Seveso Directives
Seveso Directive - requirements for large quantity substance storage
The Seveso II Directive, sometimes referred to as COMAH, stipulates certain requirements for storage of relatively large quantities of substances classified as dangerous. The following information may help clarify some of the issues involved and help with your compliance.
What are these Regulations?
The legislation is entitled the European Communities (Control of Major Accident Hazards Involving Dangerous Substances) Regulations, 2000 (S.I. No. 476 of 2000), which give effect to European Directive 96/82/EC on the control of major accident hazards involving dangerous substances. The legislation is more commonly known as the Seveso II Directive. The regulations apply to companies where dangerous substances are present in quantities equal to or above specified thresholds. There are two thresholds for LPG, a lower one of 50 tonnes ("Lower-tier sites") and a higher one of 200 tonnes ("Top-tier sites").
Firstly, please note that in determining whether the regulations apply to you, even if you are below the 50 and / or 200 tonne LPG limits, if you have quantities of other oxidising, explosive or flammable substances, these will have to be taken into account also, and may make the provisions of the legislation apply to you. The so-called "rules of aggregation" must be taken into account in this case, the manner of doing this is set out at http://www.hsa.ie/osh/frw1.htm. The rest of this guidance concentrates on the lower-tier sites: few if any end-user (customer) sites typically fall into the top tier, based on their LPG storage. In the (unlikely) event of your being classified as a top-tier site, the requirements are more onerous and further specialist advice should be sought. You may, as a result of this, wish to reassess your storage requirements of the affected product(s).
Notification
There are a number of implications to these regulations for lower-tier sites. The first, and most imminent, is that you have to notify the Health & Safety Authority (specifically the Process Industries Unit, Health & Safety Authority, 10 Hogan Place, Dublin 2) and your local planning authority with the following information by the 21st March 2001.
For the Health & Safety Authority
- the name of the operator and address of the establishment concerned
- the registered address of the operator
- the name or position of the person in charge of the establishment
- information sufficient to identify the dangerous substances or category of dangerous substances present, e.g. LPG
- the quantity and physical form of the dangerous substances present (or likely to be present), e.g. 100 tonnes of LPG in bulk tanks
- a (brief) description of the activity or proposed activity of the installation concerned
- details of the immediate environment liable to cause a major accident or to aggravate the consequences thereof (for lower-tier sites, which are not required to take into account activities outside your own site, you presumably only need provide details of other sites who have formally notified you of any risk they may present to you, i.e. adjacent top-tier sites)
- the name of any establishment located near the establishment concerned, whose inventory of dangerous substances could increase the likelihood or consequences of a major accident (again, for lower-tier sites, which are not required to take into account activities outside your own site, you presumably only need provide details of other sites who have formally notified you of any risk they may present to you, i.e. adjacent top-tier sites)
- a map of scale not less than 1:5000 clearly showing the location and boundary of the establishment concerned and the immediate environment
For your local planning authority
- confirmation that the establishment is subject to Seveso II
- the name of the operator and address of the establishment concerned
- information sufficient to identify the dangerous substances or category of dangerous substances present, e.g. LPG
- the quantity and physical form of the dangerous substances present (or likely to be present), e.g. 100 tonnes of LPG in bulk tanks
Other Requirements for Lower-tier Sites
By their nature, most if not all sites affected will probably already have the other requirements in place as they generally are already required under the Health and Safety at Work Act. You are required to have:
- an Emergency Plan and demonstrate that it is effective (e.g. fire and emergency drills) - for lower-tier sites, you do NOT need to include off-site issues, but it would be good practice (and possibly required under the Health & Safety at Work Act) to have a mechanism to notify neighbouring premises of an emergency
- a Safety Management System to review and check the effectiveness of your safety and work procedures, as well as managing changes to your operation (if you have an ISO 9000 system, most if not all of the SMS requirements either are already in your ISO 9000 system or it can be modified to incorporate them)
- a Risk Assessment to cover potential problems associated with the storage of the LPG - this would at least require that you carry out an assessment of your compliance to the relevant Irish Standard, I.S. 3216, Code of Practice for the Bulk Storage of Liquefied Petroleum Gas.
- a Major Accident Prevention Policy (MAPP), which is a high-level description of your policy (see our web site for a sample MAPP, http://www.flogas.ie)
If you plan to make significant alterations to your operation, you are required to notify the authorities in advance, giving reasonable notice to them.
Lower-tier sites are NOT required to submit a safety case.
The regulations impose planning restrictions both within and adjacent to your site, dependant on it's location and environment. This is the reason for the requirement to notify your local planning authority. The purpose is to control development that is not desirable or compatible with your operations.
Other Information
Please note that the above information is by it's nature generalised, and reference should be made to the regulations themselves.
Please remember that lower-tier sites need to notify the Health & Safety Authority and your planning authority by the 21st March 2001, even if you do not have all the required information.