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Seveso III Directive Moving from Seveso II to Seveso III Sandra Ashcroft, HSE 19 March 2013. Background to Seveso Directive. Seveso I adopted in 1982 to control major accident hazards Current COMAH Regs 1999 and planning legislation implement Seveso II
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Seveso III DirectiveMoving from Seveso II to Seveso IIISandra Ashcroft, HSE19 March 2013
Background to Seveso Directive • Seveso I adopted in 1982 to control major accident hazards • Current COMAH Regs 1999 and planning legislation implement Seveso II • Seveso III necessary as CHIP being replaced by CLP by 2015 • Overall purpose & approach to stay the same • Identification of sites, controls and mitigation • European Commission also took opportunity to modernise the Directive • Public info • Access to justice • Public participation • Inspections
Current situation • Seveso III adopted on 4th July 2012 http://ec.europe.eu/environment/seveso/index.htm • New COMAH Regs to be in force from 1June 2015 • Key issues: • Scope • Public information • Inspection • Lack of correction system for substances moving in or out of scope
What will stay the same? • Lot of changes but many are subtle • Seveso III will continue to ensure high levels of protection • Inspection • maintained flexible risk/hazard based inspection frequencies • BUT need to think about how they can be linked to other inspections under EU legislation
What are the main changes? • Scope – some changes eg new named substances, HFOs • Information to the Public • Emergency Plans • because of scope, and • Requirement to consult • Notifications – who will need to re-notify
Scope • Early indications – only a small movement of sites coming into/going out of scope • Helpful amendments on named substances • Determining whether the Directive applies will be more complex
Public information • Culture shift! • Available electronically and kept up to date • More requirements than before • Public info on safety measures for all establishments (not just top tier as present) • Confidentiality & security issues • Access to justice
Transitional arrangements • Notifications • who will need to re-notify • Implications for HSC • Safety Reports • Emergency plans • Confidentiality
Question on notifications • Do you accept the need to re-notify under COMAH 2015 with CLP info? • Can see another way of doing it to reduce the burden on operators? • Do you only have on site named substances from the named substance list in COMAH?
Timetable • Now – end of 2013 • informal consultation with industry and stakeholders • Research Group for impact assessment • Early 2014 – formal consultation; heavy fuel oils amendment to COMAH Regs 1999 • Early 2015 – lay Regulations & publication of guidance • 1 June 2015 – new COMAH Regs enter into force
Government policy • Copy-out • Gold-plating • Government view on guidance • UK influence on original Seveso Directive
Question on inspection • Would it be beneficial to your site to link COMAH inspection with environmental inspection where possible • Just with Environmental Permitting Regs & Scottish equivalent? • More general with other environmental inspection regimes? • Do you perceive it to be more burdensome to link COMAH inspections with other regimes?
Sources of information • Seveso website www.hse.gov.uk/seveso/ revised and will continue to be updated. Current features include; - information about Seveso III - implications for business - FAQs • Seveso ebulletin http://www.hse.gov.uk/seveso/bulletin.htm • Guidance http://www.hse.gov.uk/comah/index.htm
Any questions • Thank you for listening