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					CONTROL OF MAJOR ACCIDENT HAZARDS (COMAH)



Discussion for IOSH Merseyside Branch
11 January 2011


Mike Brown
HSSE Manager
Stanlow Manufacturing Complex
Contents


   Background
   Who falls under the COMAH Regulations?
   Requirements of Top Tier sites
   Safety Report Structure
   ALARP demonstration
   How do we prevent Major Accidents at Stanlow?
   Assessment and On-going Monitoring
Content


   Background
   Who falls under the COMAH Regulations?
   Requirements of Top Tier sites
   Safety Report Structure
   ALARP demonstration
   How do we prevent Major Accidents at Stanlow?
   Assessment and On-going Monitoring
What is a ‚Major Accident‛

   A ‚major accident‛ means an occurrence (including in particular, a
    major emission, fire or explosion) resulting from uncontrolled
    developments in the course of the operation of any establishment and
    leading to serious danger to human health or the environment,
    immediate or delayed, inside or outside the establishment, and involving
    one or more dangerous substances
   The aim of the COMAH Regs is to prevent major accidents involving
    dangerous substances and limit the consequences to people and the
    environment of any accidents which do occur
Briefly, the Legislative Background ….


   Major accidents in 1970s, e.g. Flixborough, Seveso
        Seveso Directive (82/501/EEC)
        UK: CIMAH Regulations 1984
   More accidents: Bhopal, Basle
         CIMAH Regulations revised in 1988 & 1990
   Seveso II Directive (96/82/EC)
        UK: COMAH Regulations 1999
   COMAH Amended in June 2005 to reflect changes to Seveso II
Briefly ….


                More accidents:
                     BP Texas City
                     Buncefield
                Future changes?
Content


   Background
   Who falls under the COMAH Regulations?
   Requirements of Top Tier sites
   Safety Report Structure
   ALARP demonstration
   How do we prevent Major Accidents at Stanlow?
   Assessment and On-going Monitoring
Application of the Regulations


   Establishments having any dangerous substance of qualifying quantity
    specified in Schedule 1:
        Named substances
             e.g. chlorine, hydrogen, LPG, methanol, petroleum products etc.

        Categories of substances according to CHIP Regs
             e.g. toxic, oxidizing, explosive, flammable, carcinogens, dangerous for the
              environment etc.

   Two thresholds: lower-tier & top-tier
   Why is Stanlow a Top Tier site?
 Named Substances


Dangerous Substance                   Top Tier Threshold (tonnes)
Hydrogen                                          50
Liquefied extremely flammable gases              200
(inc. LPG)
Petroleum Products                              25,000
   Gasolines and naphthas
   Kerosenes
   Gas oils
 Generic Substances


Dangerous Substance Category    Top Tier Threshold (tonnes)
Very Toxic                                  20
Toxic                                      200
Oxidising                                  200
Flammable                                 50,000
Highly Flammable                          50,000
Extremely Flammable                         50
Dangerous for the Environment              200
Reacts violently with water                500
Top Tier COMAH




   Not an award!


   So what does it mean…?
Content


   Background
   Who falls under the COMAH Regulations?
   Requirements of Top Tier sites
   Safety Report Structure
   ALARP demonstration
   How do we prevent Major Accidents at Stanlow?
   Assessment and On-going Monitoring
Enforcing Authority


   Competent Authority (HSE and EA / SEPA)
   Duty on the CA to:

        Examine COMAH Safety Reports and inform operators on
         conclusions within a reasonable period

        Inspect activities subject to COMAH (testing claims made in
         Safety Report, so be honest!)

        Prohibit operations where the measures in place are seriously
         deficient
Main Duties for COMAH Operators

   Notify the CA
   Take all measures necessary to prevent MAs
   Prepare a Major Accident Prevention Policy (MAPP)
   Additionally for Top Tier sites:
        Prepare a COMAH Safety Report
        Maintain Safety Report as a living document
        Prepare and test onsite emergency plan
        Supply information to LA for emergency planning purposes
        Provide information to the public
 Purpose of COMAH Safety reports

Topics:
    MAPP & SMS
         ‘demonstrating that a Major Accident Prevention Policy and a
          Safety Management System for implementing it have been put
          into effect’
    Major Accident Hazards
    Safety and Reliability
    Emergency Plan
    Land Use Planning
 Purpose of COMAH Safety reports

Topics:
    MAPP & SMS
    Major Accident Hazards
         ‘demonstrating that major accident hazards have been identified and
          that the necessary measures have been taken to prevent such
          accidents and to limit their consequences for persons and the
          environment’
    Safety and Reliability
    Emergency Plan
    Land Use Planning
 Purpose of COMAH Safety reports

