Step 9: Identify major hazard installations

Identification of major hazard installations in a country would mean locating and registering the installations where one or more hazardous substances exceeding their threshold quantities are present. The competent authorities can identify such installations before the major hazard control legislation is enacted, but identification can be finalized only after the list of hazardous substances and their threshold quantities is made legally binding.

Major hazard installations are most commonly petrochemical works and refineries, chemical Works and production plants, liquefied petroleum gas stores and terminals, chemical stores and distribution centres, large fertilizer stores, explosives factories, and works in which chlorine is used in bulk. Local inspectors of the competent authorities are familiar with these installations and their knowledge may be tapped as a first step in identifying them. Additional information on their location may be obtained from organizations such as chambers of commerce, trade associations, and trade unions.

The competent authorities can ask the management of the companies likely to have major hazard installations for information on their activities. The information may be used to establish or modify the list of hazardous substances and their threshold quantities. In order to determine whether a plant is a major hazard installation or not, the total storage capacity of the dangerous substance must be considered, not the inventory figure or consumption at a given time.

When the major hazard control legislation is in place, the management of the company must on its own initiative check the list of hazardous substances and the threshold quantities, identify its major hazard installations, and notify the competent authorities.

Hazards can be controlled only when Hall concerned are aware of them, the need to control them, and the ways of doing so. Management and workers in the installations and people living nearby must be informed about the processes carried out in the plant, the hazardous substances and their characteristics, the hazards involved in the processes (if things go wrong, what can happen), and the protective measures they themselves can take.

Management must be convinced that hazard analysis and open information on hazards will not adversely affect the company if it clearly demonstrates that it considers the safety of its personnel and installations a priority matter.

Workers must be made to realize that accidents can be avoided through proper information, instruction, training, and discipline, and that they must comply with all safety regulations.

For management and workers to be aware of the hazards and the need to control them, they should know about accidents in similar installations, their causes and how they could have been avoided, and the possible consequences of such accidents if they were to occur in their installations.

The competent authorities may inform the public through the press, radio or other media about the specific accidents that they have investigated, explaining their causes and how they could have been prevented.

Articles on accident investigation in technical publications written by safety officers, government inspectors, and technical experts create awareness of the hazards.

The competent authorities must organize training courses on the major hazard control system in cooperation with major hazard industries, professional institutions, employers' and workers' organizations, safety councils, occupational safety and health institutes, technological institutes, and universities.

A general, basic course should be pro- vided for those directly involved: safety officers and managers of major hazard installations, inspectors of the competent authorities responsible for enforcing the legislation, specialists of the technical advisory unit, occupational safety and health inspectors. It should be organized by professional training institutes. Instructors should be recruited from governmental agencies, industry, employers' and workers' organizations, safety and health institutes, universities, professional organizations, research laboratories, medical institutions, and insurance companies. Optimal use should be made of the existing training facilities.

Inspectors must also receive training in special skills and techniques for inspecting major hazard installations, scrutinizing safety reports, and investigating accidents. Courses should be held at local schools and institutions, or instruction should be given by specialists of the technical advisory unit. If possible, fellowships abroad should be arranged.

As soon as the legislation on the major hazard control system is enacted, the lead agency will inform all concerned. The competent authorities must draft guidelines on aspects such as identification and notification of major hazard installations, writing of safety reports, hazard assessment, and emergency preparedness. Guidelines may be newly drafted or they may be based on other countries' guidelines. Their contents should be examined by the group of experts.

When the major hazard control system is first set up, each major hazard installation will have to be inspected several times. Once the system is fully operational, the installation should be inspected at least once a year or every two years.

Inspectors of the competent authorities must be capable of scrutinizing a safety report and understanding from it the installation processes, the hazards involved, and the technical and organizational measures taken to control the hazards. They must be able to conclude from it whether the management of the company is sufficiently committed to safety, whether the powers and responsibilities in the company are delegated in a way to ensure safe operations, whether the hazards have been properly identified and assessed, and whether the preventive measures taken are adequate to ensure safe operation. They must be able to formulate recommendations and demands for rewriting of the safety report, additional information, and safety measures, and discuss them with the management.

