Seveso II Safety Reports: a checklist

The "Seveso II" Directive (96/82/EC) is aimed at the prevention of the major accident hazards involving dangerous substances, and the limitation of their consequences for man and the environment. The Directive wants to ensure high levels of protection throughout the Community, consistently and effectively. One of the principal measures to achieve this aim. is a requirement for a "Safety Report".

The relevant text from the Directive is contained in

• Article 9 on "Safety Report" and
• Annex II on "Minimum data and information to be considered in the safety report specified in Article 9".

This checklist is intended to compile and comment the information to be contained in the safety report; it is not meant to prescribe a particular format or style for the presentation of the information. The structure and format of a safety report for an establishment covering several installations are flexible: an operator can select the best way to present "common aspects" for the establishment and specific details for each installation which can present a major accident hazard (terms in italics are defined in the Directive).

Roles and Responsibilities

Safety Reports involve two major actors:

• the plant operator (PO)
• the competent authority (CA)

The Competent Authority

• examines the Safety Report
• requests further information from the operator (if necessary)
• decides to
  • allow or
  • prohibit (Art. 17)
  the bringing into use or continued use of the establishment
• communicates conclusions to the operator.

The Competent Authority

• applies harmonised criteria and
• decides
  • to grant a dispensation indicating to which matters the information required in the Safety Report can be limited or
  • not to grant a dispensation.

Review

Safety Report must be reviewed and updated every five years or

• at the request of the Competent Authority
• at the initiative of the operator (voluntary), where justified by
  • new facts
  • new technical knowledge about safety
  • new knowledge about hazard assessment
• in case of modification of a site (Art. 10).

Safety Report: The Contents

The requirement for a Safety Report (following Article 9 and Annexes II and III) applies only to upper tier establishments.

An operator must establish

Major-Accident Prevention Policy (MAPP)
• Safety Management System (SMS)
• Internal Emergency Plan

The Safety report must include information on the:

• environment of the establishment
• description of the installation including a listing of hazardous substances
• risk analysis and prevention methods
• control and limitation of the consequences of an accident
• MAPP and SMS.

The environment and surroundings of the establishment

The description of the natural environment and the surroundings of the establishment should be detailed to an extent proportionate to the hazard. It should demonstrate that the natural environment and surrounding activities have been sufficiently analyzed by the operator to identify both the hazards they pose to safe operation and the vulnerability of the area to the impact of major accidents.

The land use pattern of the areas around the establishment may be presented as specified in the official land use plan of the greater area. This kind of information will support the assignment of the relevant measures against potential effects of a major accident on neighboring inhabitants, ecosystems, properties and activities.

Depending on possible accident and their consequences on the surrounding environemnt, information should be supplied on:

• inhabited areas (e.g. description of the areas including population densities);
• establishments receiving the public, meeting points (regular or occasional);
• sensitive public buildings (schools, hospitals, churches, police stations, fire stations, telephone switchboards, etc.);
• conservation areas, registered monuments and areas of tourist attraction;
• public utilities, possibly affected by accident consequences, in the vicinity (electricity, gas, telephone, water, sewers and treatment plant, etc.).

External activities and developments may both be sources of hazards to the establishment and also be affected by accidents possibly originating in the establishment. The safety report should give adequate evidence that both kind of hazards have been identified. The description should include:

• industrial activities external to the establishment (i.e. nature of - and spacing with regard to - other establishments, limitations imposed by other establishments etc.);
• traffic routes and major transportation centers (i.e. roads, railways, waterways, ports, airports, marshalling yards etc.).

As the natural environment of an establishment may present potential hazard sources, influence the development of an accident, and be affected by the consequences of an accident, data will be needed for the description of the relevant environmental factors. In general this includes

meteorological data such as:

• average and maximum indices on precipitation (rain, snow, hail);
• thunderstorms;
• lightning;
• humidity, fog, frost;
• winds (direction, speed);
• stability classes;
• maximum and minimum recorded temperatures,

geological, hydrological and hydrographic site data such as:

• general geological context;
• type and conditions of the ground/underground;
• seismic data;
• flooding and landslides;
• other site specific natural hazards (uncontrolled fires, volcanic activities etc.).

Certain data can be omitted; however the reason for their exclusion should be explained.

The safety report should also present the data concerning the vulnerability of the natural environment to the impact of major accidents. The following environmental factors may be relevant:

• surface and ground water;
• water quality and uses;
• shore and marine environment;
• areas of special environmental interest i.e. natural protected areas, protected fauna and flora species, sensitive ecosystems, areas of outstanding natural beauty, etc.

Description of the establishment

An introductory section should contain general information on the establishment, i.e.

• purpose of the establishment;
• main activities and production;
• history and development of the activities including the status of authorizations for operations already agreed and/or granted;
• the number of persons working at the establishments (i.e. internal and contractors' personnel, specifying working times, visitors, etc.);
• general statements characterizing the establishment with respects to its main hazards due to relevant substances and processes.

As the organizational aspects are an integral part of the safety system, the safety report should describe the structure of the organization, including distribution of functions and responsibilities relevant to the safe operation of the establishment and its installations.

The description of the establishment should contain data on topography and accessibility to the site at a degree of detail commensurate with the extent of the hazards and the vulnerability of the surroundings.

The submitted topographic maps should be of an adequate scale and should include the establishment and surrounding developments within an area of sufficient extent in relation with the possible impact of accidents (the scale of the maps must be indicated, different scaled maps may be necessary when long distance effects are foreseeable.

On such maps the land use pattern (i.e. industry, agriculture, urban settlements, environmentally sensitive locations etc.) and the location of the most important buildings and infrastructures (i.e. hospitals, schools, other industrial sites, motorway / railway networks, stations and marshaling yards, airports, harbors, etc.) must be clearly indicated.

