, to take account of events at Buncefield



           Table guidance:
                   (a) For this table, level of implementation is gauged on compliance for each individual tank
                   (b) Enter the tank quantity in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable
                   (c) The total in-scope tanks can be found on the Part 1 Gap Analysis worksheet

                                                                                                                                                                                                              Level of Implementation
                                                                                                                                                                                                                  C%
                               MIIB D&O                         PSLG or BSTG        Requirement                                                                                                                                     Meets
              Section                              Paragraph                                             Requirement                                                         Priority       Not         Partially o Fully Meets
                                                                                                                                                                                                                   C                                             Reference                         Comments
                            Recommendation                       Reference[1]         Number                                                                                                                                      Requirement   Not Applicable
                                                                                                                                                                                        Implemented                o
                                                                                                                                                                                                      Implemented mRequirements
                                                                                                                                                                                                                  pm                SFAIRP
                                                                                                                                                                                                                  lp
                                                      126            PSLG                                Noted

                                                                                                         Are reviews of DSEAR (Dangerous Substances and Explosive
                                                                                                         Atmospheres Regulations) risk assessment performed on a
                                                                                                         regular basis (eg using the guidance in Area classification for
                                                                                                         installations handling flammable fluids (EI 15)? In addition, are
                                                                                                         reviews undertaken if there is reason to believe that the risk
                                                                                                         assessment is no longer valid or if there has been a significant
                                                                                                         change? Hazard and risk analysis may be required to
                                                                                                         ascertain appropriate risk reduction measures through
                                                                                                         additional layers of protection, as described in the guidance
                                                                                                         provided for Recommendation 1. DSEAR risk assessments
                 3                  11                                                                   should reflect the findings of the LOPA assessments (see
                                                      127             PSLG             R.11.1                                                                                               0             0             0              0              0
                                                                                                         Appendix 2). The need for a suitable and sufficient risk
                                                                                                         assessment is an ongoing duty and, as further understanding
                                                                                                         of the mechanisms of the incident becomes available and if
                                                                                                         additional specific guidance is produced, there may be a need
                                                                                                         for further reviews. DSEAR risk assessments and the
                                                                                                         measures to control identified risks should, in addition to any
                                                                                                         sector or industry-specific guidance, take account of the
                                                                                                         general guidance contained by the HSE Approved Code of
                                                                                                         Practice (ACOP) L13819 and where relevant the additional
                                                                                                         activity related DSEAR ACOPs (Refer to the full text of
                                                                                                         paragraph 127 for a list of the appropriate ACOPs)




                                                                                                                     PSLG Part 3, Recommendation 11
                                                                                                                             Implementation
                                                                                    100%

                                                                                     80%

                                                                                     60%
                                                                                                                                                                                         Not Implemented
                                                                                     40%
                                                                                                                                                                                         Partially Implemented
                                                                                     20%
                                                                                                                                                                                         Implemented
                                                                                      0%
                                                                                                R.11.1




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Recommendation 12

           MIIB Design and Operations Report Recommendation 12:
           Following on from Recommendation 11, operators of Buncefield-type sites should evaluate the siting and/or suitable protection of emergency response facilities such as firefighting pumps, lagoons or manual emergency switches

           Table guidance:
                   (a) No Gap Analysis is necessary against paragraph 128 of the main report, instead refer to the Gap Analysis performed against Appendix 6

                                                                                                                                                                                                           Level of Implementation
                                                                                                                                                                                                                C%
                                MIIB D&O                           PSLG or BSTG        Requirement                                                                                                              oC                 Meets
              Section                                Paragraph                                           Requirement                                                       Priority       Not         Partially m Fully Meets
                                                                                                                                                                                                                 o                                                        Reference                              Comments
                             Recommendation                         Reference[1]         Number                                                                                       Implemented   Implemented p Requirements
                                                                                                                                                                                                                                 Requirement   Not Applicable
                                                                                                                                                                                                                 m                 SFAIRP
                                                                                                                                                                                                                lp
                                                                                                                                                                                                                il
                 3                   12                 128             PSLG                             Refer to Appendix 6 Gap Analysis



Recommendation 13

           MIIB Design and Operations Report Recommendation 13:
           Operators of Buncefield-type sites should employ measures to detect hazardous conditions arising from loss of primary containment, including the presence of high levels of flammable vapours in secondary containment. Operators should without delay undertake an evaluation to identify suitable and
           appropriate measures. This evaluation should include, but not be limited to, consideration of the following:
                      (a) Installing flammable gas detection in bunds containing vessels or tanks into which large quantities of highly flammable liquids or vapour may be released
                      (b) The relationship between the gas detection system and the overfill prevention system. Detecting high levels of vapour in secondary containment is an early indication of loss of containment and so should initiate action, for example through the overfill prevention system, to limit the extent of any further loss
                       (c) Installing CCTV equipment to assist operators with early detection of abnormal conditions. Operators cannot routinely monitor large numbers of passive screens, but equipment is available that detects and responds to changes in conditions and alerts operators to these changes

           Table guidance:
                   (a) No Gap Analysis is necessary against paragraph 129 of the main report, instead refer to requirements R.8.1 to R.8.3

                                                                                                                                                                                                           Level of Implementation
                                                                                                                                                                                                                C%
                                MIIB D&O                           PSLG or BSTG        Requirement                                                                                                              oC                 Meets
              Section                                Paragraph                                           Requirement                                                       Priority       Not         Partially                                                           Reference                              Comments
                             Recommendation                         Reference[1]         Number                                                                                                                 m Fully Meets
                                                                                                                                                                                                                 o               Requirement   Not Applicable
                                                                                                                                                                                      Implemented   Implemented p Requirements
                                                                                                                                                                                                                 m                 SFAIRP
                                                                                                                                                                                                                lp
                                                                                                                                                                                                                il
                 3                   13                 129             PSLG                             Refer to requirements R.8.1 to R.8.3




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Recommendation 14

           MIIB Design and Operations Report Recommendation 14:
           Operators of new Buncefield-type sites or those making major modifications to existing sites (such as installing a new storage tank) should introduce further measures including, but not limited to, preventing the formation of flammable vapour in the event of tank overflow. Consideration should be given to
           modifications of tank top design and to the safe re-routing of overflowing liquids


           Table guidance:
                   (a) For this table, level of implementation is gauged on compliance for each individual tank
                   (b) Enter the tank quantity in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable
                   (c) The total in-scope tanks can be found on the Part 1 Gap Analysis worksheet

                                                                                                                                                                                                                     Level of Implementation
                                MIIB D&O                           PSLG or BSTG        Requirement                                                                                                                       %
                                                                                                                                                                                                                         C
              Section                                Paragraph                                                    Requirement                                                       Priority                                               Meets                        Reference                              Comments
                                                                                                                                                                                                   Not         Partially o Fully Meets
                                                                                                                                                                                                                         C
                             Recommendation                         Reference[1]         Number                                                                                                                                          Requirement   Not Applicable
                                                                                                                                                                                               Implemented   Implemented mRequirements
                                                                                                                                                                                                                         o
                                                                                                                                                                                                                                           SFAIRP
                                                                                                                                                                                                                         m
                                                                                                                                                                                                                         p
                                                                                                                  It cannot be shown, without further research, whether
                                                                                                                  significant modifications to tank top design would have the
                                                                                                                  desired mitigating effect in practice. Where new research or
                                                        130             PSLG               R.14.1                                                                                                  0             0             0              0              0
                                                                                                                  revised design codes indicate that modification of tank tops
                                                                                                                  may reduce the formation of vapour clouds, have these been
                                                                                                                  adopted?
                                                                                                                  Have new tanks[3] been designed to BS EN 14015 or API 650
                                                                                                                  (or equivalent)? These offer up-to-date standards providing in-
                                                        131             PSLG               R.14.2                                                                                                  0             0             0              0              0
                                                                                                                  depth guidance on design and construction elements for
                                                                                                                  vertical cylindrical atmospheric storage tanks
                                                                                                                  Are new tanks[3] of single-bottom design? This can be
                                                                                                                  supported by suitable inspection arrangements providing the
                                                        132             PSLG               R.14.3                 optimum configuration for ensuring continuing integrity. This                    0             0             0              0              0
                                                                                                                  will facilitate full non-destructive examination of floor-plate
                                                                                                                  welds
                                                                                                                  BS EN 14015 offers an alternative double bottom
                                                                                                                  configuration. Where such designs have been used, are robust
                                                                                                                  integrity management arrangements in place, in line with
                 3                   14                                                                           guidance set out in EEMUA 159 and 183? Such a
                                                        133             PSLG               R.14.4                 configuration, although not preferred, would also be                             0             0             0              0              0
                                                                                                                  acceptable. EEMUA 183 sets out the technical disadvantages
                                                                                                                  of this option. Arrangements for inspection and maintenance
                                                                                                                  should be carefully considered for such configurations to
                                                                                                                  secure containment integrity
                                                                                                                  Has consideration been given to the overflow route from vent
                                                        134             PSLG               R.14.5                 to bund to ensure that, within the constraints of the design                     0             0             0              0              0
                                                                                                                  code, obstacles in the overflow route are minimised?

                                                                                                                  Are tanks either of „frangible roof‟ construction, or equipped
                                                                                                                  with an emergency vent of adequate area to prevent over-
                                                                                                                  pressure under accidental relief conditions, which exclude
                                                                                                                  internal explosions? For further information reference should
                                                        135             PSLG               R.14.6                                                                                                  0             0             0              0              0
                                                                                                                  be made to EEMUA 180 Frangible roof joints for fixed roof
                                                                                                                  storage tanks: Guide for designers and users.26 Emergency
                                                                                                                  vents should comply with an appropriate design standard (API
                                                                                                                  200027 or equivalent)




                                                                                                                                      PSLG Part 3, Recommendation 14
                                                                                                                                              Implementation
                                                                                       100%

                                                                                        80%

                                                                                        60%
                                                                                                                                                                                                Not Implemented
                                                                                        40%
                                                                                                                                                                                                Partially Implemented
                                                                                        20%
                                                                                                                                                                                                Implemented
                                                                                         0%
                                                                                                R.14.1

                                                                                                         R.14.2

                                                                                                                    R.14.3

                                                                                                                             R.14.4

                                                                                                                                      R.14.5

                                                                                                                                               R.14.6




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Recommendation 15

           MIIB Design and Operations Report Recommendation 15:
           The sector should begin to develop guidance without delay to incorporate the latest knowledge on preventing loss of primary containment and on inhibiting escalation if loss occurs. This is likely to require the sector to collaborate with the professional institutions and trade associations


           Table guidance:
                   (a) For this table, level of implementation is gauged on compliance for each individual tank
                   (b) Enter the tank quantity in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable
                   (c) The total in-scope tanks can be found on the Part 1 Gap Analysis worksheet

                                                                                                                                                                                                             Level of Implementation
                                MIIB D&O                           PSLG or BSTG         Requirement                                                                                                              %
                                                                                                                                                                                                                 C                 Meets
              Section                                Paragraph                                           Requirement                                                        Priority       Not         Partially o Fully Meets
                                                                                                                                                                                                                 C                                                          Reference                           Comments
                             Recommendation                         Reference[1]          Number                                                                                       Implemented   Implemented mRequirements
                                                                                                                                                                                                                                 Requirement   Not Applicable
                                                                                                                                                                                                                 o                 SFAIRP
                                                                                                                                                                                                                 m
                                                                                                                                                                                                                 p
                                                                                                         EEMUA 159 and API 653 represent relevant good practice,
                                                                                                         have these been adopted to form the basis of minimum
                                                         136             PSLG               R.15.1                                                                                          0            0             0              0              0
                                                                                                         industry standards for tank integrity management and repair to
                                                                                                         prevent loss of primary containment?
                                                                                                         Have you also adopted EEMUA 183 Guide for the Prevention
                                                                                                         of Bottom Leakage, particularly with regard to the
                                                         137             PSLG               R.15.2                                                                                          0            0             0              0              0
                                                                                                         maintenance and repair aspects for tanks with a double
                                                                                                         bottom configuration?
                                                                                                         Have the factors highlighted in the HSE guidance 'Integrity of
                                                                                                         atmospheric storage tanks SPC/Tech/Gen/3529' been
                                                         138             PSLG               R.15.3       considered when operating storage tanks containing                                 0            0             0              0              0
                                                                                                         hazardous substances? this includes reference to EEMUA 159
                                                                                                         and API 653
                                                         139             PSLG                            Noted
                                                                                                         Has a written scheme of examination been prepared for
                                                                                                         internal/out-of-service inspections? EEMUA 159, Appendix B2
                                                         140             PSLG               R.15.4       provides an example of such a checklist (Refer to the full text                    0            0             0              0              0
                                                                                                         of paragraph 141-142 for technical guidance on tank
                                                                                                         inspections)
                                                         141             PSLG                            Refer to requirements R.15.4 and R.15.5
                                                         142             PSLG                            Refer to requirements R.15.4 and R.15.5

                                                                                                         Are the frequency of internal/out-of-service inspections
                                                                                                         reviewed routinely and in the light of new information?
                                                         143             PSLG               R.15.5       Inspections may become more frequent if active degradation                         0            0             0              0              0
                                                                                                         mechanisms are found (Refer to the full text of paragraph 141-
                                                                                                         142 for technical guidance on tank inspections)
                                                                                                         Has particular attention been given to insulated storage tanks?
                                                                                                         Corrosion under insulation and external coating prior to
                                                                                                         insulation can have significant effects on tank integrity. For
                                                         144             PSLG               R.15.6       corrosive products protective coatings may be applied                              0            0             0              0              0
                                                                                                         internally. This may lengthen the inspection interval. To ensure
                                                                                                         quality control, particular attention should be paid during the
                                                                                                         application of coatings
                                                                                                         Are thorough internal inspections only carried out by removing
                                                                                                         the tank from service and cleaning? As a minimum, a full-floor
                                                                                                         scan along with internal examination of the shell to
                                                         145             PSLG               R.15.7                                                                                          0            0             0              0              0
                                                                                                         annular/floor weld, annular plate and shell nozzles using non-
                                                                                                         destructive testing and visual inspection in line with good
                                                                                                         practice
                                                                                                         For floating roof tanks is there a system in place to manage
                                                                                                         water drains appropriately to ensure precautions have been
                                                                                                         taken to prevent loss of containment incidents? HSE
                                                         146             PSLG               R.15.8                                                                                          0            0             0              0              0
                                                                                                         document Drainage of floating roof tanks
                                                                                                         SPC/Enforcement/16332 provides additional guidance on this
                                                                                                         topic
                                                                                                         Is there a written scheme of examination for external/in-service
                                                         147             PSLG               R.15.9       inspections? EEMUA 159 provides an example of such a                               0            0             0              0              0
                                                                                                         checklist
                                                                                                         Are thorough internal inspections supplemented by external/in-
                                                                                                         service inspections? These inspections must be completed
                                                                                                         periodically, as this forms a part of obtaining the overall tank
                                                                                                         history and assessing fitness for future service. In-service
                                                                                                         inspection frequency may be determined through RBI
                                                         148             PSLG              R.15.10                                                                                          0            0             0              0              0
                                                                                                         assessment or may be based on fixed intervals (see EEMUA
                                                                                                         159) based on the type of product stored. Frequency of in-
                                                                                                         service inspections should be subject to review and may
                                                                                                         become more frequent if active degradation mechanisms are
                 3                   15                                                                  found




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                 3                15
                                                              Full guidance for routine operational checks is provided in
                                                              EEMUA 159 and API 653. These documents also provide
                                                              guidance on internal and external mechanical inspections to be
                                       149   PSLG   R.15.11   undertaken by a trained and competent tank inspector. Are                   0   0   0   0   0
                                                              inspections and routine checks documented? Does the
                                                              evaluation include fixed roof venting, floating roof drainage and
                                                              general operation?
                                                              Is deferral of the required inspection date risk assessed by a
                                                              competent person? Where necessary, deferral decisions
                                                              should be supported by targeted non-destructive testing. This
                                       150   PSLG   R.15.12   additional testing can be carried out to the shell, roof and in             0   0   0   0   0
                                                              many cases annular plate. Deferral decisions must also
                                                              consider previous inspection history and other relevant
                                                              information including changes in operating conditions, etc

                                                              Is particular attention given to tanks that have had no previous
                                                              internal examination? The probability of floor failure will
                                                              increase with every year that the recommended interval is
                                       151   PSLG   R.15.13                                                                               0   0   0   0   0
                                                              exceeded. In such cases it is unlikely that a deferral could be
                                                              justified. It is the dutyholder‟s responsibility to ensure that the
                                                              risk of loss of containment is properly managed

                                                              When assessing storage tanks, are competent personnel who
                                                              are aware of and able to apply relevant tank design codes
                                                              where necessary used? Competent personnel may be directly
                                       152   PSLG   R.15.14   employed or accessed on a contractual basis by the user.                    0   0   0   0   0
                                                              Tank assessors should be qualified to EEMUA 159 Tank
                                                              Integrity Assessor level 1 (minimum) or equivalent. The API
                                                              653 Tank Inspector qualification is also acceptable

                                       153   PSLG             Noted
                                                              Are regular online operational checks undertaken by suitably
                                       154   PSLG   R.15.15   trained personnel with the competencies required to carry out               0   0   0   0   0
                                                              such checks properly?
                                                              Tank repair is a specialised activity, is this performed only by
                                                              those competent in tank design, reconstruction and repair
                                                              works? Non-destructive testing should be carried out by
                                       155   PSLG   R.15.16                                                                               0   0   0   0   0
                                                              personnel qualified to TWI‟s Certification Scheme for Welding
                                                              and Inspection Personnel or Personnel Certificate of Non-
                                                              Destructive Testing, or equivalent
                                                              Repair options are detailed in API 653. For floor plate repairs,
                                                              if local overplating or plate replacement is not deemed
                                       156   PSLG   R.15.17                                                                               0   0   0   0   0
                                                              appropriate, are the original floor plates removed and a new
                                                              floor installed?
                                       157   PSLG             Refer to requirement R.15.18

                                                              For double bottom designs, has BS EN 14015 been adopted
                                                              such that a loss of vacuum in a double bottom tank should
                                                              alarm to alert the operator that either the upper or lower floor
                                       158   PSLG   R.15.18   has failed (effectively reverting to a single layer of protection)?         0   0   0   0   0
                                                              Is remedial action carried out within one year? Is continued
                                                              operation in the interim period pending repair supported by a
                                                              technical justification confirming ongoing fitness for service?