Inspectors must be capable of investigating different kinds of accidents. From scanty and sometimes distorted evidence, they must be able to draw valid conclusions as to the causes of the accident and how a recurrence can be prevented.

Inspectors need not have specialized knowledge about subjects such as risk calculations, hazard analysis, and dispersion calculations. Specialists of the technical advisory unit will assist them in this respect. If the specialists are not available, the company safety personnel who prepared the report must explain these subjects to the inspector.

Employers must set up a documented system of major hazard control (Annex 4), recording all safety measures in their operations, to ensure that relevant information can be retrieved when needed. Information from the documented system should be condensed and included in the safety report.

In principle, the safety report should be written by company personnel. It should begin with an introduction on the company's safety policy written by top management. Subsequent sections should be written preferably by company officers responsible for the subjects concerned. In the process, they may discover faults in the safety systems which they will be in the best position to correct. Parts of the report may also be written by the safety officer.

The safety report or parts of it may sometimes have to be written by an external expert. However, safe operation of the plant requires that knowledge of the hazards and safety measures is always available within the company. Contracting out the safety report to an external expert has certain disadvantages: it may turn out to be more ex- pensive than estimated as the external expert may not have in-depth knowledge of the company and the plant and will have to spend more time and energy securing all the information needed; the knowledge gained by the external expert will not remain with the company; the competent authorities will not discuss the safety report with the external expert who has no direct responsibility for the installation.

The competent authorities can guide management and workers on the requirements of the major hazard control legislation, particularly in respect of the safety report. The local inspector and one or more specialists from the technical advisory unit can answer their questions. Specialists of the technical advisory unit, through lectures and discussions, can provide them with information on implementation of new legislation or regulations on major hazard control, methods of identifying and analysing hazards, control measures, on-site emergency plan, and writing of safety reports. The lectures should be supported by printed information in the national language.

Annex 5 describes the contents of the safety report.

The safety report must be scrutinized by the competent authorities, preferably by the local inspector, has first-hand knowledge of the installation, and one or more specialists of the technical advisory unit familiar with hazard analysis and assessment and the safety reports of other installations.

The safety report should be checked on three counts:

• Does it adequately describe the hazardous substances, installation, processes, and safety organization?
• Does it properly identify, analyses and assess the hazards and the measures taken to deal with them?
• Does it show that the hazards have been adequately dealt with and operations are safe as a result?

If the descriptive part of the safety report found inadequate, the competent authorities will reject it and request the company to rewrite it. The competent authorities must ate in what respect it is inadequate. If it incomplete, the competent authorities will quest the company to provide additional formation, specifying the information needed. However, if it is generally unsatisfactory, the competent authorities will explain in what respect it is lacking so that it can be rewritten.

Hazard identification, analysis, and assessment must show that the management

In normal factory inspection, the conditions and situation are checked against precise and detailed regulations and requirements with which the inspector is thoroughly familiar. In the case of major hazard installations, however, there are no detailed regulations to follow. Inspection is carried out to verify whether the plant is being operated according to the standards set by the management in the safety report.

The inspector will announce the visit in advance and, if possible, discuss the aspects to be inspected with management and workers' representatives before entering the plant. The inspector may be accompanied and assisted by one or more specialists from the technical advisory unit involved in scrutinizing the safety report.

According to ILO Convention No.174, the competent authorities must establish a comprehensive siting policy and arrange for appropriate separation of proposed new major hazard installations from working and residential areas and public facilities, and appropriate measures for existing installations. This is to be undertaken in close coordination and cooperation with all the bodies and authorities involved in land use and siting of industrial installations. The local government bodies play an important role in the siting and licensing of major hazard industries. The competent authorities must therefore issue guidelines to the local authorities based on the national siting policy.

The off-site emergency plan is a key element of the major hazard control system and follows logically from the analysis that provided the basis for the on- site emergency plan. The two plans should therefore complement each other.

The competent authorities must ensure that the off-site emergency plan and procedures for protecting the public and the environment outside the site of the major hazard installation are established, updated, and coordinated with all concerned. They should clarify by means of policy, regulation or legislation whether it is the employer's or the local authorities' responsibility to prepare the plan.

