Major Hazard Facilities

1. Major Hazard Facilities Introduction to Safety Report

2. Some Abbreviations and Terms • AFAP - As far as practicable • BPCS – Basic process control system • Employer - Employer who has management control of the facility • FTA – Fault tree analysis • HAZOP – Hazard and operability study • HSR - Health and safety representative • LOPA – Layer of protection analysis • MHF - Major hazard facility – as defined in the regulations • MA - Major accident • OHS -Occupational health & safety • QRA – Quantitative Risk Assessment • SMS - Safety management system

3. Topics Covered in This Presentation • Introduction • Key principles and objectives of the MHF regulations • Why is a Safety Report needed? • What is the Safety Report? • What must the Safety Report do? • Main components of the Safety Report • Hazard identification • Safety assessment • Risk controls • Emergency response plans

4. Topics Covered in This Presentation • Demonstration (of adequacy) • What else is in the safety report? • MHF regulations versus process • Sources of additional information • Review and revise • Conclusion • Examples of major accidents

5. Introduction • This seminar is a basic introduction to the Safety Report that is required under the MHF Regulations. • It has been developed for the following purposes: • To provide a simple overview • To be suitable for new MHF Employers • Outline the reason for a safety report • Overview of all parts of a safety report • Show examples of major accidents

6. Key Principles of MHF Regulations • Focus on major hazards (catastrophic events i.e. typically high consequence and low frequency) • Requires a proactive risk based approach • Places the responsibility on the Employer • Employer has to actively demonstrate safe operation

7. Key Principles of MHF Regulations • Consultation with different parties required at all critical stages • Facilitate culture change at major hazard facilities • Regulator ‘peer review’, tied to a licence • Addresses both on-site and off-site safety

8. Focus of MHF Regulations is high consequence (catastrophic) but low frequency incidents Focus of MHF Regulations Increasing risk Minor risks Very high risks should already be eliminated after risk assessment Relative Frequency of Occurrence OHS risks already regulated Consequence Severity

9. Objective of the MHF Regulations • The objective of the MHF Regulations is to provide for the safe operation of major hazard facilities to: • Reduce the likelihood of an MA occurring • Reduce the consequences to health and safety and damage to property in the event of an MA occurring

10. MHF Regulations Specific parts of the MHF Regulations relevant for this seminar are: • Hazard identification (9.43) • Risk assessment (9.44) • Risk control measures (9.45) • Safety management system (9.46) • Emergency planning (9.53) • Provision of information to the community (9.50)

11. Why is a Safety Report Needed? There is a need for specific control of major hazards due to: • Changing scale and complexity of specific facilities • Advances/changes in technology - unforeseen hazards • Changing community perceptions • Range of major accidents that have occurred • Prescriptive approach has proven inappropriate

12. Why is a Safety Report Needed? Some major accidents that have occurred • Coode Island, Australia – storage terminal fire, August 1991, 0 dead, 0 injured • Longford, Australia – explosion and fire, September 1998, 2 dead, led to the development of Victorian MHF legislation • Entschede, Holland – fireworks factory explosion, May 2000, 21 dead, 1,000 injured • Texas City, USA – fire and explosion, March 2005, 15 dead, over 170 injured

13. Why is a Safety Report Needed? Port Kembla Ethanol Tank Fire, NSW, Australia, 28th January 2004 Quote from the Coroner…“not a lack of adequate safety procedures but rather the failure to adhere to them”. (Welding was carried out in an unsuitable area without a ‘hot work’ permit)

14. Why is a Safety Report Needed? This has led to Regulations where: • The Employer knows what technical and human activities occur • The Employer decides on the appropriate means of major hazard control for the facility, and prepares a Safety Report explaining this • The Regulator assesses and audits performance adequacy against the safety report

15. Why is a Safety Report Needed? • The introduction of regulations were ‘fast tracked’ in Victoria primarily as a result of the Royal Commission into the incident at Longford in 1998. • The Victorian MHF regime is now mature and is working well.