                                                              Having completed a tank inspection, repair and any additional
                                                              testing, has a new risk- or time-based inspection frequency
                                       159   PSLG   R.15.19   been determined, taking into account all relevant factors                   0   0   0   0   0
                                                              including the condition of the tank, future service requirements,
                                                              potential degradation mechanisms and failure consequences?




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                                                                                                                                         PSLG Part 3, Recommendation 15
                                                                                                                                                 Implementation
                                                                                    100%

                                                                                     80%

                                                                                     60%
                                                                                                                                                                                                                                                                        Not Implemented
                                                                                     40%
                                                                                                                                                                                                                                                                        Partially Implemented
                                                                                     20%
                                                                                                                                                                                                                                                                        Implemented
                                                                                       0%




                                                                                            R.15.1
                                                                                                     R.15.2
                                                                                                              R.15.3
                                                                                                                       R.15.4
                                                                                                                                R.15.5
                                                                                                                                         R.15.6
                                                                                                                                                  R.15.7
                                                                                                                                                           R.15.8
                                                                                                                                                                    R.15.9
                                                                                                                                                                             R.15.…
                                                                                                                                                                                      R.15.…
                                                                                                                                                                                               R.15.…
                                                                                                                                                                                                        R.15.…
                                                                                                                                                                                                                 R.15.…
                                                                                                                                                                                                                          R.15.…
                                                                                                                                                                                                                                   R.15.…
                                                                                                                                                                                                                                            R.15.…
                                                                                                                                                                                                                                                     R.15.…
                                                                                                                                                                                                                                                              R.15.…
Recommendation 16

           MIIB Design and Operations Report Recommendation 16:
           Operators of existing sites, if their risk assessments show it is not practicable to introduce measures to the same extent as for new ones, should introduce measures as close to those recommended by Recommendation 14 as is reasonably practicable. The outcomes of the assessment should be incorporated
           into the safety report submitted to the Competent Authority


           Table guidance:
                   (a) For this table, level of implementation is gauged on compliance for each individual tank
                   (b) Enter the tank quantity in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable
                   (c) The total in-scope tanks can be found on the Part 1 Gap Analysis worksheet

                                                                                                                                                                                                                                                                                             Level of Implementation
                               MIIB D&O                          PSLG or BSTG       Requirement                                                                                                                                                                                                  %
                                                                                                                                                                                                                                                                                                 C                 Meets
              Section                              Paragraph                                                  Requirement                                                                                                                            Priority              Not         Partially o Fully Meets
                                                                                                                                                                                                                                                                                                 C
                                                                                                                                                                                                                                                                                                                                                Reference   Comments
                            Recommendation                        Reference[1]        Number                                                                                                                                                                           Implemented   Implemented mRequirements
                                                                                                                                                                                                                                                                                                                 Requirement   Not Applicable
                                                                                                                                                                                                                                                                                                 o                 SFAIRP
                                                                                                                                                                                                                                                                                                 m
                                                                                                                                                                                                                                                                                                 p
                                                                                                              Ensuring risks are ALARP is a continuous improvement
                                                                                                              process. Good practice therefore requires a periodic
                                                                                                              assessment of existing tanks against current standards. As a
                                                                                                              minimum, do existing tanks comply with a relevant recognised
                                                       160            PSLG              R.16.1                design code at their date of manufacture? Where this is not                                                                                                  0             0             0              0              0
                                                                                                              the case, are tanks assessed against an appropriate current
                                                                                                              standard, BS EN 14015 or API 650? Remedial action should
                                                                                                              then be taken, as necessary, informed by the resulting gap
                                                                                                              analysis, to reduce risks ALARP
                                                                                                              Where major modifications or repairs are undertaken on
                                                       161            PSLG              R.16.2                existing tanks, do these comply with a suitable recognised                                                                                                   0             0             0              0              0
                 3                  16                                                                        standard, BS EN 14015 or EEMUA 159?
                                                       162            PSLG                                    Noted
                                                                                                              For tanks with a double bottom arrangement that do not
                                                                                                              comply with a recognised standard, are these assessed
                                                       163            PSLG              R.16.3                                                                                                                                                                             0             0             0              0              0
                                                                                                              against a recognised standard and any appropriate remedial
                                                                                                              action taken?
                                                                                                              Are tank top modifications considered where appropriate to
                                                       164            PSLG              R.16.4                eliminate any obstructions present in the overflow route from                                                                                                0             0             0              0              0
                                                                                                              vent to bund?
                                                                                                              Are emergency vents that do not comply with a suitable,
                                                       165            PSLG              R.16.5                recognised design standard at date of manufacture subject to                                                                                                 0             0             0              0              0
                                                                                                              a design gap analysis, and remedial action taken?




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                                                                      PSLG Part 3, Recommendation 16
                                                                              Implementation
                                  100%

                                  80%

                                  60%
                                                                                                                Not Implemented
                                  40%
                                                                                                                Partially Implemented
                                  20%
                                                                                                                Implemented
                                   0%




                                         R.16.1

                                                  R.16.2

                                                           R.16.3

                                                                    R.16.4

                                                                             R.16.5




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Part 4 - Engineering against loss of secondary and tertiary containment

                                   Bund Quantity:           0


Recommendations 17 and 18

           MIIB Design and Operations Report Recommendation 17:
           The Competent Authority and the sector should jointly review existing standards for secondary and tertiary containment with a view to the Competent Authority producing revised guidance by the end of 2007. The review should include, but not be limited to the following guidance by the
           end of 2007. The review should include, but not be limited to the following:
                      (a) Developing a minimum level of performance specification of secondary containment (typically this will be bunding)
                      (b)   Developing suitable means for assessing risk so as to prioritise the programme of engineering work in response to the new specification
                      (c)   Formally specifying standards to be achieved so that they may be insisted upon in the event of lack of progress with improvements
                      (d)   Improving firewater management and the installed capability to transfer contaminated liquids to a place where they present no environmental risk in the event of loss of secondary containment and fires
                      (e)   Providing greater assurance of tertiary containment measures to prevent escape of liquids from site and threatening a major accident to the environment

           MIIB Design and Operations Report Recommendation 18:
           Revised standards should be applied in full to new build sites and to new partial installations. On existing sites, it may not be practicable to fully upgrade bunding and site drainage. Where this is so operators should develop and agree with the Competent Authority risk based plans f
           or phased upgrading as close to new plant standards as is reasonably practicable


           Table guidance:
                   (a) For this table, level of implementation is gauged on compliance for each individual bund
                   (b) Enter the bund quantity in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable
                   (c) The total bund quantity can be found at the top of this Part 4 Gap Analysis worksheet
                       Part 4 of the PSLG report provides additional guidance in interpreting the COMAH Competent Authority Containment Policy, therefore operators should reference the gap analysis already performed as part of EA/SEPA
                   (d)
                       Containment Policy Scorecard as appropriate


                                                                                                                                                                                                                Level of Implementation
                                                                                                                                                                                                                    C%
                                 MIIB D&O                              PSLG or BSTG        Requirement                                                                                                                                Meets
              Section                                  Paragraph                                            Requirement                                                        Priority       Not         Partially o Fully Meets
                                                                                                                                                                                                                     C                                                       Reference                     Comments
                              Recommendation                            Reference[1]         Number                                                                                       Implemented   Implemented mRequirements
                                                                                                                                                                                                                     o              Requirement   Not Applicable
                                                                                                                                                                                                                    pm                SFAIRP
                                                                                                                                                                                                                    lp
                                                           166           PSLG/BSTG                          Noted
                                                           167           PSLG/BSTG                          Noted
                                                           168           PSLG/BSTG                          Noted
                                                           169           PSLG/BSTG                          Noted
                                                    Bund Lining Systems
                                                                                                            The COMAH Containment policy states that „Bunds shall be
                                                                                                            impermeable‟ and that „bunds shall have fire resistant
                                                                                                            structural integrity, joints and pipework penetrations‟. This
                                                           170           PSLG/BSTG           R.17.18.1                                                                                        0             0             0              0              0
                                                                                                            covers the preparation of the tank base and foundation plus
                                                                                                            the selection of lining systems; concrete, earth or polymeric or
                                                                                                            polymeric and mineral composites
                                                                                                            It is important that protection from fire is included in risk
                                                           171           PSLG/BSTG           R.17.18.2                                                                                        0             0             0              0              0
                                                                                                            assessment for selecting different types of lining systems
                                                           172           PSLG/BSTG                          Noted - Refer to Requirement R.17.18.2
                                                           173           PSLG/BSTG                          Noted
                                                                                                            The selection of any system is based on a combination of risk
                                                                                                            (to the environment and people), cost and practicality. Any
                                                           174           PSLG/BSTG           R.17.18.3      consideration of improvements to lining systems for existing                      0             0             0              0              0
                                                                                                            establishments where the risk is tolerable should be subject to
                                                                                                            an ALARP assessment
                                                           175           PSLG/BSTG                          Noted
                                                    Fire resistance and integrity of pipe penetrations and expansion joints
                                                                                                            The COMAH Containment policy states that: „Bunds shall have
                                                           176           PSLG/BSTG           R.17.18.4      fire resistant structural integrity, joints and pipework                          0             0             0              0              0
                                                                                                            penetrations.‟
                                                                                                            Improvements should be made to the fire resistance of bund
                                                                                                            joints and penetrations where the existing arrangement has
                                                                                                            inadequate fire resistance. Options for enhancing fire
                                                           177           PSLG/BSTG           R.17.18.5                                                                                        0             0             0              0              0
                                                                                                            resistance of new designs and existing situations where
                                                                                                            reasonably practical if the risk is tolerable are covered in the
                                                                                                            following sections
                                                           178           PSLG/BSTG                          Noted
                                                           179           PSLG/BSTG                          Noted
                                                           180           PSLG/BSTG                          Noted
                                                                                                            In considering the use of fire-resistant sealants, due regard
                                                                                                            should also be given to the suitability and compatibility of
                                                           181           PSLG/BSTG           R.17.18.6                                                                                        0             0             0              0              0
                                                                                                            candidate products (for example hydrocarbon and water
                                                                                                            resistance) in the specific application




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                                                                            Waterstops are integral design and construction features of
                                                                            concrete structures whose duty is to retain liquids. Good
                                                                            practice for the minimisation of leakage from concrete bunds
                                                                            includes the use of waterstops within movement joints, in
                                       182       PSLG/BSTG      R.17.18.7   accordance with BS 8007. In order to meet both fire and                0   0   0   0   0
                                                                            corrosion resistance performance requirements metal
                                                                            waterstops should be used on new build and where
                                                                            reasonably practical if the risk is tolerable for existing bunds –
                                                                            as described in paragraphs 209–216

                                       183       PSLG/BSTG                  Noted
                                       184       PSLG/BSTG                  Noted
                                       185       PSLG/BSTG                  Noted
                                  Pipe penetrations: general
                                       186       PSLG/BSTG                  HSG 176 The storage of flammable liquids in tanks states that:
                                                                            where reasonably practicable electrical equipment should be
                                                                            installed in non-hazardous areas .. and … where this cannot
                                                                            be done, equipment should be selected, installed and
                                                      •         R.17.18.8   maintained in accordance with BS 5345 Code of practice for             0   0   0   0   0
                                                                            the selection, installation and maintenance of electrical
                                                                            apparatus for use in potentially explosive atmospheres (or
                                                                            other equivalent standard), paragraph 38
                                                                            pumps are potential ignition sources and should be located
                                                                            outside the bund – this will also avoid damage from fires or
                                                      •         R.17.18.9   spillages in the bund and facilitate access for maintenance            0   0   0   0   0
                                                                            (and in practice the bund should not be considered to be a
                                                                            normal operational area), paragraph 104
                                                                            the bund should be liquid tight … and ….the integrity of the
                                                                            bund wall may be put at risk if pipework and other equipment
                                                                            are allowed to penetrate it. If it is necessary to pass pipes
                                                      •        R.17.18.10   through the bund wall, for example to the pump, then the               0   0   0   0   0
                                                                            effect on the structural strength should be assessed. Additional
                                                                            measures may be needed to ensure that the bund wall
                                                                            remains liquid tight
                                       187       PSLG/BSTG                  Noted
                                       188       PSLG/BSTG                  Noted
                                                                            The COMAH Containment policy states that: “Bunds shall
                                                                            have no pipework that penetrates through the bund floor; no
                                       189       PSLG/BSTG     R.17.18.11   pipework that penetrates through the bund walls as far as              0   0   0   0   0
                                                                            reasonably practicable, otherwise it shall be with adequate
                                                                            sealing and support.”
                                       190       PSLG/BSTG                  Noted
                                       191       PSLG/BSTG                  Noted

                                                                            When these activities are carried out on a regular basis then
                                                                            pipes will need to pass through the bund wall. Where they do,
                                       192       PSLG/BSTG     R.17.18.12                                                                          0   0   0   0   0
                                                                            structural effects should be assessed and penetrations should
                                                                            be designed to be liquid tight and fire resistant.

                                       193       PSLG/BSTG                  Noted
                                       194       PSLG/BSTG                  Noted
                                  Pipe penetrations: new builds/major upgrade work
                                       195       PSLG/BSTG                  Noted
                                                                            It is important to note that this arrangement acts as an anchor
                                                                            for the pipe. When it is used the pipe arrangement between
                                       196       PSLG/BSTG     R.17.18.13   this anchor and the tank nozzle should allow sufficient flexibility    0   0   0   0   0
                                                                            to ensure forces on both the bund wall and tank shell are
                                                                            minimised and within design limits
                                                                            This is relatively easy to achieve for smaller pipe sizes (<16″)
                                                                            and for new terminals where flexible pipe routing can be
                                                                            designed. For larger line sizes with greater temperature
                                                                            variations this design may not be workable, particularly for
                                       197       PSLG/BSTG     R.17.18.14   existing terminals with short distances between the tank and           0   0   0   0   0
                                                                            bund wall, where expansion loops cannot easily be added to
                                                                            the pipe layout. Under these circumstances alternative
                                                                            arrangements which allow for some movement of the pipe
                                                                            may need to be considered as seen in Figures 6, 7 and 8

                                                                            The BSTG puddle flange arrangement has been used by
                                                                            operators for a number of years. As long as the space
                                                                            between the pipe and external sleeve remains free from
                                       198       PSLG/BSTG     R.17.18.15                                                                          0   0   0   0   0
                                                                            debris, allows visual examination of the space and the pipe
                                                                            does not come into contact with the sleeve, it will provide a
                                                                            crevice-free arrangement that is relatively easy to maintain




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                                                                                       For the alternative arrangement there is a higher possibility of
                                                                                       crevice corrosion between the pipe and the sleeve packing.
                                                                                       For this reason pipe protective coatings and materials should
                                                199        PSLG/BSTG      R.17.18.16   be carefully selected for this detail and regular inspections           0   0   0   0   0
                                                                                       should be carried out to ensure that protective coatings and
                                                                                       seal arrangements remain in good condition and corrosion of
                                                                                       the pipe is not taking place
                                                                                       It is recommended that the fire rating of the link seal is
                                                                                       carefully considered and future fire testing should be carried
                                                200        PSLG/BSTG      R.17.18.17                                                                           0   0   0   0   0
                                                                                       out to confirm the observed suitability of these pipe penetration
                                                                                       arrangements
                                           Pipe penetrations: existing pipe penetrations
                                                                                       The upgrading of existing pipe penetrations to provide a liquid
                                                                                       tight, fire proof corrosion free joint is more difficult to achieve.
                                                                                       Any upgrade should be carefully reviewed to ensure that the
                                                201        PSLG/BSTG      R.17.18.18   upgraded penetration does not affect pipe flexibility and               0   0   0   0   0
                                                                                       integrity. A summary table is provided below paragraph 206
                                                                                       outlining the main existing pipe penetrations details and
                                                                                       methods of upgrade
                                                                                       Terminals have utilised several designs for existing pipe
                                                                                       penetrations through bund walls. Some of the methods are
                                                202        PSLG/BSTG      R.17.18.19   shown in Figure 9: straight-through; puddle flange; and                 0   0   0   0   0
                                                                                       sleeved arrangement. These can be assessed and/or applied
                                                                                       based on ALARP principles if the risk is tolerable
                                                                                       Where the operator does not consider the existing joints to be
                                                                                       fire resistant or leak tight, one upgrade option would be to bolt
                                                                                       on a steel protection ring (split for installation) sealed with
                                                                                       fire/chemical resistant sealant. This is similar in principle to the
                                                203        PSLG/BSTG      R.17.18.20                                                                           0   0   0   0   0
                                                                                       steel plates for expansion joints covered in the next section.
                                                                                       Slit plates can be installed by cold methods without the need
                                                                                       for removing the pipeline from service for modification and
                                                                                       welding
                                                                                       For existing pipes running through bund walls there are
                                                                                       genuine concerns regarding possible corrosion crevices
                                                                                       between the pipe and the wall. An upgrade option which has
                                                                                       been used is to reduce the pipe size (only local to the
                                                                                       penetration) and use the existing pipe as a sleeve with the
                                                204        PSLG/BSTG      R.17.18.21   BSTG puddle flange arrangement. This then allows various                0   0   0   0   0
                                                                                       options to seal between the sleeve and bund wall without
                                                                                       concerns for thinning of the product pipe (primary
                                                                                       containment). Regular inspection is still required to ensure that
                                                                                       long-term corrosion of the sleeve (secondary containment)
                                                                                       does not provide a leak path from the bund