Where several major hazard installations are located close to each other, they may be covered by one plan. The plan will be prepared by the local authorities or in cooperation with the employer.

The plan must be based on the hazards identified by the management of the installation, as indicated in the documented system of major hazard control and described and assessed in the safety report. Where more than one hazard have been identified, the plan must take all of them into account.

It must include the equipment immediately available, not those to be provided at a future date. It must be modified and updated whenever important aspects of the hazards and the capability of dealing with them change. It must be based on facts and realities and be certain to work when put into action.

All authorities and bodies to be counted on in the event of an accident, such as the fire brigade, ambulance, medical services, hospitals, and police, must be involved in preparing the plan, and its final version must be discussed with and communicated to them.

The plan must be easy to understand and clearly define the responsibilities and communication between all parties. It must indicate the organizations and persons concerned: names, addresses, telephone numbers. It must be made available to all who have a role in it.

The important organizational aspects the plan must cover are:

• the tasks and responsibilities of all concerned persons and services
• the ways a major accident can be detected, reported, and communicated to those who must act on it
• establishment of an emergency control centre
• communication and coordination among the public emergency services concerned
• communication and coordination between the company emergency services and the public emergency services
• procedure for warning the population
• procedure for gaining access to the accident site and keeping roads to the site clear of obstruction by spectators
• information to the public: who will respond to the press, radio, and television
• when and how to end the emergency.

The response to an emergency must be made immediately after the accident. This is possible if the accident - which often results from the accidental release of a large quantity of hazardous substance - is promptly detected and reported. If no automatic detection apparatus is in place, it may take a long time before an alarm is raised. Persons in the immediate vicinity of the release are likely to be incapacitated by it and unable to raise the alarm. Besides, no clear information on the location, nature, and extent of the release can be obtained by human observation.

To ensure prompt and adequate emergency response, employers should install sensors for hazardous substances in the proximity of the places where releases might occur. Their readings should be transmitted to the emergency control centre from where a number of instruments can be monitored. There should be 24 hours' surveillance of the readings. The system should ensure that all persons involved in emergency procedures are immediately aware of the alarm.

The monitoring system should be installed as early as possible so that reference data can be established on the conditions that existed before the accident or before the installation became operational. Such data are necessary for the correct setting of alarms.

The monitoring system should be directed towards dealing with major accidents as well as environmental pollution. The competent authorities in charge of these activities should liaise closely with each other. Agreement must be reached on: what must be measured, where, how often, and with what accuracy; how data should be recorded and in what form they should be kept; who should take action on and have access to recorded data; who will fund the monitoring service and supply personnel.

As new industries are set up and experience and expertise grow with time, the monitoring service will need to be improved and expanded: more sampling and sensing equipment would need to be added, more chemicals may require to be included in the sampling, and more information may need to be obtained on other industrial operations in the area. This will make it possible to detect, almost instantaneously, any abnormal release and trace it back to its source.

When setting up the monitoring system, it is advisable to monitor not only the release of pollutants and hazardous chemicals into the air, but also the discharge of chemicals into the effluent from the installations.

The employer must report a major accident to the competent authorities, investigate its causes, and make recommendations to prevent a recurrence.

The competent authorities will check whether the hazards that caused the accident were correctly identified and assessed in the safety report and whether the provisions to deal with them were inadequate or inactivated and, if so, why. To assess whether the action proposed by the employer will be sufficient to prevent a recurrence, the competent authorities will have to conduct their own independent investigation. The investigation will be carried out by the local inspector, assisted by one or more specialists from the technical advisory unit. They should build up and maintain their capability for investigating not only major accidents, but also the smaller ones which are likely to occur more frequently.

Criteria must be established for accidents that have to be reported by the employer to the competent authorities: what constitutes a major accident to be reported and investigated by the employer, what constitutes a "near miss" and should, as such, be analysed by the employer.

The competent authorities will set up a data bank of accidents in major hazard installations. This is usually undertaken by the technical advisory unit.