RRC SAMPLE MATERIAL. Legal Requirements KEY INFORMATION. Importance of International/National Standards for Major Hazard Industries TOPIC FOCUS

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1 KEY INFORMATION Legal Requirements The Seveso II directive has been developed to control major accidents in the European Union. The COMAH Regulations (Control of Major Accident Hazards Regulations 1999) cover the prevention of major accidents in the process and other high hazard industries in Great Britain (note these laws do not cover Northern Ireland). They apply to organisations storing specific quantities of dangerous substances on their site. All construction projects are subject to the Construction (Design and Management) Regulations These Regulations have many requirements, including the preparation of a Construction Phase Plan and a Health and Safety File. IMPORTANCE OF HEALTH AND SAFETY REGULATORY FRAMEWORKS FOR MAJOR HAZARD INDUSTRIES Importance of International/National Standards for Major Hazard Industries One of the key health and safety laws for process industries located within the European Union is the Seveso II directive (officially known as the Directive 96/82/EC on the control of major accident hazards). The main precursor for the original Seveso Directive was an accident at a chemical plant that manufactured pesticides and herbicides in Seveso Italy The accident resulted in the release of a dense cloud of a poisonous and cancer causing substance (a dioxin) into the air which although caused no fatalities resulted in the treatment of 2000 people for dioxin poisoning and the contamination of ten square miles of land. The original directive was adopted in 1982 with the Seveso II directive being adopted in The Seveso II directive has a number of key requirements aimed at controlling major accident hazards, these include: The operator notifying a competent authority before starting activities. Development a major accident prevention policy. Submission of a site safety report. Development of a safety management system. Controlling land use (e.g. location of new establishments and nearby developments). Providing information to the public. Accident reporting. The Seveso II directive has been mainly implemented in the UK under the Control of Major Accident Hazards Regulations 1999, commonly known as the COMAH Regulations. The COMAH Regulations These Regulations apply to premises which: Keep listed dangerous substances in quantities exceeding stated thresholds. Use substances which are flammable, explosive, toxic or dangerous to the environment. COMAH differentiates between those sites deemed to be of higher risk ( top tier ), due to the quantities of dangerous substances stored or used, and lower risk sites ( lower tier ). Operators of establishments covered by COMAH must: Take all measures necessary to prevent or mitigate the effects of major accidents to people and the environment. Demonstration of the presence of adequate safety measures is a key part of the process. Prepare a Major Accident Prevention Policy (MAPP), which should demonstrate that there is an adequate safety management system in place. Send details of the types and quantities of hazardous substances to the competent authority. Send a Site Safety Report to the authority for approval ( top tier sites only). RRC International Unit PS1 Element 1: The Foundations of Process Safety 1-3

2 Legal Requirements Guidance has also been prepared by the United Nations Environment Programme that sets out a framework for prevention and preparedness of chemical accidents. MORE The UNEP guidance document a flexible framework for addressing chemical accident prevention and preparedness can be found at: Framework_WEB_FINAL.pdf COMPETENT AUTHORITY The Health and Safety Executive (HSE) and the Environment Agency which jointly enforce the COMAH Regulations. MORE CONSTRUCTION (DESIGN AND MANAGEMENT) REGULATIONS 2007 Construction projects in process industries usually involve many different parties in a collaborative effort. All parties have an important role to play in ensuring that: The project is carried out safely. The end result (the structure) is safe. All construction projects are subject to the Construction (Design and Management) Regulations 2007 (CDM Regulations). These Regulations are split into various parts, some of which deal with the practical control of construction work. All parts of the Regulations apply to notifiable projects. Notifiable Projects Requirements of the Regulations include notification of projects to the HSE where construction activities last over 30 days or involve more than 500 person-days. For such notifiable projects the CDM Regulations identify five duty holders who have a part to play in ensuring safety: Client - for whom the project is being carried out. Designers or architects - who specify the finished structure. CDM Co-ordinator - who assists the client during the planning and construction phases of the project. Principal Contractor - who manages the construction phase of the project. Contractors - who carry out specific types of work under the direction of the Principal Contractor. The Regulations require the preparation of a Construction Phase Plan and a Health and Safety File for the finished structure. CONSTRUCTION PHASE PLAN The health and safety management plan for the construction phase of the project. HEALTH AND SAFETY FILE Contains information about the new or modified structure that the client needs to know. CONSTRUCTION PHASE PLAN The plan will be started by the CDM Co-ordinator and then developed by the Principal Contractor. Typical contents would include: Site description: Including project description and existing site plans. Management of the work: Management structure. Management arrangements, e.g. for site induction and accident reporting. Site rules. Fire and emergency procedures. Arrangements for controlling significant site risks: Safety risks, e.g. fall prevention. Health risks, e.g. removal of asbestos. The Health and Safety File: Arrangements for gathering and storing information. 1-4 Unit PS1 Element 1: The Foundations of Process Safety RRC International