                                                205        PSLG/BSTG                   Noted
                                                206        PSLG/BSTG                   Noted
                                           Pipe penetrations: anchoring
                                                207        PSLG/BSTG                   Noted
                                                                                       The straight-through type arrangement, although offering
                                                                                       pipeline restraint in the vertical direction, allows horizontal
                                                                                       movement and is therefore difficult to seal. If the extent of
                                                208        PSLG/BSTG      R.17.18.22                                                                           0   0   0   0   0
                                                                                       movement is such that sealants do not retain the joints‟
                                                                                       integrity, then an upgrade solution to install cover plates should
                                                                                       be considered
                                           Bund wall expansion and construction joints
                                                209        PSLG/BSTG                   Noted
                                                                                       New joints should be installed with metal waterstops and
                                                                                       fireproof joints. Waterstops fabricated from stainless steel or
                                                210        PSLG/BSTG      R.17.18.23                                                                           0   0   0   0   0
                                                                                       copper are in use at terminals and the choice of metal is
                 4                17, 18                                               informed by performance requirements
                                                                                       Where practicable, existing joints should be upgraded to
                                                                                       provide waterstops and/or fireproof joints. There are realistic
                                                211        PSLG/BSTG      R.17.18.24   methods available – however it is recognised that retrofitting          0   0   0   0   0
                                                                                       waterstops to existing bund wall joints is not a simple task and
                                                                                       it may degrade the joint integrity
                                                212        PSLG/BSTG                   Noted
                                                213        PSLG/BSTG                   Noted

                                                                                       Where it is difficult to install product-resistant sealants to
                                                                                       ensure a liquid tight seal, for example due to the condition of
                                                                                       the concrete faces of the joint, it may be practicable to create
                                                                                       a new joint with fireproof waterstop on the outside of existing
                                                                                       bund wall. This would require two new concrete pillars joined
                                                214        PSLG/BSTG      R.17.18.25   to the outside of the bund wall either side of the existing bund        0   0   0   0   0
                                                                                       wall joint. A fireproof waterstop joint could be installed
                                                                                       between the two new pillars which would then form the new
                                                                                       bund wall joint. Care would need to be taken to ensure pillars
                                                                                       are supported with suitable foundations and that any new
                                                                                       stresses would not lead to cracking of the existing bund wall




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                                                                             It is recommended that a suitable fire test method be agreed
                                       215        PSLG/BSTG     R.17.18.26   and a test programme of trial joints be carried out to confirm         0   0   0   0   0
                                                                             the observed suitability of these expansion joint arrangements

                                       216        PSLG/BSTG                  Noted
                                       217        PSLG/BSTG                  Noted
                                  Secondary containment systems under tanks
                                       218        PSLG/BSTG                  Noted - Refer to Requirement R.17.18.27
                                                                             It is important that secondary and tertiary containment systems
                                       219        PSLG/BSTG     R.17.18.27                                                                          0   0   0   0   0
                                                                             are designed to deal with both types of event
                                       220        PSLG/BSTG                  Noted - Refer to Requirement R.17.18.27
                                  Basis for bund capacity based on tank capacity
                                       221        PSLG/BSTG                  Noted
                                       222        PSLG/BSTG                  Noted - Refer to Requirement R.17.18.28
                                       223        PSLG/BSTG                  Noted
                                       224        PSLG/BSTG                  Noted

                                                                             The bund should be sized for 110% of the „tank rated capacity‟
                                                                             (TRC) as a minimum. This assumes that the minimum
                                                                             standards for overfill protection systems of control are in place
                                                                             relating to:
                                       225        PSLG/BSTG     R.17.18.28   • tank levels and capacities are determined in accordance with         0   0   0   0   0
                                                                             Appendix 3;
                                                                             • position and type of level gauges and high level detectors;
                                                                             • how are these monitored and the required response;
                                                                             • response times to shutdown inflow.

                                       226        PSLG/BSTG                  Noted - Refer to Requirement R.17.18.28
                                       227        PSLG/BSTG                  Noted - Refer to Requirement R.17.18.28
                                                                             Operators should also record overfill volumes to establish the
                                                                             difference in risk between TRC and overfill levels – which may
                                       228        PSLG/BSTG     R.17.18.29                                                                          0   0   0   0   0
                                                                             involve significant volumes for larger tanks. This is to be
                                                                             reported for information only
                                                                             Unless multiple tanks sharing the same bund are hydraulically
                                                                             linked, simultaneous overfill of independent tanks can be
                                                                             discounted as a realistic hazard. Therefore, the 25% criteria
                                       229        PSLG/BSTG     R.17.18.30   would not apply to the Overfill level. For the bund capacity           0   0   0   0   0
                                                                             calculation based on 25% of the total capacity of all the tanks,
                                                                             the normal fill levels of all the tanks within the bund should be
                                                                             used
                                       230        PSLG/BSTG                  Noted - Refer to Requirement R.17.18.30
                                  Bund strength
                                                                             A bund should be capable of withstanding the full hydrostatic
                                       231        PSLG/BSTG     R.17.18.31   head of liquid that may arise from the loss of primary                 0   0   0   0   0
                                                                             containment
                                                                             Following catastrophic failure of a tank – overtopping of a
                                                                             bund to some extent is usually inevitable. In the absence of
                                                                             practical guidance on assessment of bunds for likely levels of
                                       232        PSLG/BSTG     R.17.18.32                                                                          0   0   0   0   0
                                                                             overtopping or hydrodynamic loads – emphasis should be
                                                                             placed on mitigation and control of the effects of overtopping
                                                                             through tertiary containment
                                  Firewater management and control measures
                                                                             Well-planned and organised emergency response measures
                                                                             are likely to significantly reduce the potential duration and
                                                                             extent of fire scenarios, and so reduce firewater volumes
                                       233        PSLG/BSTG     R.17.18.33   requiring containment and management. Site-specific planning           0   0   0   0   0
                                                                             of firewater management and control measures should be
                                                                             undertaken with active participation of the local Fire and
                                                                             Rescue Service, and should include consideration of:

                                                                             bund design factors such as firewater removal pipework,
                                                      •         R.17.18.34   aqueous layer controlled overflow to remote secondary or               0   0   0   0   0
                                                                             tertiary containment (for immiscible flammable hydrocarbons)

                                                                             recommended firewater/foam additive application rates and
                                                      •         R.17.18.35   firewater flows and volumes at worst-case credible scenarios           0   0   0   0   0
                                                                             (including severe pool fire or multiple tank / multiple bund fire)
                                                                             controlled-burn options appraisal, and pre-planning/media
                                                      •         R.17.18.36                                                                          0   0   0   0   0
                                                                             implications
                                  Tertiary containment
                                       234        PSLG/BSTG                  Noted
                                       235        PSLG/BSTG                  Noted
                                                                             A risk assessment should be undertaken to determine the
                                       236        PSLG/BSTG                  extent of the requirement for tertiary containment, taking into
                                                                             account:
                                                                             foreseeable worst-case scenario – severe pool fire or multiple
                                                      •         R.17.18.37   tank/multiple bund fire (following an explosion or due to              0   0   0   0   0
                                                                             escalation)




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                                                                 foreseeable bund failure modes, including:

                                                                 • the amount of spilled substances, including hydrodynamic
                                                                 effects of catastrophic tank failure and emergency response
                                                                 actions such as fire fighting;
                                            •       R.17.18.38                                                                           0   0   0   0   0
                                                                 • the potential impact of fire on bund integrity including joints in
                                                                 walls and floors;
                                                                 • worst-case foreseeable delivered firewater volumes including
                                                                 fire fighting agents (see IP1941); and
                                                                 • passive and active firewater management measures

                                                                 environmental setting, including:

                                                                 • all relevant categories of receptors as specified in Guidance
                                                                 on the interpretation of Major Accident to the Environment;
                                                                 • proximity of receptor, for example groundwaters under the
                                                                 site;
                                            •       R.17.18.39                                                                           0   0   0   0   0
                                                                 • site and surrounding topography;
                                                                 • geological factors affecting the permeability of surrounding
                                                                 land and environmental pollution pathways; and
                                                                 • hydrogeological factors affecting liquid pollutant flows and
                                                                 receptor vulnerabilities


                                                                 known pathways and potential pathways to environmental
                                            •       R.17.18.40                                                                           0   0   0   0   0
                                                                 receptors in the event of failure of secondary containment
                                                                 likely environmental impact consequences, in terms of extent
                                            •       R.17.18.41   and severity, of the pollutant and/or firewater quantities and          0   0   0   0   0
                                                                 flows resulting from foreseeable bund failure scenarios
                                                                 Based on the scope and capacity determined by the site-
                                  237   PSLG/BSTG                specific risk assessment, tertiary containment should be
                                                                 designed to:
                                                                 be independent of secondary containment and associated
                                            •       R.17.18.42   risks of catastrophic failure in a worst-case major accident            0   0   0   0   0
                                                                 scenario
                                                                 be capable of fully containing foreseeable firewater and liquid
                                            •       R.17.18.43   pollutant volumes resulting from the failure of secondary               0   0   0   0   0
                                                                 containment
                                                                 be impermeable to water and foreseeably entrained or
                                            •       R.17.18.44                                                                           0   0   0   0   0
                                                                 dissolved pollutants
                                                                 use cellular configuration, to allow segregation of „sub-areas‟
                                            •       R.17.18.45   so as to limit the extent of the spread of fire and/or polluted         0   0   0   0   0
                                                                 liquids

                                            •       R.17.18.46   operate robustly under emergency conditions, for example in             0   0   0   0   0
                                                                 the event of loss of the normal electrical power supply
                                                                 avoid adverse impacts on fire fighting and other emergency
                                            •       R.17.18.47                                                                           0   0   0   0   0
                                                                 action requirements
                                                                 allow the controlled movement of contained liquids within the
                                            •       R.17.18.48                                                                           0   0   0   0   0
                                                                 site under normal and emergency conditions
                                                                 facilitate the use of measures for the physical separation of
                                            •       R.17.18.49                                                                           0   0   0   0   0
                                                                 water from entrained pollutants

                                            •       R.17.18.50   incorporate practical measures for the management of                    0   0   0   0   0
                                                                 rainwater and surface waters as required by the configuration
                                            •       R.17.18.51   facilitate clean-up and restoration activities                          0   0   0   0   0
                                  238   PSLG/BSTG                Noted - Refer to Requirements R.17.18.42 to R.17.18.51
                                  239   PSLG/BSTG                Noted - Refer to Requirements R.17.18.42 to R.17.18.51
                                  240   PSLG/BSTG                Noted - Refer to Requirements R.17.18.42 to R.17.18.51
                                  241   PSLG/BSTG                Noted - Refer to Requirements R.17.18.42 to R.17.18.51
                                  242   PSLG/BSTG                Noted - Refer to Requirements R.17.18.42 to R.17.18.51
                                  243   PSLG/BSTG                Noted - Refer to Requirements R.17.18.42 to R.17.18.51
                                  244   PSLG/BSTG                Noted - Refer to Requirements R.17.18.42 to R.17.18.51
                                  245   PSLG/BSTG                Noted - Refer to Requirements R.17.18.42 to R.17.18.51
                                  246   PSLG/BSTG                Noted
                                  247   PSLG/BSTG                Noted
                                  248   PSLG/BSTG                Noted

                                                                 Suitable and precautionary methodologies should be used for
                                                                 the above risk assessment. In view of the high uncertainties in
                                                                 modelling the transport of entrained or dissolved pollutants in
                                  249   PSLG/BSTG   R.17.18.52                                                                           0   0   0   0   0
                                                                 liquids escaping secondary containment, it is recommended
                                                                 that assessments concentrate on quantifiable physical
                                                                 parameters such as those indicated in Table 5

                                  250   PSLG/BSTG                Noted




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                                                                                             Partially Implemented




                                                                                                                                                                                                                                    Partially Implemented
                                                                           Not Implemented




                                                                                                                                                                                                                  Not Implemented
                                                                                                                       Implemented




                                                                                                                                                                                                                                                              Implemented
                                                                                                                                                      Implementation (Requirements R.17.18.27 to
                Implementation (Requirements R.17.18.1 to
                 PSLG Part 4, Recommendations 17 and 18




                                                                                                                                                        PSLG Part 4, Recommendations 17 and 18




                                                                                                                                          R.17.18.…
                                                                                                                                          R.17.18.…
                                                                                                                                          R.17.18.…                                                                                                                              R.17.18.…




                                                                                                                                                                                                                                                                                                         Part 4 Gap Analysis
                                                                                                                                          R.17.18.…                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.…                                                                                                                              R.17.18.…
                                                                                                                                                                                                                                                                                 R.17.18.…
                                                                                                                                          R.17.18.…
                                                                                                                                                                                                                                                                                 R.17.18.…
                                                                                                                                          R.17.18.…
                                                                                                                                                                                                                                                                                 R.17.18.…
                                                                                                                                          R.17.18.…
                                R.17.18.26)




                                                                                                                                                                       R.17.18.52)




                                                                                                                                                                                                                                                                                 R.17.18.…
                                                                                                                                          R.17.18.…                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.…                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.…                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.…                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.…                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.…                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.…                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.…                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.…                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.9                                                                                                                              R.17.18.…
                                                                                                                                                                                                                                                                                 R.17.18.…
                                                                                                                                          R.17.18.8
                                                                                                                                                                                                                                                                                 R.17.18.…
                                                                                                                                          R.17.18.7
                                                                                                                                                                                                                                                                                 R.17.18.…
                                                                                                                                          R.17.18.6
                                                                                                                                                                                                                                                                                 R.17.18.…
                                                                                                                                          R.17.18.5                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.4                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.3                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.2                                                                                                                              R.17.18.…
                                                                                                                                          R.17.18.1                                                                                                                              R.17.18.…
                                                                                40%
                                                        100%

                                                               80%

                                                                     60%




                                                                                                                     20%




                                                                                                                                                                                               100%

                                                                                                                                                                                                      80%

                                                                                                                                                                                                            60%

                                                                                                                                                                                                                       40%

                                                                                                                                                                                                                                                            20%
                                                                                                                                     0%




                                                                                                                                                                                                                                                                            0%




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Part 5 - Operating with high reliability organisations
Recommendation 19

           MIIB Design and Operations Report Recommendation 19:
           The sector should work with the Competent Authority to prepare guidance and/or standards on how to achieve a high reliability industry through placing emphasis on the assurance of human and organisational factors in design, operation, maintenance, and testing. Of particular importance are:
                      (a) understanding and defining the role and responsibilities of the control room operators (including in automated systems) in ensuring safe transfer processes
                      (b) providing suitable information and system interfaces for front line staff to enable them to reliably detect, diagnose and respond to potential incidents
                      (c) training, experience and competence assurance of staff for safety critical and environmental protection activities
                      (d) defining appropriate workload, staffing levels and working conditions for front line personnel
                      (e) ensuring robust communications management within and between sites and contractors and with operators of distribution systems and transmitting sites (such as refineries)
                       (f) prequalification auditing and operational monitoring of contractors’ capabilities to supply, support and maintain high integrity equipment
                      (g) providing effective standardised procedures for key activities in maintenance, testing, and operations
                      (h) clarifying arrangements for monitoring and supervision of control room staff
                       (i) effectively managing changes that impact on people, processes and equipment

           Table guidance:
                   (a) No Gap Analysis is necessary against paragraphs 251-254 of the main report, instead refer to the Gap Analysis performed against Appendix 5

                                                                                                                                                                                                        Level of Implementation
                                                                                                                                                                                                             C%
                                MIIB D&O                          PSLG or BSTG        Requirement                                                                                                                              Meets
              Section                               Paragraph                                          Requirement                                                      Priority       Not         Partially o Fully Meets
                                                                                                                                                                                                              C                                                    Reference                              Comments
                             Recommendation                        Reference[1]         Number                                                                                                                               Requirement   Not Applicable
                                                                                                                                                                                   Implemented                o
                                                                                                                                                                                                 Implemented mRequirements
                                                                                                                                                                                                             pm                SFAIRP
                                                                                                                                                                                                             lp
                                                        251             PSLG                           Refer to Appendix 5 Gap Analysis
                                                        252             PSLG                           Refer to Appendix 5 Gap Analysis
                 5                   19
                                                        253             PSLG                           Refer to Appendix 5 Gap Analysis
                                                        254            BSTG                            Refer to Appendix 5 Gap Analysis



Recommendation 20

           MIIB Design and Operations Report Recommendation 20:
           The sector should ensure that the resulting guidance and/or standards is/are implemented fully throughout the sector, including where necessary with the refining and distribution sectors. The Competent Authority should check that this is done

           Table guidance:
                   (a) No Gap Analysis is necessary against paragraphs 255-256 of the main report, instead refer to the Gap Analysis performed against Appendix 5

                                                                                                                                                                                                        Level of Implementation
                                                                                                                                                                                                             C%
                                MIIB D&O                          PSLG or BSTG        Requirement                                                                                                            o Fully Meets
                                                                                                                                                                                                              C                Meets
              Section                               Paragraph                                          Requirement                                                      Priority       Not         Partially                                                       Reference                              Comments
                             Recommendation                        Reference[1]         Number                                                                                                                               Requirement   Not Applicable
                                                                                                                                                                                   Implemented                o
                                                                                                                                                                                                 Implemented mRequirements
                                                                                                                                                                                                             pm                SFAIRP
                                                                                                                                                                                                             lp
                                                        255             PSLG                           Refer to Appendix 5 Gap Analysis
                 5                   20
                                                        256             PSLG                           Competent Authority Action




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                                                                                                                                                                                                                                                                                                                   Page 39 of 65




Recommendation 21

           MIIB Design and Operations Report Recommendation 21:
           The sector should put in place arrangements to ensure that good practice in these areas, incorporating experience from other high hazard sectors, is shared openly between organisations

           Table guidance:
                   (a) For this table, level of implementation is not gauged against the quantity of individual tanks, but instead implementation of the management system processes as a whole
                   (b) Enter '1' in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable

                                                                                                                                                                                                       Level of Implementation
                                                                                                                                                                                                           C%
                               MIIB D&O                          PSLG or BSTG        Requirement                                                                                                           o Fully Meets
                                                                                                                                                                                                            C                Meets
              Section                               Paragraph                                           Requirement                                                   Priority       Not         Partially                                                     Reference                             Comments
                            Recommendation                        Reference[1]         Number                                                                                                                              Requirement   Not Applicable
                                                                                                                                                                                 Implemented                o
                                                                                                                                                                                               Implemented mRequirements
                                                                                                                                                                                                           pm                SFAIRP
                                                                                                                                                                                                           lp
                                                                                                        Do you actively participate (for example through a trade
                                                                                                        association) in the new Process Safety Forum which has been
                 5                  21                 257             PSLG              R.21.1         established to collectively review incidents and share the                   0             0             0              0              0
                                                                                                        lessons and good practice? See Appendix 8 for the Forum‟s
                                                                                                        terms of reference




                                                                                                                   PSLG Part 5, Recommendation 21
                                                                                                                           Implementation
                                                                                     100%