Topics:
    MAPP & SMS
    Major Accident Hazards
    Safety and Reliability
         ‘demonstrating that adequate safety and reliability have been
          incorporated into the design, construction, operation and maintenance
          of any installation / equipment / infrastructure which are linked to
          Major Accident Hazards (MAH) within the establishment’
    Emergency Plan
    Land Use Planning
 Purpose of COMAH Safety reports

Topics:
    MAPP & SMS
    Major Accident Hazards
    Safety and Reliability
    Emergency Plan
         ‘demonstrating that on-site emergency plans have been drawn up and
          supplying information to enable the off-site plan to be drawn up in
          order to take the necessary measures in the event of a major
          accident’
    Land Use Planning
 Purpose of COMAH Safety reports

Topics:
    MAPP & SMS
    Major Accident Hazards
    Safety and Reliability
    Emergency Plan
    Land Use Planning
         ‘providing sufficient information to the competent authority to enable
          decisions to be made in terms of the siting of new activities or
          developments around establishments’
Content


   Background
   Who falls under the COMAH Regulations?
   Requirements of Top Tier sites
   Safety Report Structure
   ALARP demonstration
   How do we prevent Major Accidents at Stanlow?
   Assessment and On-going Monitoring
 Safety Report Assessment Manual (SRAM)


Most Safety Reports are structured around the SRAM:
   SRAM Sections 1-8: Notes for assessors
   SRAM Section 9:        Descriptive Aspects
   SRAM Section 10:     Predictive Aspects
   SRAM Section 11:     MAPP and SMS Aspects
   SRAM Section 12:     Technical Aspects
   SRAM Section 13:     Environmental Aspects
   SRAM Section 14:     Emergency Response Aspects
 Section 9 - Descriptive Aspects


Describes the potential for harm, i.e.
   Dangerous substances
   Natural and built environment
   Establishment
   Common infrastructure and utilities
Section 10 - Predictive Aspects


Risk assessment methodology, i.e.
   MAH identification (100’s events)
   Selection of Representative Set (10’s events)
   Likelihood
   Consequences
   Risk Assessment
   Demonstration of ALARP (As Low As Reasonably Practicable)
 Section 11 - MAPP & SMS Aspects

Organisational measures in place:
   Major Accident Prevention Policy (MAPP)
   Safety Management System (SMS)
   Procedures
   Roles and responsibilities
   Training and competence
   Management of change (plant/processes, procedures and people)
   Measurement of performance (emphasis now on process safety KPIs)
   Audit and review
 Section 12 - Technical Aspects


Demonstration of hierarchical approach:
   Inventory
   Layout
   Materials of construction
   Construction methods (e.g. stress relieving, etc.)
   Design for maximum foreseeable conditions
   Protective devices for extremes
   Primary / secondary / tertiary containment
Section 12 - Technical Aspects (cont.)


Need to show what more can be done:
   Compliance with applicable codes and standards represents the minimum
    (Good Practice)
   Rationale for including / excluding additional risk reduction measures
    (can take cost / benefit into consideration)
   Asset integrity is the key issue!
       Primary / Secondary / Tertiary Containment
   Linkage to MAH
 Section 13 - Environmental Aspects


Overlaps with other sections:
   Identify Source-Pathway-Receptor (EA like this!)
   Description of installation (containment, ETP etc.)
   Substances
   Hazard identification / Likelihood / Consequences
   Risk Assessment / ALARP Demonstration
   Emergency Response
 Section 14 - Emergency Response


Should consider mobilisation of resources:
   People, i.e. onsite and offsite
   Equipment available, e.g. fire fighting systems, PPE, containment (air
    and ground), cleanup, etc.
   Maintenance of equipment
   Training and competence
   Provision of information to neighbours
 Improvement Plan


COMAH does not go away when SR is submitted …


SR preparation will identify areas for improvement
   CA expects an Improvement Plan
   Identify actions in text
   Collate into one document
   Timescales and responsible persons
   SR should be a ‘living document’
Content


   Background
   Who falls under the COMAH Regulations?
   Requirements of Top Tier sites
   Safety Report Structure
   ALARP demonstration
   How do we prevent Major Accidents at Stanlow?
   Assessment and On-going Monitoring
ALARP Demonstration - Summary


   Hazard Identification
   Risk Assessment of Representative Set of MAH Scenarios
        Consequences (Extent and Severity)
        Likelihood (Risk Reduction Measures)
        Tolerability of Risk
   What more can be done?
        Improvement Plan, or
        If not, why not?
            Cost Benefit Analysis – is cost grossly disproportionate to benefit?
RISK BOUNDARIES & CBA