Also on the maps access routes to the establishment should be clearly indicated as well as the escape routes from the establishment and other traffic routes significant for rescue and emergency operations.

Lay out of the establishment

The lay-out should adequately identify installations and other activities of the establishment, including:

• main storage facilities;
• process installations;
• location of relevant substances and their quantities;
• relevant equipment (including vessels and pipes);
• spacing of the installations and their main sections;
• clearance between flammable liquid storage tanks in multi-storage sites, etc.;
• utilities, services and fire water retention;
• escape routes from the installations and across the establishment;
• control rooms and office rooms.

Dangerous substances

• raw materials;
• intermediate products;
• finished products;
• by-products;
• wastes and auxiliary products;
• products formed as a result of loss of control of chemical processes.

For the eligible dangerous substances, data to be provided should include:

• type and origin of the substance (i.e. CAS Number, IUPAC Name, commercial name, empirical formula, chemical composition, degree of purity if relevant, the most important contamination, etc.);
  
• physical and chemical properties (i.e. characteristic temperatures and pressures, concentration and phases at normal and at the onset of abnormal conditions, equilibrium data and operation curves if relevant, thermodynamic and transport properties, data on phase changes, flash points, ignition temperatures, combustibility of solids, spontaneous-ignition temperatures, explosion limits, thermal stability data, data on reactions and their rates, decomposition etc.);
• toxicological, flammability and explosive characteristics (i.e. toxicity, persistence, irritant effects, long-term effects, synergistic effects, warning symptoms, effects to the environment, ecotoxic data, etc.).
• others (e.g. corrosion characteristics in particular relating to the containment' material).

Most information may be found in safety data-sheets (including maximum permissible working concentrations, relevant threshold levels, reference to guidelines for health at the work place, methods and means to detect their presence in the workplace and/or in the case of loss of containment, etc.).

Hazardous installations and activities

1. basic operations;
2. chemical reactions, physical and biological conversions and transformations;
3. on-site interim storage;
4. other storage related activities i.e. loading-unloading, transport including pipework, etc.;
5. discharge, retention, re-use and recycling or disposal of residues and wastes;
6. discharge and treatment of waste gases;
7. other process stages, especially treatment and processing operations.

   Further details may be required of the safety relevant sections in accordance with the hazard analysis. This description should thus include a substantial amount of data significant from the process engineering and technical safety standpoint; and cover the safety systems as well. This may include:

   1. flow charts and Piping and Instrumentation (P&I) diagrams;
   2. flow patterns and machinery / equipment needed in the processes; inventories and key dimensions of the containers and pipes shall be available if relevant;
   3. process conditions i.e. pressure, temperature, concentration (their safe operation ranges) and any relevant thermodynamic and transport properties at the successive steps of the process such as:
      • normal and maximum flows, consumption of reactants, production of intermediate / end- / by-products (e.g. overall and substance mass balances);
      • average or typical quantities normally or accidentally possible to be present, stored or in process;
      • formation conditions of by-products and unplanned accident products;
      • conditioning of the final products;
   4. instrumentation, control / alarm and other safety systems;
   5. relevant qualitative and quantitative information on energy and mass transport in the processes i.e. material and energy balances:
      • in normal running;
      • in start-up or shut-down periods;
      • during abnormal operations;
   6. characteristic process conditions and substance state parameters (i.e. temperature / pressure / concentration / boil-off fluctuation etc.).

   Sufficient information should be provided in the safety report to permit the competent authority to assess the adequacy of the controls, but reference can be made to other documents available to the authority on request.

   The safety report should also provide an outline description of the procedures for safe operation in all process stages, which includes:

   1. operations (e.g. normal running, shut-down and start-up, exceptional operations, emergency and safety procedures);
   2. specific precautions during storage, transport or handling because of specific characteristic of the substance (e.g. protection from vibration or from ambient humidity).

   Structural characteristics and other design data of the storage or process plant handling the dangerous substances should be supplied in the form of the applied standards used for their design. A more analytical presentation of such data may be required for the parts of the establishment in which major hazards are encountered. The description need not enter into great detail, but should refer to other documents, available to the authority on request, covering certain relevant topics such as:

   • choice of materials important to safety;
   • foundations;<
   • design of equipment under high pressure or temperature and their supports;
   • size;
   • stability (static calculations, conditions and load - bearing capacity of the ground);
   • design against external events.

   The presentation of the establishment services should specify important characteristics of such utilities (i.e. emergency service, primary / secondary etc.). The description should make clear which services/ supplies are in common to more or all installations, and which are installation specific and should include the relevant back-up systems. The following topics should be addressed if relevant:

   Outside supplies

   • outside electrical, other power sources supply;
   • outside supply of water;
   • outside supply of other fluids or solids.

   Utilities inside the establishment

   • production of power internally, fuel supply and storage;
   • internal electrical distribution network;
   • back-up electrical supply (emergency supply);
   • fire-fighting and supply arrangements;
   • hot water and other fluid distribution networks;
   • communication systems;
   • instrument air.

   Other services

   • health and safety (working environment);<
   • medical service;
   • control centers, emergency refuges, muster points;
   • rescue service (emergency);
   • service of guarding and controlling the access;
   • environmental service;
   • equipment inspection service;
   • maintenance and repair workshop;
   • laboratory, etc.

   Waste treatment systems

   • sewer network and waste water systems;
   • arrangements for controlling and collecting fire water run-off.

   Monitoring services

   • weather stations;
     
   • services for detecting toxic products in the air;
   • services for detecting toxic products in the sewers/discharges to surface and ground water;
   • services for detecting and alarms for fires / explosive atmospheres;
   • services for monitoring access and detecting intrusions.