                                                                                      80%

                                                                                      60%
                                                                                                                                                                                  Not Implemented
                                                                                      40%
                                                                                                                                                                                  Partially Implemented
                                                                                      20%
                                                                                                                                                                                  Implemented
                                                                                       0%
                                                                                               R.21.1




Recommendation 22

           MIIB Design and Operations Report Recommendation 22:
           The Competent Authority should ensure that safety reports submitted under the COMAH Regulations contain information to demonstrate that good practice in human and organisational design, operation, maintenance and testing is implemented as rigorously as for control and environmental protection

           Table guidance:
                   (a) No Gap Analysis is necessary against paragraphs 258

                                                                                                                                                                                                       Level of Implementation
                                                                                                                                                                                                           C%
                               MIIB D&O                          PSLG or BSTG        Requirement                                                                                                           o Fully Meets
                                                                                                                                                                                                            C                Meets
              Section                               Paragraph                                           Requirement                                                   Priority       Not         Partially                                                     Reference                             Comments
                            Recommendation                        Reference[1]         Number                                                                                    Implemented   Implemented mRequirements
                                                                                                                                                                                                            o              Requirement   Not Applicable
                                                                                                                                                                                                           pm                SFAIRP
                                                                                                                                                                                                           lp
                 5                  22                 258             PSLG                             Competent Authority Action




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Part 6 - Delivering high performance through culture and leadership
Recommendations 23, 24, 25

           MIIB Design and Operations Report Recommendation 23:
           The sector should set up arrangements to collate incident data on high potential incidents including overfilling, equipment failure, spills and alarm system defects, evaluate trends, and communicate information on risks, their related solutions and control measures to the industry

           MIIB Design and Operations Report Recommendation 24:
           The arrangements set up to meet Recommendation 23 should include, but not be limited to, the following
                      (a) Thorough investigation of root causes of failures and malfunctions of safety and environmental protection critical elements during testing or maintenance, or in service
                      (b) Developing incident databases that can be shared across the entire sector, subject to data protection and other legal requirements. Examples exist of effective voluntary systems that could provide suitable models
                      (c) Collaboration between the workforce and its representatives, dutyholders and regulators to ensure lessons are learned from incidents, and best practices are shared

           MIIB Design and Operations Report Recommendation 25:
           In particular, the sector should draw together current knowledge of major hazard events, failure histories of safety and environmental protection critical elements, and developments in new knowledge and innovation to continuously improve the control of risks. This should take advantage of the experience of other
           high hazard sectors such as chemical processing, offshore oil and gas operations, nuclear processing and railways

                           Table guidance:
                                         (a) For this table, level of implementation is not gauged against the quantity of individual tanks, but instead implementation of the management system processes as a whole
                                         (b) Enter '1' in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable

                                                                                                                                                                                                            Level of Implementation
                                                                                                                                                                                                                C%
                                MIIB D&O                           PSLG or BSTG        Requirement                                                                                                                                Meets
              Section                                Paragraph                                           Requirement                                                       Priority       Not         Partially o Fully Meets
                                                                                                                                                                                                                 C                                                        Reference                              Comments
                             Recommendation                         Reference[1]         Number                                                                                       Implemented   Implemented mRequirements
                                                                                                                                                                                                                 o              Requirement   Not Applicable
                                                                                                                                                                                                                pm                SFAIRP
                                                                                                                                                                                                                lp
                                                         259             PSLG                            Noted
                                                         260             PSLG                            Noted
                                                                                                         To demonstrate the importance of culture and leadership in
                                                                                                         the delivery of a high reliability organisation, PSLG has
                                                                                                         published Principles of Process Safety Leadership. The
                                                         261             PSLG           R.23.24.25.1                                                                                      0             0             0              0              0
                                                                                                         principles can be found in Appendix 7 of this report. Have you
                 6                23, 24, 25
                                                                                                         adopted these principles (For example throgh your trade
                                                                                                         association)? Further guidance is provided in Appendix 5
                                                         262             PSLG                            Refer to Requirement R.21.1
                                                         263             PSLG                            Noted
                                                         264             PSLG                            Noted
                                                         265             PSLG                            Noted




                                                                                                           PSLG Part 5, Recommendation 23, 24 and 25                                                                                                                                                                                    Compliant
                                                                                                                                                                                                                                                                                                                                        Partial
                                                                                                                         Implementation                                                                                                                                                                                                 Not
                                                                                        100%                                                                                                                                                                                                                                            Total

                                                                                         80%

                                                                                         60%
                                                                                                                                                                                       Not Implemented
                                                                                         40%
                                                                                                                                                                                       Partially Implemented
                                                                                         20%
                                                                                                                                                                                       Implemented
                                                                                          0%
                                                                                                R.23.2
                                                                                                4.25.1




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Appendix 4 - Guidance on automatic overfill protection systems for bulk gasoline storage tanks


           The following table provides additional analysis in support of Part 2, Protecting against loss of primary containment using high integrity systems, specifically:
           Paragraphs 48, 70, 78, 120 and 121


           Table guidance:
                   (a) For this table, level of implementation is gauged on compliance for each individual tank
                   (b) Enter the tank quantity in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable
                   (c) The total in-scope tanks can be found on the Part 1 Gap Analysis worksheet

                                                                                                                                                                                                                Level of Implementation
                                                                                                                                                                                                                    C%
                                MIIB D&O                             PSLG or BSTG         Requirement                                                                                                               o Fully Meets
                                                                                                                                                                                                                     C                Meets
              Section                                 Paragraph                                             Requirement                                                        Priority       Not         Partially                                                Reference   Comments
                             Recommendation                           Reference[1]          Number                                                                                                                                  Requirement   Not Applicable
                                                                                                                                                                                          Implemented                o
                                                                                                                                                                                                        Implemented mRequirements
                                                                                                                                                                                                                    pm                SFAIRP
                                                                                                                                                                                                                    lp
                                                           1              PSLG                              Noted
                                                           2              PSLG                              Noted
                                                           3              PSLG                              Noted
                                                           4              PSLG                              Refer to requirements R.345.1 and R.345.2
                                                     Detailed design requirements
                                                                                                            The following specific requirements from BS EN 61511 should
                                                           5              PSLG
                                                                                                            all be complied with:
                                                                             •                R.A4.1        the design must meet the safety requirement specification                         0             0             0              0              0
                                                                                                            the system architecture must meet the hardware fault
                                                                             •                R.A4.2        tolerance requirements for the specified SIL (Refer to the full                   0             0             0              0              0
                                                                                                            text of annex 1 and annex 2)
                                                                                                            the overall PFD of the safety instrumented function design
                                                                             •                R.A4.3        must meet the PFD as determined by the risk assessment                            0             0             0              0              0
                                                                                                            (Refer to the full text of annex 3)
                                                                                                            subsystems should meet the general requirements of BS EN
                                                                             •                R.A4.4        61511 section 11.5.2 and section 12 for programmable                              0             0             0              0              0
                                                                                                            subsystems
                                                                                                            General good practice: The following should be considered
                                                           6              PSLG                              during the design, development and maintenance of an
                                                                                                            automatic overfill protection system:
                                                                                                            Dominant failure modes of any device should be to the safe
                                                                             •                R.A4.5        state or dangerous failure detected, unless architecture allows                   0             0             0              0              0
                                                                                                            for fault tolerance
                                                                                                            Diagnostics for all subsystems are recommended where
                                                                                                            necessary to detect dangerous unrevealed failures.
                                                                             •                R.A4.6                                                                                          0             0             0              0              0
                                                                                                            Procedures should be in place to respond to diagnostic
                                                                                                            alarms. Diagnostics should be tested during proof testing
                                                                                                            The SIS should be capable of carrying out its designed
                                                                             •                R.A4.7        function on loss of power (pneumatic, electric, hydraulic) (BS                    0             0             0              0              0
                                                                                                            EN 61511 section 11.2.11)
                                                                             •                R.A4.8        Operation of the SIF should generate an alert to the operator                     0             0             0              0              0
                                                                                                            Sufficient independence and separation should be
                                                                             •                R.A4.9        demonstrated between the SIS and the basic process control                        0             0             0              0              0
                                                                                                            system (BPCS) (BS EN 61511 section 9.5)
                                                                                                            User‟s own valid failure rate data should be used within PFD
                                                                             •               R.A4.10        calculations. Where this is not available use of appropriate                      0             0             0              0              0
                                                                                                            recognised external data sources is acceptable
                                                                                                            The SIS design should provide facilities for ease of proof
                                                                             •               R.A4.11                                                                                          0             0             0              0              0
                                                                                                            testing
                                                                                                            All equipment should be suitably designed for the process and
                                                                             •               R.A4.12        operating conditions, the environment and the hazardous area                      0             0             0              0              0
                                                                                                            requirements
                                                                                                            Input overrides should only be provided where justified (as
                                                                             •               R.A4.13        described in paragraph 24). Output overrides should not be                        0             0             0              0              0
                                                                                                            used
                                                           7              PSLG                              For level sensors, has the following been considered:
                                                                                                            Analogue level sensors are preferred to digital (switched)
                                                                             •               R.A4.14                                                                                          0             0             0              0              0
                                                                                                            sensors
                                                                                                            A discrepancy alarm between the tank level indication system
                                                                             •               R.A4.15        and an analogue trip system can be used to alert that there is                    0             0             0              0              0
                                                                                                            a problem with the level measurement
                                                                                                            For logic solver fault tolerance, has the following been
                                                           8              PSLG
                                                                                                            considered:
                                                                                                            Non-programmable logic solvers should comply with Table 6
                                                                             •               R.A4.16                                                                                          0             0             0              0              0
                                                                                                            of BS EN 61511
                                                                                                            Programmable logic solvers should comply with Table 5 of BS
                                                                             •               R.A4.17                                                                                          0             0             0              0              0
                                                                                                            EN 61511
                                                           9              PSLG                              For final elements, has the following been considered:




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                                                                                          Electrically operated valves that do not fail safe on loss of
                                                                    •           R.A4.18   power should have a backup power supply. The loss of power                0   0   0   0   0
                                                                                          supply should be alerted to the operator
                                                                    •           R.A4.19   Auto reset of the final element should not be possible                    0   0   0   0   0

                                                                                          An adequate margin of safety factor should be provided for
                                                                    •           R.A4.20   actuator torque on shut-off valves. The break off (from open              0   0   0   0   0
                                                                                          position) force/torque recommended as minimum 1.5 times
                                                                                          Manual operating facilities which inhibit the SIF operation on
                                                                    •           R.A4.21                                                                             0   0   0   0   0
                                                                                          valves (eg hand wheels) are not recommended
                                                                                          Performance of the shut-off valve should meet the
                                                                    •           R.A4.22   requirements of the safety requirement specification (eg shut-            0   0   0   0   0
                                                                                          off classification)
                                                                                          Closure of shut-off valves should be designed to prevent
                                                                    •           R.A4.23   pressure surges on the system pipework and couplings                      0   0   0   0   0
                                                                                          (particularly to flexible pipes on ship to shore)
                                                                                          Note: To prevent damage to pipelines and flexible hoses due
                                                                                          to pressure surges or over-pressure in the event of a shutdown
                                                                                          for any reason including inadvertent export valve closure, the
                                                                                          supplying source (eg ships) should already be fitted with the
                                                                                          necessary protection against over-pressure or no flow in the
                                                                   Note         R.A4.24                                                                             0   0   0   0
                                                                                          event of dead head or other effect of shutdown. This is the
                                                                                          responsibility of the shipping company and ship owner but the
                                                                                          terminal owner has the responsibility of informing the shipping
                                                                                          company that an automatic shutdown system is in operation
                                                                                          and may operate at any time

                                                  New tank automatic overfill protection system
                                                                                          Automatic overfill protection systems for a new tank[3] should
                                                      10          PSLG          R.A4.25                                                                             0   0   0   0   0
                                                                                          meet the requirements of BS EN 61511 and paragraphs 5 to 9

                                                      11          PSLG                    Noted
                                                      12          PSLG                    Noted
                                                  Existing tank installations
                                                                                          Where there is an existing overfill protection system to a
                                                                                          standard other than BS EN 61511, a gap analysis should be
                                                      13          PSLG          R.A4.26                                                                             0   0   0   0   0
                                                                                          conducted to determine the extent of compliance with BS EN
                                                                                          61511
                                                                                          For SIL 2 or higher safety requirements the installation should
                                                      14          PSLG          R.A4.27                                                                             0   0   0   0   0
                                                                                          fully comply with BS EN 61511
                                                                                          For SIL1 safety requirements, improvements to existing
                                                                                          systems may still be necessary to meet ALARP even in cases
                                                                                          where it is not reasonably practicable to upgrade or replace
                                                      15          PSLG                    existing systems to fully meet the requirements of BS EN
                                                                                          61511. The following issues should be addressed when
                                                                                          considering what improvements are required: (Refer also to
                                                                                          the full text of annex 4)
                                                                                          The degree of independence of sensors used for the high-high
                                                                    •           R.A4.28                                                                             0   0   0   0   0
                                                                                          alarm/shut-off
                                                                    •           R.A4.29   The suitability of the logic solver                                       0   0   0   0   0
                                                                    •           R.A4.30   Degree of independence from BPCS                                          0   0   0   0   0
                                                                    •           R.A4.31   Demonstration and evidence of prior use                                   0   0   0   0   0
                                                                    •           R.A4.32   Suitability of final elements                                             0   0   0   0   0
                                                      16          PSLG                    Noted
                                                      17          PSLG                    Noted
                                                      18          PSLG                    Noted
             Appendix 4           2, 3, 4, 5, 8
                                                      19          PSLG                    Noted




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             Appendix 4           2, 3, 4, 5, 8

                                                  Lifecycle maintenance
                                                                                      To assure the continued effective operation of an overfill
                                                                                      protection system appropriate maintenance will be required
                                                      20          PSLG
                                                                                      over its lifetime. Key elements in planning such lifecycle
                                                                                      maintenance are:
                                                                                      The principle activity of maintenance is proof testing to identify
                                                                   •        R.A4.33   any dangerous un-revealed failures. See „Proof testing‟ in this             0   0   0   0   0
                                                                                      appendix
                                                                                      System hardware should be inspected to check the
                                                                   •        R.A4.34   mechanical integrity of system components; this may be                      0   0   0   0   0
                                                                                      performed at the same time as the testing
                                                                                      Manufacturers‟ recommended installation and maintenance
                                                                                      activities should be carried out to ensure that all system
                                                                   •        R.A4.35                                                                               0   0   0   0   0
                                                                                      components are correctly installed, in good working order,
                                                                                      lubricated, adjusted and protected
                                                                                      Calibration, where necessary, should be checked when
                                                                   •        R.A4.36                                                                               0   0   0   0   0
                                                                                      systems are tested or more frequently if required
                                                                                      Modifications should be subject to a management of change
                                                                   •        R.A4.37   procedure to check that the safety function is not affected by              0   0   0   0   0
                                                                                      the modification (see section on management)
                                                  Overrides
                                                                                      Overrides should not be used during tank filling. However, if an
                                                                                      override is deemed to be necessary then management control
                                                      21          PSLG
                                                                                      is required. As a minimum the override management controls
                                                                                      should include:
                                                                   •        R.A4.38   override management process                                                 0   0   0   0   0
                                                                                      a method for risk assessing and identifying appropriate
                                                                   •        R.A4.39                                                                               0   0   0   0   0
                                                                                      measures before applying override
                                                                   •        R.A4.40   time limit for the override                                                 0   0   0   0   0
                                                                   •        R.A4.41   authorised signatory                                                        0   0   0   0   0
                                                                   •        R.A4.42   override information handed across shift changes                            0   0   0   0   0
                                                                   •        R,A4.43   time limit for review of an override                                        0   0   0   0   0
                                                                   •        R.A4.44   no output overrides allowed                                                 0   0   0   0   0
                                                                   •        R.A4.45   the status when an override has been applied (eg alarmed)                   0   0   0   0   0
                                                                   •        R.A4.46   an audit process                                                            0   0   0   0   0
                                                  Manual shutdown push-buttons
                                                                                      A manual means should be provided to terminate the transfer
                                                                                      of product into the tank. This does not form part of the
                                                      22          PSLG      R.A4.47                                                                               0   0   0   0   0
                                                                                      automatic tank overfill instrumented function. Periodic testing
                                                                                      of this function is recommended
                                                  Proof testing
                                                      23          PSLG                Noted

                                                                                      All elements of an overfill prevention system should be proof
                                                                                      tested in accordance with the validated arrangements and
                                                      24          PSLG      R.A4.48                                                                               0   0   0   0   0
                                                                                      procedures frequently enough to ensure the specified safety
                                                                                      integrity level is maintained in practice

                                                                                      Proof testing should be end to end so far as is reasonably
                                                                                      practicable including the detector at the liquid interface and the
                                                                                      final element. The test period should be determined by
                                                                                      calculation according to the historical failure rate for each
                                                      25          PSLG      R.A4.49   component or the system and the probability of failure on                   0   0   0   0   0
                                                                                      demand required to achieve the specified SIL. Records of test
                                                                                      results, including faults found and any repairs carried out,
                                                                                      should be kept. Part 1 of BS EN 61511 provides appropriate
                                                                                      guidance on this issue

                                                      26          PSLG                Noted
                                                                                      A proof test or a number of tests should cover, where
                                                      27          PSLG      R.A4.50   practicable, all dangerous failure modes. The test interval will            0   0   0   0   0
                                                                                      be that determined in the PFD calculations
                                                                                      A full function test should be carried out, where practicable.
                                                                                      Where not practicable, and more than one test is used to
                                                      28          PSLG      R.A4.51   demonstrate the function operation, then there should be                    0   0   0   0   0
                                                                                      sufficient overlap such that no parts of the function are not
                                                                                      tested
                                                                                      Proof tests (part or full) should be carried out before and after
                                                                                      any calibration, corrective, remedial or intrusive action carried
                                                      29          PSLG      R.A4.52                                                                               0   0   0   0   0
                                                                                      out. For example, proof tests should be carried out before and
                                                                                      after maintenance
                                                                                      This should be to carry out, where practicable, using wetted
                                                                                      process conditions to operate the sensor. Where this is not
                                                                                      practicable then a simulated test of the sensor (eg radar,
                                                      30          PSLG      R.A4.53                                                                               0   0   0   0   0
                                                                                      vibronics or RF admittance) may be acceptable where it can
                                                                                      be demonstrated, that the wetted contact cannot be prevented
                                                                                      from operating the sensor on genuine high-level condition
                                                                                      Final element (Isolation valves, pump) should be tripped for a
                                                      31          PSLG      R.A4.54                                                                               0   0   0   0   0
                                                                                      full proof test
                                                      32          PSLG      R.A4.55   Testing should cover the testing of any diagnostic features                 0   0   0   0   0
                                                      33          PSLG                Noted




