Changes to Public Information Culture SIESO, 13 May 2013

1. Changes to Public Information CultureSIESO, 13 May 2013 Pauline Nash, Chemical Industries Policy pauline.nash@hse.gsi.gov.uk

2. Purpose of session • To outline key differences in the public information requirements between Seveso II and Seveso III • Look at the key issues • To discuss how best to implement the requirements (syndicate work) • Return to a plenary session to present your views for discussion

3. Setting the context • EC desire for openness • UK Government agenda for openness /transparency • Balancing the conflict between the public ‘right to know’ and national security issues • Major Hazards work moving in same direction • Plan to take forward • Secretary of State Direction

4. Key differences • Public info on safety measures for all establishments - not just TT sites as present • Annex 5 – details of public info to be made available - Part 1 for all establishments, Part 2 for TT only • Information to be held electronically and permanently available • Information to be kept up to date

5. What are the key issues? • Ensuring that the public has access to relevant information which is current • How to achieve this? • Safety Report v NTS? • Confidentiality and security issues

6. Definitions in Seveso III • More than in Seveso II • ‘the public’ – means ‘natural’ or ‘legal persons’, ‘associations’, ‘organisations’ or ‘groups’ • ‘the public concerned’ – relates to the public who would have an interest in planning matters

7. Public information requirements for LT and TT sites • Annex V, Part I info permanently electronically available and kept up to date i.e. • Name/trade name of operator and address • Confirmation that the Regs apply • Simple explanation of activities • Common names/generic names of dangerous substances

8. Public information requirements for LT and TT sites (2) • How the public will be warned and how they should behave in the event of a major accident • Date of last site visit or ref to where the info can be found electronically • Advice where more detailed information about inspection plan and the inspection can be found

9. Public information requirements for TT sites – Article 14 • Info on safety measures to anyone likely to be affected by a major accident – at least every 5 years • A copy of Safety Report upon request or NTS if there are confidentiality/security issues • An inventory of dangerous substances unless confidentiality/security issues

10. Public information requirements for TT sites – Annex 5 • In addition to the Part 1 requirements, TT sites to also comply with Part 2 requirements: • …but first 3 requirements same as Seveso II • The new requirement – operator to indicate if an incident at a site is likely to affect another member state

11. Taking the Public Information requirements forward • HSE is currently scoping a project to set up a CA website for the public information requirements • Potential to form a one-stop shop for information and notifications • Further down the line - Intervention reports and letters

12. Non-technical summaries of COMAH Safety Report • Daniel Gaskarth to provide an overview of the project • At the end of both presentations there will be an opportunity to explore what has been said. Thank you.

13. Daniel GaskarthEnvironment Agency secondee to HSE SIESO conference, Manchester 13 May 2013 Non-Technical Summaries of COMAH Safety Reports Project

14. Seveso III requirements Balance the conflicting requirements of: The EC and UK Govt. for openness and the public “right to know”, and The Home Office for national security and restricted access to information

15. Non-technical summaries of SRs project The UK Government Seveso III implementation group set up a project to investigate the feasibility of NTSs Project team includes: COMAH regulators, Home Office and Public Health England (PHE)

16. Non-technical summaries of SRs project Objectives: Satisfy Seveso III directive requirements Provide useful information in simple terms Minimise burden on operators and regulators Not significantly increase security risk

17. Annexes II and V and articles 14 and 22

18. NTS project – progress so far Produced a template (max. 8 sides of A4) Includes COMAH named substances and categories (toxic, flammable etc), not every substance Presented the idea to industry at a Seveso III seminar in Leeds, October 2012 and launched pilot Meeting with Home Office in Feb. 2013 reviewed and approved version 1 of the exemplars Reviewed version 2 of the exemplars with pilot companies in May 2013

19. Sites of non-technical summary exemplars

20. Map for fictitious example LECC

21. Detail in full safety report vs NTS and Annex V Provision of accurate information at a required level Technical assessment vs informing the public Access to the information Available on request vs permanently available Efficiency of response Resource requirements

22. Conclusions Seveso III requires more information to be provided to the public information to be provided electronically The CA is considering implementation options in this informal consultation stage NTS template being developed virtually reflects the requirements in Annex V

23. Syndicate work • Question sheets on tables • Mixed Groups • Spokesperson to be appointed to provide feedback