Seveso 2 Risk Assessment Harmonisation: Types, Methods, and Challenges

1. Seveso 2 Risk Assessment Harmonisation Industry view of Risk Assessment in the context of Seveso 2 Richard Gowland - CEFIC/EPSC/Dow Chemical

2. Seveso 2 Risk Assessment Harmonisation Purpose of Risk Assessment • Protection of the community • Protection of workers • Protection of the environment • All these occur in Seveso 2

3. Seveso 2 Risk Assessment Harmonisation Types of risk assessment • Deterministic • Probabilistic • Other (hybrid, mixed types)

4. Seveso 2 Risk Assessment Harmonisation Detail • Use for control of establishment operators • Land Use Policy and planning • Emergency planning and response

5. Seveso 2 Risk Assessment Harmonisation Deterministic methods • Land Use planning decisions driven by inventories of different classes of hazardous substances. • Land Use planning decisions usually results in requirement/guarantee that there are zero off-site effects • Management system driven by Compliance with existing technical standards

6. Seveso 2 Risk Assessment Harmonisation Quantitative methods • Origins in the nuclear industry • Rasmussen report • Developed for the chemical/hydrocarbon industry .e.g. Canvey Island in the U.K.

7. Seveso 2 Risk Assessment Harmonisation Quantitative methods • Provision of defined methodologies and targets for consequences and associated frequencies (Clear, understandable transparent and actionable) • or • Performance/need to demonstrate that there is a safe system performance AND that further requirements are not justified. (Users and regulators not always clear on how to comply)

8. Seveso 2 Risk Assessment Harmonisation Quantitative methods • Misconceptions: • Results are completely accurate • An event which is predicted at a frequency of 1 in a million years will not happen for a million years starting today • Everyone studying a facility will achieve the same result.

9. Seveso 2 Risk Assessment Harmonisation • Different risk assessment methods and criteria result in • very large differences over Land Use Planning

10. independent studies by different partners of a standard scenario Z2 Z1 Average = 1484 m Variation = -61% … +156% Lethal effects Irreversible effects Average = 5047 m Variation = -70% … +91% thanks to MAHB

11. Member state differences in distances Separation Distances - Case 1: Toxic (Ammonia)

12. An individual company (DOW) experience in different E.U. member states. -

13. recognising that differences and difficulties are greatly affected by member state legal systems – may explain some of the differences, but does not necessarily ease the suffering!

14. Generic comparisons Deterministic • Transparency of decision process varies among states (no one seems to be sure when something is adequate in some cases) • Requirement to adopt ‘Best Practice’ appears to be attractive but is often difficult to find and rarely endorsed by the competent authority.

15. Generic comparisons Deterministic - cont • May appear to be more stringent than the probabilistic approach but… • Operator must demonstrate obedience to very clear rules • Control measures are clear • The questions assume manageable proportions in frequency, range and depth • You are in compliance or not in compliance

16. Generic comparisons Probabilistic and hybrid systems • May appear to be more flexible than the deterministic approach but… • Operator must demonstrate that risk is managed appropriately • The questions keep coming • In some cases you are never quite sure if you are staying in compliance • to quantify or not to quantify • Role of ‘Best Practice’

17. Common problems • Scenarios required for Safety Report vary widely (credible vs worst imaginable) • Ambiguity in response about Safety Report from Competent Authorities. (accepted, rejected, improvement needed etc. frequently referring to guidance published after Safety Report submission deadline)

18. Seveso 2 Risk Assessment Harmonisation • Netherlands: • Generic Quantitative Risk Analysis with a concept ‘As Low as Reasonably Achievable’ - ALARA • Terneuzen site (Dow’s largest in Europe) selected as a pilot for Seveso 2 implementation in The Netherlands • Scenarios and Safety Report development done together with a team of representatives from the governmental bodies involved.

19. Seveso 2 Risk Assessment Harmonisation • What went/is going well in the Netherlands: • synergy by using the same reporting tool as the Labour Inspectorate • minimisation of discussion items by using regulatory formats and methodologies where possible • co-operation with - and between the various regulatory bodies during report development • scenario definition via fault tree analysis led to new scenarios that the Dow tools had not identified • follow-up inspections, all parties participate simultaneously • reports are used for training and scenarios for emergency drills

20. Seveso 2 Risk Assessment Harmonisation Netherlands cont. • Challenges: • approval of reports went slowly but was reasonable compared with experience from others • following approval, co-ordination between the governmental bodies became slow and less structured

21. Seveso 2 Risk Assessment Harmonisation Netherlands - continued • Challenges: • follow-up inspection take a lot of time • requirements re. report contents keep changing • reports took 6 man years, maintenance and follow-up inspections take 0.5 - 1 man year • Terneuzen was the first in Dow, we thought that our effort could be leveraged to the other European sites, that was not the case

22. Seveso 2 Risk Assessment Harmonisation Belgium • First draft of Safety Report was issued Feb. 2002. Comment have been received. No particular issues. • HAZOP/What-if needed to be used for scenario development vs. SAVRIM in Terneuzen • Reports (2) took 1 man year • Overall: satisfied with the process but it takes too much time

23. Seveso 2 Risk Assessment Harmonisation Germany • Risk Assessment is deterministic • Designed to eliminate Hazards offsite • ‘Guarantee’ of no offsite hazard • Strict application of legal technical and management system requirements • Requirements clearly stated, understandable and compliance is relatively easy to demonstrate if you are already in compliance with technical regulations

24. Seveso 2 Risk Assessment Harmonisation U.K. • U.K. bases decisions on risks being demonstrated As Low as Reasonably Practicable – ALARP • Aimed to allow flexibility on means of performance • In practice it has confused industry – which frequently failed to realise that Seveso 2 is different from Seveso1 • ALARA (NL) is easier to understand and apply than ALARP (UK) • No ‘harmonisation’ between regulator and industry on methods for risk assessment • Regulator methods not made available to industry

25. Seveso 2 Risk Assessment Harmonisation U.K. Continued • Guidance often published after Report submission deadline • Safety Reports are large, expensive and frequently produced by third parties. (adding little to the safety of the facility) - one (not Dow) establishment spent close to £1,000,000 on the Safety Report • Permitting multi purpose establishments is very difficult because generic scenarios are rarely accepted

26. Seveso 2 Risk Assessment Harmonisation Italy Very slow approval process • Different responsible bodies are waiting for each other to make decisions (e.g. Fire Brigade Commanders waiting for Comitato Technico Regionale decisions) • Safety Management system approval shows the most progress.

27. Seveso 2 Risk Assessment Harmonisation The Future

28. Seveso 2 Risk Assessment Harmonisation • European Commission is driving appropriate harmonisation efforts • ARAMIS project • Technical Work Group 5 (Land Use Planning) • Industry welcomes this and hope they are successful!