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                                  Documentation
                                                                       The requirements of BS EN 61511 concerning documentation
                                                                       should be met in full for new systems. For existing systems,
                                      34          PSLG       R.A4.56                                                                             0   0   0   0   0
                                                                       the documentation requirements should be complied with as
                                                                       far as is reasonably practicable

                                  Recommended data sources for SIL calculations
                                                                       Where a company does not have their own failure data,
                                                                       paragraph 38 lists typical data sources that could be used to
                                      35          PSLG       R.A4.57                                                                             0   0   0   0   0
                                                                       establish the recommended parameter values for the SIL
                                                                       calculation of SIFs and the architectures of the SISs
                                                                       Users should consider the effect of the installed and process
                                      36          PSLG       R.A4.58                                                                             0   0   0   0   0
                                                                       environment on the data used
                                                                       Manufacturers‟ reliability data can be used where it can be
                                      37          PSLG       R.A4.59   shown to be appropriate and the type, duty and environment                0   0   0   0   0
                                                                       are similar to that specified
                                      38          PSLG                 Refer to requirement R.A4.57
                                      39          PSLG                 Noted
                                      40          PSLG                 Noted
                                      41          PSLG                 Noted
                                      42          PSLG                 Noted
                                      43          PSLG                 Noted
                                      44          PSLG                 Noted
                                      45          PSLG                 Noted
                                      46          PSLG                 Noted
                                      47          PSLG                 Noted
                                      48          PSLG                 Noted
                                      49          PSLG                 Noted
                                      50          PSLG                 Noted
                                      51          PSLG                 Noted
                                      52          PSLG                 Noted




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                                                                            PSLG Appendix 4
                                                             Implementation (Requirements R.A4.1 to R.A4.24)
                                  100%

                                  80%

                                  60%
                                                                                                                                                                                                                                                                                                                Not Implemented
                                  40%
                                                                                                                                                                                                                                                                                                                Partially Implemented
                                  20%                                                                                                                                                                                                                                                                           Implemented

                                   0%




                                         R.A4.1
                                                   R.A4.2
                                                             R.A4.3
                                                                        R.A4.4
                                                                                   R.A4.5
                                                                                               R.A4.6
                                                                                                           R.A4.7
                                                                                                                        R.A4.8
                                                                                                                                     R.A4.9
                                                                                                                                              R.A4.10
                                                                                                                                                        R.A4.11
                                                                                                                                                                  R.A4.12
                                                                                                                                                                            R.A4.13
                                                                                                                                                                                      R.A4.14
                                                                                                                                                                                                R.A4.15
                                                                                                                                                                                                          R.A4.16
                                                                                                                                                                                                                       R.A4.17
                                                                                                                                                                                                                                    R.A4.18
                                                                                                                                                                                                                                                R.A4.19
                                                                                                                                                                                                                                                            R.A4.20
                                                                                                                                                                                                                                                                       R.A4.21
                                                                                                                                                                                                                                                                                  R.A4.22
                                                                                                                                                                                                                                                                                            R.A4.23
                                                                                                                                                                                                                                                                                                      R.A4.24
                                                                         PSLG Appendix 4
                                                         Implementation (Requirements R.A4.25 to R.A4.47)
                                  100%

                                  80%

                                  60%
                                                                                                                                                                                                                                                                                                                Not Implemented
                                  40%
                                                                                                                                                                                                                                                                                                                Partially Implemented
                                  20%                                                                                                                                                                                                                                                                           Implemented

                                   0%




                                                                                                                                                                                                                                                          R,A4.43
                                         R.A4.25
                                                   R.A4.26
                                                              R.A4.27
                                                                         R.A4.28
                                                                                     R.A4.29
                                                                                                 R.A4.30
                                                                                                              R.A4.31
                                                                                                                           R.A4.32
                                                                                                                                        R.A4.33
                                                                                                                                                  R.A4.34
                                                                                                                                                             R.A4.35
                                                                                                                                                                       R.A4.36
                                                                                                                                                                                 R.A4.37
                                                                                                                                                                                            R.A4.38
                                                                                                                                                                                                      R.A4.39
                                                                                                                                                                                                                    R.A4.40
                                                                                                                                                                                                                                 R.A4.41
                                                                                                                                                                                                                                              R.A4.42


                                                                                                                                                                                                                                                                      R.A4.44
                                                                                                                                                                                                                                                                                 R.A4.45
                                                                                                                                                                                                                                                                                            R.A4.46
                                                                                                                                                                                                                                                                                                      R.A4.47
                                                                         PSLG Appendix 4
                                                         Implementation (Requirements R.A4.48 to R.A4.59)
                                  100%

                                  80%

                                  60%
                                                                                                                                                                                                                                                                                                                Not Implemented
                                  40%
                                                                                                                                                                                                                                                                                                                Partially Implemented
                                  20%                                                                                                                                                                                                                                                                           Implemented

                                   0%
                                         R.A4.48
                                                   R.A4.49
                                                             R.A4.50
                                                                        R.A4.51
                                                                                   R.A4.52
                                                                                               R.A4.53
                                                                                                           R.A4.54
                                                                                                                        R.A4.55
                                                                                                                                  R.A4.56
                                                                                                                                              R.A4.57
                                                                                                                                                        R.A4.58
                                                                                                                                                                  R.A4.59




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Appendix 5 - Guidance for the management of operations and human factors


           The following table provides additional analysis in support of MIIB recommendations 6, 7, 9, 10, 19, 23, 24 and 25


           Table guidance:
                   (a) For this table, level of implementation is not gauged against the quantity of individual tanks, but instead implementation of the management system processes as a whole
                       Due to the structure of Appendix 5, Gap Analysis is performed against the summary of each topic, however reference should be made to the preceding paragraphs of the PSLG Report to provide the supporting detail for the
                   (b)
                       requirement
                   (c) Enter '1' in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable

                                                                                                                                                                                                           Level of Implementation
                                                                                                                                                                                                               C%
                                MIIB D&O                           PSLG or BSTG        Requirement                                                                                                             o Fully Meets
                                                                                                                                                                                                                C                Meets
              Section                                Paragraph                                          Requirement                                                       Priority       Not         Partially                                                Reference   Comments
                             Recommendation                         Reference[1]         Number                                                                                                                                Requirement   Not Applicable
                                                                                                                                                                                     Implemented                o
                                                                                                                                                                                                   Implemented mRequirements
                                                                                                                                                                                                               pm                SFAIRP
                                                                                                                                                                                                               lp
                                                          1             PSLG                            Noted
                                                          2             PSLG                            Noted
                                                          3             PSLG                            Noted
                                                          4             PSLG                            Noted
                                                          5             PSLG                            Noted
                                                          6             PSLG                            Noted
                                                   Leadership and a development of a positive safety culture
                                                          7             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                          8             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                          9             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                         10             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                         11             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                         12             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                         13             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                         14             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                         15             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                         16             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                         17             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                         18             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                         19             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                         20             PSLG                            Refer to requirements R.A5.1 to R.A5.4
                                                                                                        Have you ensured that your executive management provides
                                                                                                        effective leadership of process safety to develop a positive,
                                                         21             PSLG                            open, fair and trusting process safety culture? A review of the
                                                                                                        characteristics of their leadership and process safety culture
                                                                                                        should be carried out. The review should:
                                                                           •               R.A5.1       be owned at a senior level within the company                                    0             0             0              0              0
                                                                           •               R.A5.2       be developed as appropriate for each site                                        0             0             0              0              0
                                                                           •               R.A5.3       apply to all parties operating at each site                                      0             0             0              0              0
                                                                                                        lead to the development of action plans to ensure that a
                                                                           •               R.A5.4                                                                                        0             0             0              0              0
                                                                                                        positive process safety culture is developed and maintained
                                                   Process safety management
                                                         22             BSTG                            Refer to requirement R.A5.5
                                                         23             BSTG                            Refer to requirement R.A5.5
                                                         24             BSTG                            Refer to requirement R.A5.5
                                                         25             BSTG                            Refer to requirement R.A5.5
                                                         26             BSTG                            Refer to requirement R.A5.5

                                                                                                        Dutyholders should ensure they have implemented an
                                                                                                        integrated and comprehensive management system that
                                                         27             BSTG               R.A5.5                                                                                        0             0             0              0              0
                                                                                                        systematically and continuously identifies, reduces and
                                                                                                        manages process safety risks, including risk of human failure




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                                                                                                                                                                       Page 47 of 64




                                  Hazard identification, layers of protection, and assessment of their effectiveness
                                      28          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      29          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      30          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      31          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      32          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      33          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      34          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      35          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      36          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      37          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      38          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      39          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      40          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      41          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      42          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      43          BSTG                     Refer to requirements R.A5.6 and R.A5.7
                                      44          BSTG                     Refer to requirements R.A5.6 and R.A5.7

                                                                           Dutyholders should ensure that they have suitable techniques
                                      45          BSTG          R.A5.6     to demonstrate and assess their layers of protection for                0   0   0   0   0
                                                                           prevention and mitigation of major accident scenarios
                                                                           Dutyholders should update their COMAH safety reports in the
                                                                           light of current guidance on extent and severity, and to
                                      46          BSTG          R.A5.7                                                                             0   0   0   0   0
                                                                           describe the process for identification and assessment of
                                                                           control measures
                                  Roles, responsibilities and competence
                                      47          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      48          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      49          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      50          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      51          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      52          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      53          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      54          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      55          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      56          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      57          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      58          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      59          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      60          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      61          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      62          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      63          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      64          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      65          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      66          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      67          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      68          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      69          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      70          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      71          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      72          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      73          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      74          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      75          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      76          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      77          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      78          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      79          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      80          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      81          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      82          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      83          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      84          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      85          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      86          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      87          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      88          PSLG                     Refer to requirements R.A5.8 to R.A5.11
                                      89          PSLG                     Refer to requirements R.A5.8 to R.A5.11




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                                      90           PSLG                  Refer to requirements R.A5.8 to R.A5.11
                                      91           PSLG                  Dutyholders should ensure that they have:
                                                                         clearly identified the roles and responsibilities of all those
                                                    •          R.A5.8    involved in managing, performing, or verifying work in the                  0   0   0   0   0
                                                                         management of major hazards, including contractors
                                                                         in particular, defined the roles and responsibilities of control
                                                    •          R.A5.9    room operators (including in automated systems) in ensuring                 0   0   0   0   0
                                                                         safe fuel transfer operations
                                                                         defined the roles and responsibilities of managers and
                                                    •         R.A5.10    supervisors in monitoring safety-critical aspects of fuel transfer          0   0   0   0   0
                                                                         operations
                                                                         Dutyholders should ensure that they have implemented a
                                                                         competence management system, linked to major accident
                                      92           PSLG       R.A5.11                                                                                0   0   0   0   0
                                                                         risk assessment, to ensure that anyone whose work impacts
                                                                         on the control of major accident hazards is competent to do so

                                  Staffing, shift work arrangements, and working conditions
                                      93           PSLG                  Refer to Requirements R.A5.12 to R.A5.14
                                      94           PSLG                  Refer to Requirements R.A5.12 to R.A5.14
                                      95           PSLG                  Refer to Requirements R.A5.12 to R.A5.14
                                      96           PSLG                  Refer to Requirements R.A5.12 to R.A5.14
                                      97           PSLG                  Refer to Requirement R.A5.12
                                      98           PSLG                  Refer to Requirement R.A5.12
                                      99           PSLG                  Refer to Requirement R.A5.12
                                     100           PSLG                  Refer to Requirement R.A5.12
                                     101           PSLG                  Refer to Requirement R.A5.12
                                     102           PSLG                  Refer to Requirement R.A5.12
                                     103           PSLG                  Refer to Requirement R.A5.12
                                     104           PSLG                  Refer to Requirement R.A5.13
                                     105           PSLG                  Refer to Requirement R.A5.13
                                     106           PSLG                  Refer to Requirement R.A5.13
                                     107           PSLG                  Refer to Requirement R.A5.13
                                     108           PSLG                  Refer to Requirement R.A5.13
                                     109           PSLG                  Refer to Requirement R.A5.13
                                     110           PSLG                  Refer to Requirement R.A5.13
                                     111           PSLG                  Refer to Requirement R.A5.13
                                     112           PSLG                  Refer to Requirement R.A5.14
                                     113           PSLG                  Refer to Requirement R.A5.14
                                     114           PSLG                  Refer to Requirement R.A5.14
                                     115           PSLG                  Refer to Requirement R.A5.14
                                                                         Dutyholders should ensure they can demonstrate that staffing
                                     116           PSLG       R.A5.12    arrangements are adequate to detect, diagnose and recover                   0   0   0   0   0
                                                                         any reasonably credible hazardous scenario
                                                                         Dutyholders should develop a fatigue management plan, to
                                     117           PSLG       R.A5.13    ensure that shift work is adequately managed to control risks               0   0   0   0   0
                                                                         arising from fatigue
                                                                         Dutyholders should review working conditions, in particular for
                                     118           PSLG       R.A5.14                                                                                0   0   0   0   0
                                                                         control room staff, and develop a plan
                                  Shift handover
                                     119           BSTG                  Refer to Requirements R.A5.15 and R.A5.16
                                     120           BSTG                  Refer to Requirements R.A5.15 and R.A5.16
                                     121           BSTG                  Refer to Requirements R.A5.15 and R.A5.16
                                     122           BSTG                  Refer to Requirements R.A5.15 and R.A5.16
                                     123           BSTG                  Refer to Requirements R.A5.15 and R.A5.16
                                     124           BSTG                  Refer to Requirements R.A5.15 and R.A5.16
                                     125           BSTG                  Refer to Requirements R.A5.15 and R.A5.16
                                     126           BSTG                  Refer to Requirements R.A5.15 and R.A5.16
                                     127           BSTG                  Refer to Requirements R.A5.15 and R.A5.16
                                                                         Dutyholders should set and implement arrangements for
                                     128           BSTG       R.A5.15    effective and safe communication at shift and crew change                   0   0   0   0   0
                                                                         handover
                                                                         Top-tier COMAH sites should include a summary of the
                                                                         arrangements for effective and safe communication at shift
                                     129           BSTG       R.A5.16                                                                                0   0   0   0   0
                                                                         and crew change handover in the next revision of the safety
                                                                         report
                                  Organisational change and management of contractors
                                     130           PSLG                  Refer to Requirements R.A5.17 to R.A5.21
                                     131           PSLG                  Refer to Requirements R.A5.17 to R.A5.21
                                     132           PSLG                  Refer to Requirements R.A5.17 to R.A5.21
                                     133           PSLG                  Refer to Requirements R.A5.17 to R.A5.21
                                     134           PSLG                  Refer to Requirements R.A5.17 to R.A5.21
                                     135           PSLG                  Refer to Requirements R.A5.17 to R.A5.21
                                     136           PSLG                  Refer to Requirements R.A5.17 to R.A5.21
                                     137           PSLG                  Refer to Requirements R.A5.17 to R.A5.21




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                                                        138          PSLG                     Refer to Requirements R.A5.17 to R.A5.21
                                                        139          PSLG                     Refer to Requirements R.A5.17 to R.A5.21
                                                        140          PSLG                     Refer to Requirements R.A5.17 to R.A5.21
                                                        141          PSLG                     Refer to Requirement R.A5.17
                                                        142          PSLG                     Refer to Requirement R.A5.17
                                                        143          PSLG                     Refer to Requirement R.A5.19 and R.A5.20
                                                        144          PSLG                     Refer to Requirement R.A5.19 and R.A5.20
                                                        145          PSLG                     Refer to Requirement R.A5.19 and R.A5.20
                                                        146          PSLG                     Refer to Requirement R.A5.19 and R.A5.20
                                                        147          PSLG                     Refer to Requirement R.A5.19 and R.A5.20
                                                        148          PSLG                     Refer to Requirement R.A5.19 and R.A5.20
                                                        149          PSLG                     Refer to Requirement R.A5.19 and R.A5.20
                                                        150          PSLG                     Refer to Requirement R.A5.19 and R.A5.20
                                                        151          PSLG                     Refer to Requirement R.A5.19 and R.A5.20
                                                        152          PSLG                     Refer to Requirement R.A5.19 and R.A5.20
                                                        153          PSLG                     Refer to Requirement R.A5.19 and R.A5.20
                                                        154          PSLG                     Refer to Requirement R.A5.18
                                                        155          PSLG                     Refer to Requirement R.A5.18
                                                        156          PSLG                     Refer to Requirements R.A5.21
                                                        157          PSLG                     Refer to Requirements R.A5.21
                                                        158          PSLG                     Refer to Requirements R.A5.21
                                                        159          PSLG                     Refer to Requirements R.A5.21
                                                        160          PSLG                     Refer to Requirements R.A5.21
                                                        161          PSLG                     Refer to Requirements R.A5.21
                                                        162          PSLG                     Refer to Requirements R.A5.21
                                                                                              Dutyholders should ensure that there is a suitable policy and
                                                        163          PSLG          R.A5.17                                                                              0   0   0   0   0
                                                                                              procedure for managing organisational changes
                                                                                              Dutyholders should ensure that there is a suitable policy and
                                                        164          PSLG          R.A5.18                                                                              0   0   0   0   0
                                                                                              procedure for retention of corporate memory
                                                                                              Dutyholders should ensure that they retain adequate technical
                                                                                              competence and „intelligent customer‟ capability when work
                                                        165          PSLG          R.A5.19                                                                              0   0   0   0   0
                                                                                              impacting on the control of major accident hazards is
                                                                                              outsourced or contractorised
                                                                                              Dutyholders should ensure that suitable arrangements are in
                                                        166          PSLG          R.A5.20                                                                              0   0   0   0   0
                                                                                              place for management and monitoring of contractor activities
                                                                                              Dutyholders should ensure that in addition to retaining
                                                                                              intelligent customer capability, they consider using industry
                          6, 7, 9, 10, 19, 23, 24,      167          PSLG          R.A5.21                                                                              0   0   0   0   0
             Appendix 5                                                                       guidance for interfacing safety management systems where
                                     25                                                       core business is contracted out
                                                        168          PSLG                     Competent Authority Requirement
                                                     Management of plant and process changes
                                                        169          PSLG                     Refer to Requirement R.A5.22
                                                        170          PSLG                     Refer to Requirement R.A5.22
                                                        171          PSLG                     Refer to Requirement R.A5.22
                                                        172          PSLG                     Refer to Requirement R.A5.22
                                                        173          PSLG                     Refer to Requirement R.A5.22
                                                        174          PSLG                     Refer to Requirement R.A5.22
                                                        175          PSLG                     Refer to Requirement R.A5.22
                                                        176          PSLG                     Refer to Requirement R.A5.22
                                                        177          PSLG                     Refer to Requirement R.A5.22
                                                                                              Dutyholders should ensure they have suitable guidance for
                                                                                              their staff about what constitutes a plant or process change,
                                                        178          PSLG          R.A5.22    and that they have suitable arrangements in place for                     0   0   0   0   0
                                                                                              management of the range of permanent, temporary, and
                                                                                              urgent operational changes
                                                     Principles for safe management of fuel transfer
                                                        179          BSTG                     Refer to Requirements R.A5.23 and R.A5.24
                                                        180          BSTG                     Refer to Requirements R.A5.23 and R.A5.24
                                                        181          BSTG                     Refer to Requirements R.A5.23 and R.A5.24
                                                        182          BSTG                     Refer to Requirements R.A5.23 and R.A5.24
                                                                                              Dutyholders involved in the transfer and storage of fuel should
                                                        183          BSTG          R.A5.23    adopt good practice principles for safe management of fuel                0   0   0   0   0
                                                                                              transfer
                                                                                              Dutyholders involved in the transfer and storage of fuel should
                                                        184          BSTG          R.A5.24                                                                              0   0   0   0   0
                                                                                              review „job factors‟ to facilitate safe fuel transfer
                                                     Operational planning for fuel transfer by pipeline
                                                        185          BSTG                     Refer to Requirements R.A5.25 to R.A5.30
                                                        186          BSTG                     Refer to Requirements R.A5.25 to R.A5.31
                                                        187          BSTG                     Refer to Requirements R.A5.25 to R.A5.32
                                                        188          BSTG                     Refer to Requirements R.A5.25 to R.A5.33
                                                        189          BSTG                     Refer to Requirements R.A5.25 to R.A5.34
                                                        190          BSTG                     Refer to Requirements R.A5.25 to R.A5.35