16. What is the Safety Report? • The safety report must address all hazardous events that could result in MAs that pose serious danger or harm to: • Persons • The community • Property • The environment

17. What is the Safety Report? • A safety report is a detailed document that outlines: • The identification and control mechanisms in place to prevent and mitigate all MAs for the facility • The types of safety studies undertaken • The results obtained for such studies • The management arrangements in place to ensure the continued safety of the facility and its people and the surrounding community. • The safety report must be prepared in consultation with employees and be a true reflection of the state of the safety arrangements for the facility.

18. What is the Safety Report? The Role of the Safety Report • Regulatory role: The primary document used by an approved assessor to verify that the facility is operated safely to support the Employer’s licence application. • Information Repository: Contains all information about the safe operation of the facility which contributes to continuous improvement of safety at the facility.

19. What Must the Safety Report Do? • Document the state of safety arrangements for the facility • Demonstrate to the satisfaction of the Commission, through content and supporting material, that: • The employer knows what technical and human activities occur • How activities are managed • How safety will be managed in the event of an emergency

20. What Must the Safety Report Do? Identify methods to be used for monitoring and reviewing all activities for continual improvement of the safety arrangements of the facility over its lifetime. Review Monitor Safer Facility Improve

21. The Safety Report Should… • Reflect the facility safety culture • Contain information about the facility and interaction with its surroundings • Describe the systems used to achieve safety • Identify, assess and show controls for potential major accidents • Demonstrate ongoing consultation between the employer and workforce • Be integrated into the Employers management systems rather than a collection of separate individual safety studies

22. Safety Report Timeline Refer Guidance Booklet 4 for this timeline

23. Main Components of a Safety Report The main components of the safety report are: • Facility description • Risk assessment • Hazard and MA identification • Risk control measures • Safety management system description • Emergency response plan • Demonstration of adequacy • Control measures • Safety Management System

24. Facility Description • History • Daily operations • Schedule 9 materials and their characteristics • Demographic description • Facility topography & meteorological data • Simplified process flow diagrams • Site layout drawings • Location plans, surrounding facilities and sensitive neighbours • Proposed changes

25. Risk Assessment Requirements • Hazard identification – for determining MAs • Risk assessment studies – for determining controls • Risk evaluation - for determining risk acceptability • Recommendations and review – for continuous improvement

26. Hazard and MA Identification Process Hazard Studies (HAZOP/What If) Past Risk Assessments Unit Technical Review Input (Specialist Review) Hazards that can lead to major accidents are identified. From these, MA scenarios can be developed for further analysis. Incident History (internal / external) Dangerous Goods Present and Material Properties Major Accident Event Grouping

27. Mitigative Controls Preventative Controls Outcomes MA Causes Controls Controls Hazards Consequences Risk Assessment The information for assessment can be presented as a bow-tie diagram

28. Example: Layer of Protection Analysis Risk Assessment Analysing the safety measures and controls that are between an uncontrolled event and the worst potential consequence - risk reduction study

29. Risk Assessment Example Risk Matrix

30. Description of the Safety Management System • A comprehensive and integrated management system for all aspects of control measures adopted • Documented and describes how compliance is to be achieved • Site safety philosophy and how it is reflected in the SMS • Safety policy and safety objectives • Organisation and personnel responsible for the implementation and compliance with the SMS • Major features/elements of the SMS • SMS performance monitoring processes • Consultative processes used to develop and implement the SMS

31. OH&S Management System Model – AS 4801 Overall vision, goals and commitment to improve • Suitable, adequate, effective • Changes needed? • Opportunities to improve? • Legal compliance • Objectives and targets • Implementation plans • Resources • Leadership responsibility • Training and competency • Consultation and communication • Documentation • Hazard identification, risk assessment and controls • Emergency response • Monitoring and measurement • Incident investigation • Records management • Audits

32. Emergency Response Plans • Promote preparation • Ensure necessary equipment is available • Ensure personnel are trained and prepared to respond • Identify communication methods • Identify community resources • Consultation with emergency services, local council & community

33. Emergency Incident Scenario Plans • Analysis of the consequences of specific MA’s to determine fire fighting access and to identify affected areas • Determination of firewater and foam requirements for extinguishing the fire and/or protecting affected equipment • Available as a resource for training

34. Demonstration of Adequacy • The safety report must demonstrate that the Employer is achieving safe operation of the facility by : • Use of adequate control measures • Satisfactory management systems

35. Demonstration of Adequacy of Control Measures • Controls linked to hazards and proportionate to risk • Depth and breadth of control measures • Performance indicators defined and performance monitored • Risk has been reduced AFAP • Standards, industry practices • Decisions are documented and justifiable • Improvement programs – past and future • More information is available in the Comcare guidance Booklet 3 (control measures).