3 HEALTH AND SAFETY FILE The CDM Co-ordinator is responsible for preparing and updating the Health and Safety File. Typical content would include: Brief description of work. Residual hazards. Key structural principles. Hazardous material used. Information relevant to dismantling. Information on cleaning or maintenance of equipment. Services (electricity, gas, etc.). Information and as-built drawings regarding the structure and plant and equipment. The Regulations assign the following duties to each party: The Client should ensure that: All other parties are competent. Adequate information is passed on to the other duty holders. Work does not start until a Construction Phase Plan for the project exists. Adequate arrangements are made to ensure health, safety and welfare during the construction phase. Any structure intended for use as a workplace complies with the Workplace (Health, Safety and Welfare) Regulations (Continued) Legal Requirements The Designers should ensure that: The Client is aware of his duties under the CDM Regulations. A CDM Co-ordinator has been appointed for notifiable projects. The design minimises health and safety risks to: the construction workers; those who will occupy the structure on completion; and those involved in cleaning and maintenance. The design for a structure intended for use as a workplace complies with the Workplace (Health, Safety and Welfare) Regulations The CDM Co-ordinator should ensure that: The Client is advised on: The adequacy of the arrangements put in place by other duty holders. The appointment of competent contractors and designers. The HSE are notified of the project. Proper co-operation and co-ordination takes place during the design and planning process. The Health and Safety File is prepared and passed to the Client at the end of the project. The Principal Contractor should ensure that: A Construction Phase Plan for the project exists. The construction phase of the project is carried out safely. The site is secure. All contractors are working to the site rules. All contractors receive site-specific induction training. The Contractors should ensure that they: Work to site rules. Co-operate with the main contractor. MORE RRC International Unit PS1 Element 1: The Foundations of Process Safety 1-5

4 Legal Requirements REVISION QUESTIONS 1. Name two requirements of the COMAH Regulations. 2. What are the duties of the CDM Co-ordinator? (Suggested Answers are at the end.) 1-6 Unit PS1 Element 1: The Foundations of Process Safety RRC International

5 KEY INFORMATION Human Factors Human Factors is defined as the interaction between the main factors (job, individual and organisation) that affect human performance while at work. Human factors that influence work activities must be determined to gain an understanding of the reasons why people behave as they do while at work. Unintended actions (actions that were not intended to be carried out) include slips, lapses and mistakes. Actions that are intended include violations, e.g. a deliberate breach of procedures and rules. WHAT IS MEANT BY HUMAN FACTORS AND ERGONOMICS Human Factors HUMAN FACTORS Defined by the HSE as the interaction between the main factors that affect human performance while at work. The main factors are classed as the job, the individual and the organisation. RRC International Unit PS1 Element 1: The Foundations of Process Safety 1-7

6 Human Factors In an organisation that has a high level of management, human factors would constitute: The job - this is fitted to the strengths and weaknesses of the person/team that is carrying it out. This is fitting the job to the human. Examples might include ensuring that machinery, control and display devices, tools, etc. are all designed correctly. The individual - the organisation should select individuals who are suitable for the needs of the job. This is known as fitting the human to the job. They must have the correct skills, knowledge, experience and training. The organisation - responsibility for all work (including design) is taken by the organisation management. This will include developing an effective safety management system, encouraging good safety culture by displaying commitment and generally consulting with employees. A good organisation will also learn from accidents and near misses and take into account the latest thinking on health and safety issues. Factors Which Influence Behaviour SAFETY CULTURE Can be defined as the shared attitudes, values, beliefs and behaviours relating to health and safety. The safety culture of an organisation is the way that everyone within the organisation thinks and feels about health and safety and how this translates into their behaviour. NEAR MISS An unplanned, unwanted event that had the potential to lead to injury, damage or loss (but did not, in fact, do so). Ergonomics Ergonomics is concerned with the interaction between people and: The tools, equipment or machinery that they are using (e.g. the ease of use of control panels). The workplace environment (e.g. suitability of lighting). Organisational factors (e.g. shift patterns, hours of work). The aim of ergonomics is to minimise ill-health effects and optimise efficiency by adapting the workplace to suit the individual. This means taking into account both a person s physical attributes (such as height, shape, muscle strength, etc.) and their mental attributes (processing speed, decision-making ability, etc.). For example, ergonomic principles can be applied to a manual handling operation to reduce the risk of injury. THE IMPORTANCE OF HUMAN FACTORS Human factors cannot just be dismissed as being a result of carelessness, because this: Results in blame of the worker. Fails to identify the underlying or true cause and subsequently actions required to correct the situation. The human factors that influence work activities must be determined to gain an understanding of the reasons why people behave as they do while at work. If this can be determined then poor behaviour can be: Corrected by identifying and removing the cause of the behaviour. Anticipated, so that changes can be implemented to decrease the likelihood of it occurring. 1-8 Unit PS1 Element 1: The Foundations of Process Safety RRC International