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                                     191          BSTG                     Refer to Requirements R.A5.25 to R.A5.36

                                                                           Dutyholders that are receivers of fuel should develop
                                                                           procedures for successful planning and review them with their
                                     192          BSTG
                                                                           senders and all appropriate intermediates. The stages to be
                                                                           considered in the planning process should include:
                                                                           contract strategy for deliveries of fuel (long-term planning
                                                    •           R.A5.25                                                                                 0   0   0   0   0
                                                                           process)
                                                    •           R.A5.26    development and agreement of monthly movement plans                          0   0   0   0   0
                                                    •           R.A5.27    amendments to monthly plans                                                  0   0   0   0   0
                                                    •           R.A5.28    development of weekly and daily operational plans                            0   0   0   0   0
                                                    •           R.A5.29    amendments to weekly and daily operational plans                             0   0   0   0   0
                                                    •           R.A5.30    in line‟ amendments                                                          0   0   0   0   0
                                  Principles for consignment transfer agreements
                                     193          BSTG                     Refer to Requirements R.A5.31 to R.A5.33
                                     194          BSTG                     Refer to Requirements R.A5.31 to R.A5.33
                                     195          BSTG                     Refer to Requirements R.A5.31 to R.A5.33
                                     196          BSTG                     Refer to Requirements R.A5.31 to R.A5.33
                                     197          BSTG                     Refer to Requirements R.A5.31 to R.A5.33
                                     198          BSTG                     Refer to Requirements R.A5.31 to R.A5.33
                                     199          BSTG                     Refer to Requirements R.A5.31 to R.A5.33
                                     200          BSTG                     Refer to Requirements R.A5.31 to R.A5.33
                                     201          BSTG                     Refer to Requirements R.A5.31 to R.A5.33
                                     202          BSTG                     Refer to Requirements R.A5.31 to R.A5.33
                                     203          BSTG                     Refer to Requirements R.A5.31 to R.A5.33
                                                                           Dutyholders involved in the transfer of fuel by pipeline should
                                     204          BSTG          R.A5.31    develop consignment transfer agreement procedures                            0   0   0   0   0
                                                                           consistent with good practice principles
                                                                           Dutyholders involved in inter-business transfer of fuel by
                                     205          BSTG          R.A5.32    pipeline should agree on the nomenclature to be used for their               0   0   0   0   0
                                                                           product types
                                                                           Dutyholders receiving ship transfers should, for each relevant
                                                                           terminal, carry out a review to ensure compliance with the
                                     206          BSTG          R.A5.33                                                                                 0   0   0   0   0
                                                                           current edition of the International Safety Guide for Oil Tankers
                                                                           and Terminals (ISGOTT)
                                  Procedures for control and monitoring of fuel transfer
                                     207          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     208          BSTG                     Refer to Requirements R.A5.34
                                     209          BSTG                     Refer to Requirements R.A5.34
                                     210          BSTG                     Refer to Requirements R.A5.34
                                     211          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     212          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     213          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     214          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     215          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     216          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     217          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     218          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     219          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     220          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     221          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     222          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     223          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     224          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     225          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     226          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     227          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     228          BSTG                     Refer to Requirements R.A5.34 to R.A5.35
                                     229          BSTG                     Refer to Requirements R.A5.34 to R.A5.35

                                                                           Dutyholders should ensure that written procedures are in
                                     230          BSTG          R.A5.34    place, and consistent with current good practice, for safety-                0   0   0   0   0
                                                                           critical operating activities in the transfer and storage of fuel

                                                                           The above notes on „Procedures for fuel transfer by pipeline‟
                                                                           provide further information on the scope and standards
                                     231          BSTG          R.A5.35                                                                                 0   0   0   0   0
                                                                           expected of the review, which should be conducted against
                                                                           Revitalising procedures or similarly effective guidance

                                  Information and system interfaces for front line staff
                                     232          PSLG                     Refer to Requirements R.A5.36 to R.A5.38
                                     233          PSLG                     Refer to Requirements R.A5.36 to R.A5.38
                                     234          PSLG                     Refer to Requirements R.A5.36 to R.A5.38
                                     235          PSLG                     Refer to Requirements R.A5.36 to R.A5.38




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                                      236         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      237         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      238         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      239         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      240         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      241         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      242         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      243         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      244         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      245         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      246         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      247         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      248         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      249         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      250         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      251         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      252         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                      253         PSLG                      Refer to Requirements R.A5.36 to R.A5.38
                                                                            Dutyholders should ensure that their control room information
                                                                            displays, including human-computer interfaces and alarm
                                      254         PSLG          R.A5.36                                                                              0   0   0   0   0
                                                                            systems, are reviewed in relation to recognised good industry
                                                                            practice
                                                                            Where reasonably practicable, dutyholders should put plans in
                                                                            place to upgrade control room information displays, including
                                      255         PSLG          R.A5.37                                                                              0   0   0   0   0
                                                                            human–computer interfaces and alarm systems, to recognised
                                                                            good industry practice
                                                                            Dutyholders should ensure that modifications or development
                                                                            of new control rooms or HCIs comply with recognised industry
                                      256         PSLG          R.A5.38                                                                              0   0   0   0   0
                                                                            good practice both in their design, and their development and
                                                                            testing
                                  Availability of records for periodic review
                                      257         BSTG                      Refer to Requirement R.A5.39
                                      258         BSTG                      Refer to Requirement R.A5.39

                                                                            Dutyholders should identify those records needed for the
                                                                            periodic review of the effectiveness of control measures, and
                                      259         BSTG          R.A5.39     for the root cause analysis of those incidents and near misses           0   0   0   0   0
                                                                            that could potentially develop into a major incident. The
                                                                            records should be retained for a minimum period of one year

                                  Measuring process safety performance
                                      260         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      261         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      262         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      263         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      264         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      265         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      266         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      267         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      268         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      269         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      270         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      271         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      272         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      273         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      274         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      275         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      276         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      277         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      278         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      279         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      280         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      281         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                      282         BSTG                      Refer to Requirements R.A5.40 to R.A5.41
                                                                            Dutyholders should ensure that a suitable active monitoring
                                      283         BSTG          R.A5.40     programme is in place for key systems and procedures for the             0   0   0   0   0
                                                                            control of major accident hazards
                                                                            Dutyholders should develop an integrated set of leading and
                                      284         BSTG          R.A5.41     lagging performance indicators for effective monitoring of               0   0   0   0   0
                                                                            process safety performance
                                  Investigation of incidents and near misses
                                      285         BSTG                      Refer to Requirements R.A5.42 to R.A5.46
                                      286         BSTG                      Refer to Requirements R.A5.42 to R.A5.46
                                      287         BSTG                      Refer to Requirements R.A5.42 to R.A5.46




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                                     288         BSTG              Refer to Requirements R.A5.42 to R.A5.46
                                     289         BSTG              Refer to Requirements R.A5.42 to R.A5.46
                                     290         BSTG              Refer to Requirements R.A5.42 to R.A5.46

                                     291         BSTG              Dutyholders should ensure they have suitable procedures for:
                                                     •   R.A5.42   identifying incident/near miss potential                                   0   0   0   0   0
                                                     •   R.A5.43   investigating according to the identified potential                        0   0   0   0   0
                                                                   identifying and addressing both immediate and underlying
                                                     •   R.A5.44                                                                              0   0   0   0   0
                                                                   causes
                                                     •   R.A5.45   sharing of lessons learned                                                 0   0   0   0   0
                                                     •   R.A5.46   tracking of remedial actions                                               0   0   0   0   0
                                  Audit and review
                                     292         BSTG              Refer to Requirements R.A5.47 to R.A5.59
                                     293         BSTG              Refer to Requirements R.A5.47 to R.A5.59
                                     294         BSTG              Refer to Requirements R.A5.47 to R.A5.59
                                     295         BSTG              Refer to Requirements R.A5.47 to R.A5.59
                                     296         BSTG              Refer to Requirements R.A5.47 to R.A5.59
                                     297         BSTG              Refer to Requirements R.A5.47 to R.A5.53
                                     298         BSTG              Refer to Requirements R.A5.47 to R.A5.53
                                     299         BSTG              Refer to Requirements R.A5.47 to R.A5.53
                                     300         BSTG              Refer to Requirements R.A5.47 to R.A5.53
                                     301         BSTG              Refer to Requirements R.A5.47 to R.A5.53
                                     302         BSTG              Refer to Requirements R.A5.47 to R.A5.53
                                     303         BSTG              Refer to Requirements R.A5.47 to R.A5.53
                                     304         BSTG              Refer to Requirements R.A5.54 to R.A5.59
                                     305         BSTG              Refer to Requirements R.A5.54 to R.A5.59

                                     306         BSTG              Dutyholders should adopt and implement audit plans defining:
                                                                   the areas and activities to be audited, with a particular focus
                                                     •   R.A5.47                                                                              0   0   0   0   0
                                                                   on process; safety/control of major accident hazards
                                                     •   R.A5.48   the frequency of audits for each area covered                              0   0   0   0   0
                                                     •   R.A5.49   the responsibility for each audit                                          0   0   0   0   0
                                                     •   R.A5.50   the resources and personnel required for each audit                        0   0   0   0   0
                                                     •   R.A5.51   the audit protocols to be used                                             0   0   0   0   0
                                                     •   R.A5.52   the procedures for reporting audit findings                                0   0   0   0   0
                                                     •   R.A5.53   the follow-up procedures, including responsibilities                       0   0   0   0   0
                                                                   Dutyholders should ensure that they have implemented
                                     307         BSTG              suitable arrangements for a formal review of arrangements for
                                                                   control of major accident hazards, including:
                                                                   the areas and activities to be reviewed, with a particular focus
                                                     •   R.A5.54                                                                              0   0   0   0   0
                                                                   on process safety/control of major accident hazards
                                                     •   R.A5.55   the frequency of review (at various levels of the organisation)            0   0   0   0   0
                                                     •   R.A5.56   responsibility for the reviews                                             0   0   0   0   0
                                                     •   R.A5.57   the resources and personnel required for each review                       0   0   0   0   0
                                                     •   R.A5.58   procedures for reporting the review findings                               0   0   0   0   0
                                                                   arrangements for developing and progressing improvement
                                                     •   R.A5.59   plans                                                                      0   0   0   0   0




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                                                                                                                                                                                                                                                      Partially Implemented
                                                                                                        Partially Implemented
                                                                                     Not Implemented




                                                                                                                                                                                                                                   Not Implemented
                                                                                                                                Implemented




                                                                                                                                                                                                                                                                              Implemented
                                                                                                                                                             Implementation (Requirements R.A5.31 to R.A5.59)
                Implementation (Requirements R.A5.1 to R.A5.30)




                                                                                                                                                   R.A5.30                                                                                                                                       R.A5.59




                                                                                                                                                                                                                                                                                                                       Appendix 5 Gap Analysis
                                                                                                                                                   R.A5.29                                                                                                                                       R.A5.58
                                                                                                                                                   R.A5.28                                                                                                                                       R.A5.57
                                                                                                                                                   R.A5.27                                                                                                                                       R.A5.56
                                                                                                                                                   R.A5.26                                                                                                                                       R.A5.55
                                                                                                                                                   R.A5.25                                                                                                                                       R.A5.54
                                                                                                                                                   R.A5.24                                                                                                                                       R.A5.53
                               PSLG Appendix 5




                                                                                                                                                                             PSLG Appendix 5




                                                                                                                                                   R.A5.23                                                                                                                                       R.A5.52
                                                                                                                                                   R.A5.22                                                                                                                                       R.A5.51
                                                                                                                                                   R.A5.21                                                                                                                                       R.A5.50
                                                                                                                                                   R.A5.20                                                                                                                                       R.A5.49
                                                                                                                                                   R.A5.19                                                                                                                                       R.A5.48
                                                                                                                                                   R.A5.18
                                                                                                                                                                                                                                                                                                 R.A5.47
                                                                                                                                                   R.A5.17
                                                                                                                                                                                                                                                                                                 R.A5.46
                                                                                                                                                   R.A5.16
                                                                                                                                                                                                                                                                                                 R.A5.45
                                                                                                                                                   R.A5.15
                                                                                                                                                                                                                                                                                                 R.A5.44
                                                                                                                                                   R.A5.14
                                                                                                                                                                                                                                                                                                 R.A5.43
                                                                                                                                                   R.A5.13
                                                                                                                                                   R.A5.12                                                                                                                                       R.A5.42
                                                                                                                                                   R.A5.11                                                                                                                                       R.A5.41
                                                                                                                                                   R.A5.10                                                                                                                                       R.A5.40
                                                                                                                                                   R.A5.9                                                                                                                                        R.A5.39
                                                                                                                                                   R.A5.8                                                                                                                                        R.A5.38
                                                                                                                                                   R.A5.7                                                                                                                                        R.A5.37
                                                                                                                                                   R.A5.6                                                                                                                                        R.A5.36
                                                                                                                                                   R.A5.5                                                                                                                                        R.A5.35
                                                                                                                                                   R.A5.4                                                                                                                                        R.A5.34
                                                                                                                                                   R.A5.3                                                                                                                                        R.A5.33
                                                                                                                                                   R.A5.2                                                                                                                                        R.A5.32
                                                                                                                                                   R.A5.1                                                                                                                                        R.A5.31
                                                                                                                                20%
                                                                  100%

                                                                         80%

                                                                               60%

                                                                                                       40%



                                                                                                                                              0%




                                                                                                                                                                                                                100%

                                                                                                                                                                                                                       80%

                                                                                                                                                                                                                             60%

                                                                                                                                                                                                                                                     40%

                                                                                                                                                                                                                                                                              20%

                                                                                                                                                                                                                                                                                            0%




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Appendix 6 - Emergency planning guidance


           The following table provides additional analysis in support of MIIB recommendation 12 of the Design and Operations Report & recommendations 1, 3, 4, 5, 6, 7, 8 of the Emergency Preparedness for, Response to and Recovery from Incidents Report


           Table guidance:
                   (a) For this table, level of implementation is not gauged against the quantity of individual tanks, but instead implementation of the management system processes as a whole
                   (b) Enter '1' in the appropriate column: either Not Compliant, Partially Compliant, Fully Meets Requirements, Meets Requirements SFAIRP or Not Applicable

                                                                                                                                                                                                            Level of Implementation
                                                                                                                                                                                                                C%
                               MIIB D&O                          PSLG or BSTG       Requirement                                                                                                                 o Fully Meets
                                                                                                                                                                                                                 C                Meets
              Section                              Paragraph                                         Requirement                                                           Priority       Not         Partially                                                Reference   Comments
                            Recommendation                        Reference[1]        Number                                                                                                                                    Requirement   Not Applicable
                                                                                                                                                                                      Implemented                o
                                                                                                                                                                                                    Implemented mRequirements
                                                                                                                                                                                                                pm                SFAIRP
                                                                                                                                                                                                                lp
                                                  Part 1 Route map to emergency planning guidance
                                                       N/A            BSTG                           Refer to requirement R.A6.77 to R.A6.82
                                                  Part 2 Emergency response arrangements
                                                        1             BSTG                           Noted
                                                  Principles
                                                                                                     All sites in scope should prepare in writing a suitable on-site
                                                                                                     emergency plan as required by the COMAH Regulations. For
                                                        2             BSTG              R.A6.1                                                                                            0             0             0              0              0
                                                                                                     lower-tier COMAH sites the plan should be prepared as part of
                                                                                                     the MAPP