36. Demonstration of Adequacy of SMS Comprehensive and Integrated • Performance standards for the control measures are defined • Control measures are monitored and failures are addressed • Adequate education and training is provided for employees • Processes are provided for review and revision of control measures • Sufficient resources are provided, responsibilities, accountabilities defined • Planning, implementation and monitoring processes are provided for control measures and the system as a whole • More information is available in Booklet 3 (SMS)

37. What Else is in a Safety Report? Detailed Risk Assessment Records • Risk analysis of the hazards on site. E.g. • LOPA • FTA • Risk matrix • QRA • Provides a more detailed analysis of causes/frequency/consequences/controls for each identified MA • Assessment of off-site risk • Comparison of risk reduction options

38. What Else is in a Safety Report? Occupied Buildings Risk Assessment • Analysis of the impact of MAs on occupied buildings • Mainly risks (due to flame impingement, explosions, toxic gas) from other buildings/operations

39. What Else is in a Safety Report? Risk Assessment Procedures • Details of all the hazard and risk assessment work documented in procedures and referenced • Procedures provide step by step guidance on how the assessments were undertaken – enables corporate memory retention • Consistency of approach for all assessments • Justification for selection of risk assessment processes • Resources/guidance for the conduct of future assessments

40. What Else is in a Safety Report? Community Consultation • Community consultation philosophy • Summary of Safety Report information for community • Community bulletins

41. What Else is in a Safety Report? Recommendations and Improvements • Identification of opportunities to reduce risk via risk assessments • Recommendations are assessed and prioritised

42. MHF Regulation vs. Suggested Process

43. MHF Regulation vs. Suggested Process

44. Review & Revision • Employers must review (and revise) the safety report for an MHF to ensure risks remain reduced AFAP: • Prior to modification • When new information becomes available regarding possible MA hazards previously unknown • Upon licence renewal conditions or at least every 5 years • At the direction of the Commission • After a major accident

45. Conclusion • The safety report must demonstrate adequacy of all Safety Duties required by the MHF regulations • Safety Duties are ongoing requirements • An Employer at a MHF who fails to comply with the MHF regulations may be subject to civil proceedings or criminal prosecution under the OHS Act.

46. Sources of Additional Information • Part 9 of the Occupational Health and Safety (Safety Standards) Regulations 1994 • Major Hazard Facility Guidance Material – Comcare website www.comcare.gov.au • WorkSafe Victoria www.workcover.vic.gov.au • NSW Major Industry Hazard Advisory Papers 1 to 9 • Centre for Chemical Process Safety • UK Health and Safety Executive, www.hse.gov/comah

47. Questions?

48. Publicly Available Data/Incidents Several examples of incidents are available. These include: • Tosco Avon refinery fire incident, Martinez California, 23rd February 1999 (source: U.S. Chemical Safety and Hazard Investigation Board, Report No. 99-014-1-CA, issue date March 200) • Buncefield fire, December 2005 (source: UK HSE) • Dubai Dry Dock Incident (source: Web site, US Naval Sea Systems Command)

49. Buncefield Incident (UK) – December 2005. • In the early hours of Sunday 11 December 2005, a number of explosions occurred at Buncefield Oil Storage Depot, Hemel Hempstead, Hertfordshire • At least one of the initial explosions was of massive proportions and there was a large fire, which engulfed a high proportion of the site • Over 40 people were injured; fortunately there were no fatalities

50. Buncefield Incident Off-Site Consequences • “Significant damage” to commercial and residential neighbours • 2000 people evacuated • Sections of M1 Motorway closed • Very large smoke plume over Southern England → Air pollution • Large quantities of foam and water → contaminated water courses and ground water