CONTROL OF MAJOR ACCIDENT HAZARDS (COMAH)

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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

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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

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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

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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

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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

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Briefly .

• More accidents
• BP Texas City
• Buncefield
• Future changes?

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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

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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?

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Named Substances
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Generic Substances
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Top Tier COMAH

• Not an award!
• So what does it mean?

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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Section 9 - Descriptive Aspects

• Describes the potential for harm, i.e.
• Dangerous substances
• Natural and built environment
• Establishment
• Common infrastructure and utilities

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Section 10 - Predictive Aspects

• Risk assessment methodology, i.e.
• MAH identification (100s events)
• Selection of Representative Set (10s events)
• Likelihood
• Consequences
• Risk Assessment
• Demonstration of ALARP (As Low As Reasonably
  Practicable)

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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

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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

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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

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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

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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

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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

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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

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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?

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RISK BOUNDARIES CBA

• Be guided by
• HSEs 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

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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

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Understanding the Process Safety pyramid

Huge Focus on Process Safety

• Were all so familiar with the Personal Safety
  pyramid.
• The Process Safety pyramid follows the same
  concept by focussing on and dealing with
  weaknesses at the bottom of the pyramid we reduce
  the likelihood of more serious incidents at the
  top.
• LOPCs are near the top of the process safety
  pyramid.
• Because of this an LOPC is a lagging
  indicator. Its like an amber light - they tell
  us something in our processes is failing and
  warns us about more serious consequences
• If we want to reduce our LOPCs we need to look
  downwards in the pyramid to see whats going
  wrong

lagging
leading
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Controls in a Bowtie
Barrier Thinking




Threat 1
Consequence 1





Hazard








Top Event LOPC
Threat 2
Consequence 2



Control Barrier

Recovery Barrier


Threat 3
Consequence 3


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

HSE Critical Activities
Ÿ
Engineering
Maintenance
Ÿ
Ÿ
Operations
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Barrier Thinking for all Staff
LOPCs are causedWhat Barriers do you have
responsibility for ?
API-754 Process safety incidents are rarely
caused by 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, Inspection
TEC/ENG/OPS Management of Change
MNT/OPS Pre-Startup checks
Hazard/ Risk
TFS/OPS Emergency response
MNT Maintenance quality, trip RV systems
testing, maintenance schedule
TEC Design, Operating windows, control
ES Crude acceptance
OPS/MNT/ENG Permit To Work (Process Isolation)
Undesirable outcome
All Learning from Incidents
OCT (Excel)/All Training Skill Development
ENG/FIN (CP) Managing our Contractors
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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

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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

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Intervention Visits

• Do we do what we say we do (in our Safety
  Report)?
• Time spent by the Health Safety Executives
  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

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HSE Publication L111
Any Questions?