                                                                                                     The emergency plans should consider the response to and
                                                                                                     mitigation of a multiple tank fire following an explosion. The
                                                        3             BSTG              R.A6.2       plan should cover the on-site consequences of such an event                          0             0             0              0              0
                                                                                                     and the assistance available in the form of off-site mitigatory
                                                                                                     actions (reference should be made to HSG191 paragraph 115
                                                                                                     for examples of such off-site mitigatory actions)
                                                                                                     The incident-specific emergency response plans should
                                                                                                     consider fire management requirements in response to, and
                                                                                                     mitigation of, a multiple tank fire. The plan should cover the on-
                                                                                                     site consequences of such an event and the assistance
                                                        4             BSTG              R.A6.3                                                                                            0             0             0              0              0
                                                                                                     available in the form of off-site mitigatory actions. Any plan
                                                                                                     deemed necessary to deal with such an event must be
                                                                                                     capable of operating effectively even in the event of a
                                                                                                     preceding explosion

                                                                                                     The emergency response plan (for a multiple tank fire) should
                                                        5             BSTG              R.A6.4       be tested on a schedule to be agreed with the local CA                               0             0             0              0              0
                                                                                                     inspectors. Site-specific guidance should be produced as to
                                                                                                     what is required to exercise the firefighting arrangements
                                                                                                     During preparation of the on-site plan, the operator should
                                                                                                     consult with the local authority emergency planning unit, the
                                                                                                     Environment Agency (or SEPA) and the local emergency
                                                        6             BSTG              R.A6.5                                                                                            0             0             0              0              0
                                                                                                     services, particularly the local Fire and Rescue Service, on the
                                                                                                     content of the on-site plan to ensure the off-site response
                                                                                                     available is adequate to deal with the incident
                                                                                                     The operator should provide all information (relating to the site)
                                                                                                     required by the COMAH Regulations to the local emergency
                                                        7             BSTG              R.A6.6                                                                                            0             0             0              0              0
                                                                                                     planning unit to allow the off-site plan arrangements to dovetail
                                                                                                     with the on-site plan

                                                                                                     The operator should keep the on-site plan up to date and
                                                        8             BSTG              R.A6.7                                                                                            0             0             0              0              0
                                                                                                     should ensure that any significant changes are communicated
                                                                                                     to the local authority and other concerned agencies

                                                                                                     The operator should ensure the on-site plan is functionally
                                                        9             BSTG              R.A6.8                                                                                            0             0             0              0              0
                                                                                                     tested at least every three years. Site-specific guidance should
                                                                                                     be produced as to what is required to exercise the plan
                                                                                                     Trained, knowledgeable and competent personnel must be
                                                                                                     involved in the exercise of the firefighting plan (the firefighting
                                                                                                     plan being a sub-set and one specific aspect of an overall
                                                                                                     emergency response plan, which specifically covers firefighting
                                                       10             BSTG              R.A6.9                                                                                            0             0             0              0              0
                                                                                                     tactics and equipment etc. needed to deal with a fire, or to
                                                                                                     allow a controlled burn) and in the testing of the on-site plan.
                                                                                                     They must fulfil the tasks they will be expected to fulfil during
                                                                                                     an incident
                                                                                                     Whenever a plan is reviewed/tested or if there has been a
                                                                                                     material change in an aspect of an emergency arrangement,
                                                                                                     the operator should inform all contributors to the plan of any
                                                       11             BSTG             R.A6.10       changes to arrangements and verify that the arrangements are                         0             0             0              0              0
                                                                                                     still adequate. All contributors to the plan should be
                                                                                                     encouraged to inform the site operator proactively of any
                                                                                                     material changes affecting their contribution
                                                  On-site emergency plan




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                                                                          A template for an on-site emergency plan can be found in
                                                                          Appendix 6. For each site, have you completed this template
                                                                          (or equivalent)? This acts as a high-level document providing
                                      12         BSTG          R.A6.11                                                                                 0   0   0   0   0
                                                                          an overview of the site‟s arrangements. Underpinning this
                                                                          document will be a series of detailed plans relating to specific
                                                                          incidents

                                                                          Has the planning activity considered the scenario of a multiple
                                                                          tank fire following an explosion? The magnitude and extent of
                                                                          the Buncefield explosion has been investigated and discussed
                                                                          in the „Buncefield explosion mechanism phase 1: Volumes 1
                                                                          and 2 RR718 HSE Books 2009‟ report, however further
                                      13         BSTG          R.A6.12                                                                                 0   0   0   0   0
                                                                          research is currently ongoing as part of phase 2 of this work.
                                                                          Once accurate information is available this will be
                                                                          disseminated. In the meantime, operators should make a
                                                                          reasonable estimate of the scale of explosion that may occur
                                                                          on their site and plan accordingly. Refer to paragraphs 35-49
                                                                          for guidance on planning emergency arrangements
                                  Firefighting planning and preparation
                                                                          This topic comprises of two elements; firstly, have you
                                                                          considered the actions that should be put in place before an
                                                                          event occurs, and secondly, have you considered the actions
                                      14         BSTG          R.A6.13                                                                                 0   0   0   0   0
                                                                          that should be carried out once an event has occurred? These
                                                                          arrangements should be agreed by all parties involved,
                                                                          including off-site responders
                                      15         BSTG                     Refer to requirement R.A6.14
                                      16         BSTG                     Refer to requirement R.A6.14
                                      17         BSTG                     Refer to requirement R.A6.14
                                      18         BSTG                     Refer to requirement R.A6.14
                                      19         BSTG                     Refer to requirement R.A6.14
                                                                          Such deliberations should form part of the environmental and
                                                                          safety risk assessment carried out by the operator when
                                                                          producing the on-site emergency plan. This should be in
                                      20         BSTG          R.A6.14                                                                                 0   0   0   0   0
                                                                          consultation with the environment agencies, the local
                                                                          authorities, the emergency services (particularly the Fire and
                                                                          Rescue Service) and other stakeholders
                                      21         BSTG                     Noted

                                                                          If it is decided to extinguish the fire then EI 19 Fire precautions
                                                                          at petroleum refineries and bulk storage installations is
                                                                          considered to be „relevant good practice‟ under COMAH, and
                                                                          operators should comply fully with this good practice. New
                                                                          sites should comply fully with EI 19. Existing operators should
                                      22         BSTG          R.A6.15    comply with this relevant good practice where it is reasonably               0   0   0   0   0
                                                                          practicable to do so. In effect, this means that existing
                                                                          operators should undertake a gap analysis between the
                                                                          requirements in this code and those measures present on site.
                                                                          Any measures not in place but which are specified in the code
                                                                          should be implemented if it is reasonably practicable to do so


                                                                          The following (paragraphs 24-33) is a list of the steps needed
                                                                          to plan for tank related fire and emergency scenarios, which
                                                                          have been drawn from EI 19 to aid operators. It states the
                                      23         BSTG
                                                                          questions that need to be considered and points to the
                                                                          relevant section in the code for further detail.
                                                                          Refer to requirements R.A6.16 to R.A6.25
                                                                          Step 1 Determine the worst-case scenario for the fire event.
                                                                          For fuel depots this is considered to be either the largest tank
                                                                          in a single bund, or the largest group of tanks in a single bund.
                                      24         BSTG          R.A6.16    If the plan adequately covers the resources for the worst-case               0   0   0   0   0
                                                                          scenario, it can be considered capable of dealing with lesser
                                                                          similar events, eg fires in smaller tanks etc. (EI 19 sections
                                                                          2.5–2.7, section 3.2.)




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                                  25   BSTG   R.A6.17   Step 2 Assume a full surface tank fire and bund fire                      0   0   0   0   0

                                                        Step 3 Determine the radiant heat hazard ranges using
                                                        appropriate consequence modelling (and including weather
                                                        factors) to determine safe locations for the firefighting
                                                        resources deployment. (EI 19 section 2.6.) This also
                                                        determines the size of monitor necessary to achieve the
                                                        required throw to reach the tank roof. The actual distance from
                                                        the monitor to the involved tank only depends on the effective
                                  26   BSTG   R.A6.18   reach of the monitor used. It is important to determine the wind          0   0   0   0   0
                                                        direction because the monitor should be placed to allow the
                                                        wind to carry the foam to the fire. Changes in wind direction
                                                        will have to be accommodated in the plan. Fire monitor
                                                        performance is available from the manufacturer, but be aware
                                                        the figures quoted will relate to best performance. Operators
                                                        should base their plan on perhaps 20% reduction in
                                                        performance to counter this, and then test it appropriately to
                                                        prove the effectiveness

                                  27   BSTG   R.A6.19   Step 4 Determine the amount of foam concentrate and water                 0   0   0   0   0
                                                        necessary to firefight the worst-case scenario. (EI 19 Annex D.)
                                                        Step 5 Assess whether the necessary foam stocks are
                                                        available on site. If not, consider how quickly these stocks can
                                                        be brought to the site and by whom – what arrangements have
                                                        been made with the Fire and Rescue Service, foam
                                  28   BSTG   R.A6.20   manufacturers and/or neighbouring sites. Ideally operators                0   0   0   0   0
                                                        should have the means and quantity of foam on site to cope
                                                        with a fire in the largest bund immediately. Operators will also
                                                        need to consider how foam stocks can be transported around
                                                        the site
                                                        Step 6 Is the water supply sufficient in terms of quantity,
                                                        pressure and flow rate? (EI 19 Annex D6.) The pressure
                                                        required is back-calculated starting at the monitor. Most
                                                        monitors require 7 to 9 bar, then add in the frictional losses
                                                        from the monitor to the pumps. Operators need to remember
                                  29   BSTG   R.A6.21   that the system demands will not just be at the monitors; water           0   0   0   0   0
                                                        drawn from any fixed system applications and cooling streams
                                                        will also need to be considered. It is important to determine the
                                                        required volumes and pressures used. Dynamic system
                                                        demand testing will provide the evidence that the system can
                                                        deliver the required resources

                                                        Step 7 If high volume pumps or high pressure pumps are
                                                        necessary to achieve the required water capacities, where will
                                                        these be provided from and how long will they take to arrive
                                                        and be set up? The possibilities include fixed firewater pumps
                                  30   BSTG   R.A6.22   at the site, mobile firewater pumps purchased by the site, pre-           0   0   0   0   0
                                                        arranged mutual aid from other nearby facilities or the Fire and
                                                        Rescue Service. All resources will need to be considered in
                                                        the plan so they can be logistically arranged for relay pumping
                                                        purposes. Remember to build in redundancy to cover for the
                                                        nearest resources being already in use or in repair etc
                                                        Step 8 What means are there for delivering the required
                                                        foam/water to the fire? How many and what size monitors are
                                                        necessary? This is determined by the area at risk and the
                                  31   BSTG   R.A6.23                                                                             0   0   0   0   0
                                                        application rates required to secure and extinguish this risk.
                                                        Remember the need for compatibility where hardware is
                                                        brought from a variety of sources

                                                        Step 9 How much and what size and pressure rating of hose
                                                        is required? Where will this quantity of hose be obtained from?
                                  32   BSTG   R.A6.24   The size and quantity of hose required on the flow rate,                  0   0   0   0   0
                                                        pressure and distance from the water supply. The greater the
                                                        flow rate, pressure or distance from the water supply, the
                                                        larger the diameter and pressure rating of the hose needed

                                                        Step 10 How will any firewater run-off be dealt with? Hose
                                                        and pumps will be necessary to transfer firewater run-off from
                                  33   BSTG   R.A6.25   the bund to another bund or catchment area. Alternatives                  0   0   0   0   0
                                                        include purpose-built bund overflows to a remote tertiary
                                                        containment system, or increasing the capacity of an existing
                                                        bund. Transfer could be by pumps or via gravity flow




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                                       Firefighting incident management
                                           34         BSTG                   The following actions should be carried out:
                                                                             Operators should contact the local authority Fire and Rescue
                                                                             Service in accordance with the pre-incident management
                                                       •           R.A6.26                                                                                0   0   0   0   0
                                                                             agreement between the operator and the Fire and Rescue
                                                                             Service
                                                                             The local authority Fire and Rescue Service should
                                                       •           R.A6.27   rendezvous at a predetermined holding point for the company                  0   0   0   0   0
                                                                             concerned

                                                                             Fire and Rescue Service Incident Commander should formally
                                                                             liaise with the company on-scene commander (and site fire
                                                                             officer if applicable), obtaining information regarding the
                                                       •           R.A6.28                                                                                0   0   0   0   0
                                                                             incident, whether or not people are involved, the resources in
                                                                             place and the hazards and risks associated with the particular
                                                                             event. These persons will form the incident control team (ICT)
                                                                             along with any others required by the circumstances
                                                                             Establish immediate priorities and the potential for escalation.
                                                                             Local scenario-specific emergency response plans (ERPs) for
                                                       •           R.A6.29                                                                                0   0   0   0   0
                                                                             the plant or area should at this time be made available to, and
                                                                             be used by, the ICT
                                                                             Lines of supervisory authority and the means of
                                                       •           R.A6.30   communication should be clearly established within the ERPs                  0   0   0   0   0
                                                                             to assist in effective reporting and incident control
                                                                             The ICT must ensure the safety of all personnel. This team
                                                                             should have:
                                                                             ○ completed a dynamic risk assessment (DRA) and if there
                                                                             has been time, a written record needs to be handed to the Fire
                                                                             and Rescue Service IC on their arrival;
                                                       •           R.A6.31   ○ arranged for the DRA to be recorded and constantly                         0   0   0   0   0
                                                                             reviewed. The DRA also needs to be communicated and the
                                                                             tactical mode declared, implemented and recorded;
                                                                             ○ ensured that safety officers are appointed with their
                                                                             responsibilities clearly established




                                                                             The ICT should also:
                                                                             ○ establish the incident command position;
                                                                             ○ determine the operational objectives and the incident plan,
                                                                             including tactical and strategic considerations;
                                                                             ○ identify from the ERPs, the equipment, material and
                                                                             resources required, coordinating effort into sourcing equipment
                                                                             and materials to the incident;
                                                                             ○ obtain additional support/equipment/resources if required
                                                       •           R.A6.32   (via mutual aid partnerships if in existence);                               0   0   0   0   0
                                                                             ○ implement the mutually agreed strategy by bringing
                                                                             resources on-site from the rendezvous point at this stage;
                                                                             ○ monitor and review the implemented plan for ongoing
                                                                             potential hazards and the continued effectiveness of the plan
                                                                             at predetermined intervals. If the plan cannot be followed or if
                                                                             a deviation is required from it at any time then a DRA must be
                                                                             carried out, communicated to all concerned and recorded;
                                                                             ○ establish welfare arrangements for all at incident scene; and
                                                                             ○ ensure that media issues are addressed

                                       Guidance for planning emergency arrangements
                                                                             The event that operators should plan for, with respect to
                                                                             emergency arrangements, is that of a multiple tank fire
                                           35         BSTG         R.A6.33                                                                                0   0   0   0   0
                                                                             following an explosion. Are emergency arrangements capable
                                                                             of operating effectively following such an event?
                                           36         BSTG                   Noted
                                                                             Have you considered the typical effects of over-pressure when
                                                                             planning emergency arrangements? The effects of over-
                                           37         BSTG         R.A6.34                                                                                0   0   0   0   0
                                                                             pressure are not exact and sensible interpretation erring on the
                                                                             side of caution should be employed


             Appendix 6           12                                         At Buncefield, the damage from the vapour cloud explosion
                                                                             (VCE) occurred out to approximately 250 m from the tank wall
                                                                             of the tank that was overfilled (Note: the distances are radii
                                                                             from the tank wall as this is the location of the overflow. Bund
                                                                             layouts can vary significantly, so measuring the distances from
                                                                             the bund wall would not provide a consistent approach). While
                                                                             the behaviour of vapour clouds can be directional, the
                                           38         BSTG         R.A6.35   movement of the cloud is heavily dependant on factors such                   0   0   0   0   0
                                                                             as site topography, degree of congestion and weather
                                                                             conditions. Attempting to predict the travel of a potential
                                                                             vapour cloud with the necessary level of reliability in view of its
                                                                             potential effects is not a practical proposition with existing
                                                                             knowledge. Hence the effects of the explosion should be
                                                                             considered as being 250 m from the tank wall, assuming that
                                                                             the cloud could travel in any direction




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                                  39   BSTG             Noted
                                  40   BSTG             Noted
                                                        Dutyholders should carry out individual site assessments
                                  41   BSTG
                                                        based on the following methodology:
                                                        identify the critical equipment and resources necessary to
                                        •     R.A6.36   respond to a credible incident scenario following a VCE.                     0   0   0   0   0
                                                        Typically this would be a multi-tank fire initiated by the VCE
                                                        for those resources identified, plot the location on a site plan of
                                        •     R.A6.37   those that are installed at the facility or provided as part of a            0   0   0   0   0
                                                        mutual aid or common user scheme
                                                        apply the over-pressure area of 250 m radius from the tank
                                                        wall (Note: the distances are radii from the tank wall as this is
                                                        the location of the overflow. Bund layouts can vary
                                                        significantly, so measuring the distances from the bund wall
                                        •     R.A6.38                                                                                0   0   0   0   0
                                                        would not provide a consistent approach) (note: it is possible
                                                        that this area will cover the whole site and may extend to
                                                        include areas where mutual aid or common user equipment is
                                                        held)
                                                        the effects of blast over-pressure should be applied to all items
                                                        of critical equipment and resources within the designated area.
                                        •     R.A6.39   Decide whether the equipment or resource would remain                        0   0   0   0   0
                                                        usable or not (note: apply the precautionary principle and if in
                                                        doubt treat as unusable)




                                                        for each item of critical equipment or resource that is likely to
                                                        be damaged in the event of a VCE, the facility should consider:
                                                        ○ moving the equipment outside the area likely to be affected;
                                                        ○ duplicating the equipment by providing an alternative outside
                                                        the area;
                                                        ○ providing protection in the form of blast shielding (note: if site
                                                        power and control systems are lost there may be little
                                                        advantage in protecting pumps or other equipment that cannot
                                        •     R.A6.40   be used);                                                                    0   0   0   0   0
                                                        ○ reducing the consequence of the damage. For example, if a
                                                        fire pump is lost in the blast, but an underground hydrant
                                                        system is still usable, then additional inlet points for mobile
                                                        pumps from open water could restore operation of the system;
                                                        ○ using off-site emergency equipment and resources, eg by
                                                        providing mobile equipment from the Fire and Rescue Service
                                                        or mutual aid scheme;
                                                        ○ for access and egress points used by the emergency
                                                        services, provide alternate routes in case the main roads and
                                                        gates are affected by the incident

                                                        The results of the assessment should be documented and
                                                        incorporated into the on-site and off-site emergency plans.
                                                        These results should be used to plan the emergency
                                                        arrangements for the site. Any dependency on mutual aid or
                                                        external resources should be agreed, and these arrangements                      0   0   0   0
                                  42   BSTG   R.A6.41                                                                                0
                                                        regularly tested and reviewed. The template for completion of
                                                        the on-site plan for COMAH sites is provided in part 1 of this
                                                        appendix. The template can be completed and used as the
                                                        basis for the on-site emergency plan. This approach may be of
                                                        benefit to lower-tier COMAH sites
                                  43   BSTG             Noted
                                                        Each emergency plan should be specific to an individual site.
                                                        Dutyholders should review their on-site emergency plan to
                                  44   BSTG   R.A6.42                                                                                0   0   0   0   0
                                                        ensure that there are enough people with the right training and
                                                        competence to deal with an emergency
                                  45   BSTG             The following factors should be considered
                                                        Have all the risks been identified for the site with respect to the              0   0   0   0
                                        •     R.A6.43                                                                                0
                                                        credible emergency scenarios?
                                        •     R.A6.44                                                                                0   0   0   0   0
                                                        Have response plans been developed to deal with these risks?
                                                        Do the response plans identify actions and resources needed
                                        •     R.A6.45                                                                                0   0   0   0   0
                                                        especially people?
                                                        Do the response plans identify escalation measures including
                                        •     R.A6.46                                                                                0   0   0   0   0
                                                        the resources needed to action the plan?
                                                        Are there sufficient resources to action these plans? This can
                                                        be done by a gap analysis of the staff and other resources.
                                                        Consider the following:
                                                        ○ Time: Can staff be released in an emergency? Have they
                                                        time to do all that they need to under the plan?
                                                        ○ Tools: Do staff have access to the correct
                                        •     R.A6.47   equipment/information?                                                       0   0   0   0   0
                                                        ○ Ability: Can they use the equipment/understand the
                                                        information and do what they need to properly?
                                                        ○ Sustainability (for longer duration scenarios): Are suitably
                                                        competent relief staff available to maintain the emergency
                                                        plan over a realistic response period.