Be guided by:
   HSE’s R2P2 – Reducing Risks, Protecting
    People
   SPC/Permissioning/12
NB SPC/Permissioning/09 states:
   When a number of options for risk reduction
    exist all options, or combination of options,
    that are reasonably practicable must be
    implemented. The legal requirement to reduce
    risks to as low as is reasonably practicable
    rules out HSE accepting a less protected but
    significantly cheaper option
    Content


   Background
   Who falls under the COMAH Regulations?
   Requirements of Top Tier sites
   Safety Report Structure
   ALARP demonstration
   How do we prevent Major Accidents at Stanlow?
   Assessment and On-going Monitoring
              Understanding the Process Safety pyramid

         Huge Focus on Process Safety
   We’re all so familiar with the Personal Safety pyramid.
  The Process Safety pyramid follows the same concept: by focussing                                          lagging
                                                                                               Fire,
on and dealing with weaknesses at the bottom of the pyramid we reduce                   Explosion, Fatality
the likelihood of more serious incidents at the top.
   LOPCs are near the top of the process safety pyramid.                              Significant LOPCs
                                                                                        (API/RIDDOR)
 Because of this an LOPC is a ‚lagging‛ indicator.
                                                                                              Significant LOPCs
It’s like an amber light - they tell us something in our processes is
                                                                                Small LOPCs(API/RIDDOR)
                                                                                                 to deck and
failing and warns us about more serious consequences                                  LOPCs to flare
                                                                                    Small LOPCs to deck and
 If we want to reduce our LOPCs we need to look downwards in the                                                             leading
                                                                                            LOPCs to flare
pyramid to see what’s                                                 inspection < tmin, trips, ESP Critical alarm rate
going wrong                                                                inspection < tmin, trips, ESPCritical alarm rate
                                                                     RCM gaps, overdues, poor maintenance quality, ESP
                                                                         gaps, PCDM not followed, PTW , Design
         Controls in a ‚Bowtie‛
         Barrier Thinking

             Threat 1                                                                                  Consequence 1

Hazard
                                                             Top Event
             Threat 2                                                                                  Consequence 2
                                                                LO PC

                                         Control                             Recovery
              Threat 3                   Barrier                             Barrier                   Consequence 3




                    Relief valve                                                        Deluge
                    IPF                                                                 High level alarm
                    Start up procedure                                                  Emergency response




                                                   HSE Critical Activities
                                                       Ÿ Engineering
                                                      Ÿ Maintenance
                                                       Ÿ Operations
             Barrier Thinking for all Staff
 LOPCs are caused                                                                         API-754: ‚Process safety incidents are rarely caused by
 What Barriers do you have responsibility for ?                                           a single catastrophic failure, but rather by multiple events
                                                                                          or failures that coincide‛
                                              OPS: Compliance with PCDM, operator
                                              rounds, ESP limits & proactive monitoring

      ENG: RCM, RBI,
                                                                       TEC/ENG/OPS: Management of Change
      Inspection
                                                                                           MNT/OPS: Pre-Startup checks
                                    Hazard/
TFS/OPS: Emergency
response                             Risk                                                               MNT: Maintenance quality, trip & RV
                                                                                                        systems testing, maintenance schedule
            TEC: Design, Operating windows, control

                                                                                                                  E&S: Crude acceptance
 OPS/MNT/ENG: Permit To Work
 (Process Isolation)
                                                                                                Undesirable
                                                                                                 outcome
                                                                                                                                   All: Learning from
OCT (Excel)/All: Training – Skill                                                                                                  Incidents
Development

                                                                                                      ENG/FIN (C&P):
                                                                                                      Managing our Contractors
Content


   Background
   Who falls under the COMAH Regulations?
   Requirements of Top Tier sites
   Safety Report Structure
   ALARP demonstration
   How do we prevent Major Accidents at Stanlow?
   Assessment and On-going Monitoring
COMAH Safety Reports


Assessment process:
   SRAM (Safety Report Assessment Manual)
   Early predictive screen (HSE & EA)
   Detailed assessment by specialist inspectors
   Further information request
   Conclusions letter
   Intervention
Intervention Visits

Do we do what we say we do (in our Safety Report)?
    Time spent by the Health & Safety Executive’s multi-disciplinary visits
    to Stanlow over the past year:
   Q4 2009 – 246 hours = 33 days
   Q1 2010 – 252 hours = 34 days
   Q2 2010 – 328 hours = 44 days
   Q3 2010 – 298 hours = 40 days
   At a cost of £171 per hour!
   We have multi-disciplined resources spending longer to prepare for and
    respond to the visits
HSE Publication L111




     Any Questions?

				
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