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                                  46   BSTG             Refer to requirements R.A6.43 to R.A6.47
                                                        Each member of staff should be competent to implement the
                                                        emergency plan. Competency should be checked during
                                                        training and testing of emergency plans. Can each person do
                                                        what they need to – if not train and evaluate? Refresher
                                  47   BSTG   R.A6.48                                                                                0   0   0   0   0
                                                        training is vital to maintain competence and there needs to be
                                                        realistic testing to ensure that staff demonstrate competence.
                                                        Dutyholders should record all reviews, analysis, training and
                                                        testing

                                                        Table 2 is derived from the Energy Institute guidance in EI 19.
                                                        It provides an example of the competencies required by a
                                                        typical emergency response team member. The areas where
                                  48   BSTG   R.A6.49                                                                                0   0   0   0   0
                                                        competencies are necessary have been identified by analysing
                                                        the tasks that the person will fulfil as their part in the plan. The
                                                        same process can be applied to all tasks and the
                                                        competencies required identified
                                                        It is essential to consider tasks such as drainage, firewater
                                  49   BSTG   R.A6.50   management, pollution control and site recovery when                         0   0   0   0   0
                                                        deciding on training and competencies
                                                        Dutyholders should evaluate the siting and protection of
                                                        emergency response facilities, and put in place contingency
                                                        arrangements either on or off site in the event of failure. This
                                  50   BSTG   R.A6.51                                                                                0   0   0   0   0
                                                        should include identifying and establishing an alternative
                                                        emergency control with a duplicate set of plans and technical
                                                        information
                                  51   BSTG             Noted

                                                        Fire protection and other critical emergency equipment and
                                                        resources should be located in non-hazardous areas so far as
                                                        is reasonably practicable. Dutyholders should consider the
                                                        consequence of a major incident to determine where to locate
                                                        such items as they may constitute sources of ignition. Locate
                                  52   BSTG   R.A6.52                                                                                0   0   0   0   0
                                                        equipment and resources to enable access at all times during
                                                        incidents. They should be capable of functioning despite the
                                                        effects of fire and explosion, for example, fire pumps should
                                                        be located at a safe distance away from any possible
                                                        explosion/fire consequences

                                  53   BSTG             Refer to requirements R.A6.53 to R.A6.57
                                                        Step 1 Dutyholders should consider and list worst-case events
                                                        in terms of:

                                                        • hazard distances;
                                                        • over-pressures;
                                                        • radiant heat levels;
                                                        • potential for missile generation.
                                  54   BSTG   R.A6.53                                                                                0   0   0   0   0
                                                        The emphasis should be on the effects of „worst-case‟ incident
                                                        scenarios, as these identify the most vulnerable emergency
                                                        equipment and resources. However, dutyholders should
                                                        consider specific issues that may arise from lesser incidents,
                                                        eg different types of foam concentrate, critical emergency
                                                        equipment located near relatively low-hazard operational
                                                        areas etc.

                                                        Step 2 Identify critical emergency response equipment and
                                                        resources vulnerable to the worst-case scenarios. Start by
                                                        reviewing the list to identify critical equipment and resources
                                  55   BSTG   R.A6.54                                                                                0   0   0   0   0
                                                        that may be vulnerable in a major incident. Detailed site plans
                                                        with significant hazard ranges marked on them may be used
                                                        as an aid
                                                        The templates in part 3 of this appendix provide a detailed list
                                                        of emergency response equipment and resources, drawn from
                                                        industry guidance, codes, reports of the Buncefield Standards
                                                        Task Group (BSTG) and the MIIB. Relevant issues in
                                  56   BSTG   R.A6.55   Buncefield: Hertfordshire Fire and Rescue Service‟s Review of                0   0   0   0   0
                                                        the Fire Response have also been included. The list should not
                                                        be seen as exhaustive. Dutyholders should also consider
                                                        unique features of their own sites and emergency response
                                                        arrangements
                                                        Step 3 In reviewing critical equipment and resources consider
                                                        all necessary measures to manage the incident, ie drainage,
                                                        firewater management, power supply, control centres,
                                                        communications etc. Consider the requirements to deal with
                                  57   BSTG   R.A6.56                                                                                0   0   0   0   0
                                                        the more likely scenarios, not just the high impact–low
                                                        probability events. Assess what the likely level of damage
                                                        would be to vulnerable equipment and resources, in terms of
                                                        Table 3




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                                                        Step 4 Where there are gaps against current good practice,
                                                        as an alternative to upgrading the on-site facilities, dutyholders
                                                        may consider other contingency arrangements, for example,
                                                        relocating mobile equipment and resources. Where further
                                                        measures are necessary to provide an alternative to fixed
                                  58   BSTG   R.A6.57                                                                                0   0   0   0   0
                                                        equipment, it may be more appropriate to identify what
                                                        external assistance may be available to provide sufficient
                                                        contingency (eg local emergency services, mutual aid
                                                        schemes). Emergency plans should be revised to take into
                                                        account any possible loss of critical equipment and resources

                                  59   BSTG             Additional measures to consider include:
                                         •    R.A6.58   reducing the risk of the incident at source                                  0   0   0   0   0
                                                        increased redundancy, eg alternative fire pumps in different
                                        •     R.A6.59                                                                                0   0   0   0   0
                                                        locations
                                        •     R.A6.60   increasing supplies                                                          0   0   0   0   0
                                        •     R.A6.61   relocating resources                                                         0   0   0   0   0
                                        •     R.A6.62   splitting supplies into different locations                                  0   0   0   0   0
                                        •     R.A6.63   manual back up for automated systems                                         0   0   0   0   0
                                        •     R.A6.64   resources that can be brought in by the emergency services                   0   0   0   0   0
                                        •     R.A6.65   mutual aid schemes                                                           0   0   0   0   0
                                                        contracts/agreements with specialist companies who can
                                        •     R.A6.66                                                                                0   0   0   0   0
                                                        provide additional resources within a reasonable time period
                                                        duplicate copies of emergency information (hazard data, site
                                        •     R.A6.67   plans, etc). Information kept in different locations (on and off             0   0   0   0   0
                                                        site) and different formats (hard copy and electronic)
                                        •     R.A6.68   alternative emergency control centre off site                                0   0   0   0   0
                                                        alternative emergency response tactics (eg consideration of
                                        •     R.A6.69                                                                                0   0   0   0   0
                                                        controlled burn if firewater supplies are lost)
                                        •     R.A6.70   revision of emergency plans, tactics and strategies                          0   0   0   0   0

                                        •     R.A6.71                                                                                0   0   0   0   0
                                                        exercises to test the adequacy of contingency arrangements
                                                        Should the dutyholder rely on off-site fire and rescue services,
                                  60   BSTG   R.A6.72   the on site plan should clearly demonstrate that there are                   0   0   0   0   0
                                                        adequate arrangements in place between the parties

                                  61   BSTG             Noted

                                                        Part 3 of this appendix provides a template for auditing the test
                                                        of an off-site emergency plan. It can also be used as a basis
                                                        for identifying those parts of an on-site emergency plan that
                                  62   BSTG
                                                        rely on off-site responders. The following are examples of
                                                        areas where this is likely: (The effectiveness of these
                                                        arrangements should be exercised and evaluated)
                                                        Reliable relations between dutyholders, the emergency
                                                        services and other responders (eg the Environment
                                        •     R.A6.73   Agency/HPA) are critical in the successful management of                     0   0   0   0   0
                                                        major emergencies and there should be scheduled liaison
                                                        meetings held
                                                        if the external Fire and Rescue Service supplements on-site
                                        •     R.A6.74   fire teams, the level of training and compatibility of breathing             0   0   0   0   0
                                                        apparatus and firefighting equipment must be established;
                                                        where a fire plan has been produced by the Fire and Rescue
                                        •     R.A6.75   Service for specific COMAH sites including rendezvous points                 0   0   0   0   0
                                                        and alternative access to the site
                                                        When all instances of reliance on off-site responders have
                                                        been identified, the adequacy of the joint arrangements should
                                  63   BSTG   R.A6.76   be demonstrated. Part 3 of this appendix can be used to audit                0   0   0   0   0
                                                        a test of the emergency plan. Assumptions should be validated
                                                        and emergency plans reviewed and updated as appropriate
                                                        Part 1 of this appendix clearly defines the arrangements
                                                        between the dutyholder and the Fire and Rescue Service,
                                  64   BSTG
                                                        have these been addressed? These include but are not limited
                                                        to:
                                        •     R.A6.77   raising an alert and initial information                                     0   0   0   0   0
                                                        access points, suitable hard-standings for vehicles and
                                        •     R.A6.78                                                                                0   0   0   0   0
                                                        rendezvous points
                                                        site information (water supplies, foam stocks, equipment
                                        •     R.A6.79   details, drainage information, containment capability,                       0   0   0   0   0
                                                        evacuation arrangements, etc)

                                        •     R.A6.80   pre-fire plans clearly indicating firefighting capability, resources         0   0   0   0   0
                                                        available and firewater management arrangements
                                                        Dutyholders should review their arrangements to communicate
                                                        with people and establishments likely to be affected by a
                                  65   BSTG   R.A6.81   major accident to ensure that this information takes account of              0   0   0   0   0
                                                        any additional major accident scenarios resulting from, for
                                                        example, a large flammable vapour cloud

                                  66   BSTG             Noted




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                                  Part 3 Example templates supporting the guidance for recommendations 11 and 12
                                      1         BSTG                   Noted
                                                                       The operator must consult with off-site agencies, and it is
                                                                       advised that the plan is formulated in consultation with the
                                                                       agencies (local authority emergency planners, Fire and
                                      2         BSTG         R.A6.82   Rescue Service, environment agencies, HSE, police and                       0   0   0   0   0
                                                                       ambulance) as appropriate during the preparation of the plan.
                                                                       It is advised that consultation starts at an early stage to allow
                                                                       for full involvement with the off-site agencies




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Page 62 of 65




                                                                                                                                                                                                                                                      Partially Implemented
                                                                                                        Partially Implemented




                                                                                                                                                                                                                                                                                                                                                                                                    Partially Implemented
                                                                                     Not Implemented




                                                                                                                                                                                                                                   Not Implemented




                                                                                                                                                                                                                                                                                                                                                                                 Not Implemented
                                                                                                                                Implemented




                                                                                                                                                                                                                                                                              Implemented




                                                                                                                                                                                                                                                                                                                                                                                                                            Implemented
                                                                                                                                                             Implementation (Requirements R.A6.33 to R.A6.57)




                                                                                                                                                                                                                                                                                                           Implementation (Requirements R.A6.58 to R.A6.82)
                Implementation (Requirements R.A6.1 to R.A6.32)




                                                                                                                                                   R.A6.32                                                                                                                                                                                                                                                                                     R.A6.82
                                                                                                                                                   R.A6.31
                                                                                                                                                                                                                                                                                                                                                                                                                                               R.A6.81
                                                                                                                                                   R.A6.30
                                                                                                                                                                                                                                                                                                 R.A6.57                                                                                                                                       R.A6.80
                                                                                                                                                   R.A6.29
                                                                                                                                                   R.A6.28                                                                                                                                       R.A6.56                                                                                                                                       R.A6.79




                                                                                                                                                                                                                                                                                                                                                                                                                                                                     Appendix 6 Gap Analysis
                                                                                                                                                   R.A6.27                                                                                                                                       R.A6.55
                                                                                                                                                                                                                                                                                                                                                                                                                                               R.A6.78
                                                                                                                                                   R.A6.26                                                                                                                                       R.A6.54
                                                                                                                                                                                                                                                                                                                                                                                                                                               R.A6.77
                                                                                                                                                   R.A6.25                                                                                                                                       R.A6.53
                                                                                                                                                                                                                                                                                                                                                                                                                                               R.A6.76
                                                                                                                                                                             PSLG Appendix 6




                                                                                                                                                                                                                                                                                                                           PSLG Appendix 6
                               PSLG Appendix 6




                                                                                                                                                   R.A6.24
                                                                                                                                                                                                                                                                                                 R.A6.52
                                                                                                                                                   R.A6.23                                                                                                                                                                                                                                                                                     R.A6.75
                                                                                                                                                                                                                                                                                                 R.A6.51
                                                                                                                                                   R.A6.22                                                                                                                                                                                                                                                                                     R.A6.74
                                                                                                                                                   R.A6.21                                                                                                                                       R.A6.50
                                                                                                                                                   R.A6.20                                                                                                                                       R.A6.49                                                                                                                                       R.A6.73
                                                                                                                                                   R.A6.19                                                                                                                                       R.A6.48                                                                                                                                       R.A6.72
                                                                                                                                                   R.A6.18                                                                                                                                       R.A6.47                                                                                                                                       R.A6.71
                                                                                                                                                   R.A6.17
                                                                                                                                                                                                                                                                                                 R.A6.46                                                                                                                                       R.A6.70
                                                                                                                                                   R.A6.16
                                                                                                                                                   R.A6.15                                                                                                                                       R.A6.45                                                                                                                                       R.A6.69
                                                                                                                                                   R.A6.14                                                                                                                                       R.A6.44                                                                                                                                       R.A6.68
                                                                                                                                                   R.A6.13                                                                                                                                       R.A6.43                                                                                                                                       R.A6.67
                                                                                                                                                   R.A6.12                                                                                                                                       R.A6.42
                                                                                                                                                   R.A6.11                                                                                                                                                                                                                                                                                     R.A6.66
                                                                                                                                                                                                                                                                                                 R.A6.41
                                                                                                                                                   R.A6.10                                                                                                                                                                                                                                                                                     R.A6.65
                                                                                                                                                                                                                                                                                                 R.A6.40
                                                                                                                                                   R.A6.9                                                                                                                                                                                                                                                                                      R.A6.64
                                                                                                                                                   R.A6.8                                                                                                                                        R.A6.39
                                                                                                                                                                                                                                                                                                                                                                                                                                               R.A6.63
                                                                                                                                                   R.A6.7                                                                                                                                        R.A6.38
                                                                                                                                                   R.A6.6                                                                                                                                                                                                                                                                                      R.A6.62
                                                                                                                                                                                                                                                                                                 R.A6.37
                                                                                                                                                   R.A6.5                                                                                                                                        R.A6.36                                                                                                                                       R.A6.61
                                                                                                                                                   R.A6.4                                                                                                                                                                                                                                                                                      R.A6.60
                                                                                                                                                                                                                                                                                                 R.A6.35
                                                                                                                                                   R.A6.3
                                                                                                                                                                                                                                                                                                 R.A6.34                                                                                                                                       R.A6.59
                                                                                                                                                   R.A6.2
                                                                                                                                                   R.A6.1                                                                                                                                        R.A6.33                                                                                                                                       R.A6.58
                                                                  100%




                                                                                                                                              0%




                                                                                                                                                                                                                100%




                                                                                                                                                                                                                                                                                            0%




                                                                                                                                                                                                                                                                                                                                                              100%




                                                                                                                                                                                                                                                                                                                                                                                                                                          0%
                                                                                                       40%




                                                                                                                                                                                                                                                                                                                                                                     80%
                                                                         80%

                                                                               60%



                                                                                                                                20%




                                                                                                                                                                                                                       80%

                                                                                                                                                                                                                             60%

                                                                                                                                                                                                                                                     40%

                                                                                                                                                                                                                                                                              20%




                                                                                                                                                                                                                                                                                                                                                                           60%

                                                                                                                                                                                                                                                                                                                                                                                                   40%

                                                                                                                                                                                                                                                                                                                                                                                                                            20%




                                                                                                                                                                                                                                                                                                                                                                                                                                                         Process Safety Leadership Group
                                                                                                                                                                                                                                                                                                                                                                                                                                                         Final Report Gap Analysis
                                                                                              Page 63 of 65



Revision History
         Revision Section                       Description                     Date         Change By
           0.0   All              Tool Created                           #################      PD
                                  PSLN, MHWG and LAC Comments
            0.1   All                                                    #################      PD
                                  Incorporated
                                  Added column for proposed completion
            0.2   All             date and explanatory text              #################      PD




Process Safety Leadership Group
Final Report Gap Analysis                       Revision History                             Revision: 0.1

								
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