Safety Report Assessment Guide: LPG

1 PM/Technical/03 HID - Safety Report Assessment GUIDE: LPG Safety Report Assessment Guide: LPG Introduction The purpose of HSE s Assessment of a Safety Report against the criteria in the SRAM, is to come to a conclusion on whether the requirements and demonstrations in Schedule 4 Part 1 have been met. The extent of the information required for each demonstration to be made will depend on the level of proportionality considerations and the type of Safety Report required by COMAH Regs. 7 or 8. The different Report types include: the initial Report for existing establishments, pre-construction (PCSR), pre-operation (POSR), modification and updated reports.

2 The predictive criteria are designed to help the Assessor make consistent professional judgements about whether the demonstrations in a Safety Report are adequate. Such demonstrations need to be based on a suitable and sufficient risk Assessment . The criteria are necessarily quite general, but sufficiently broad in nature to cover the various types of installation, the range of hazards to be encountered, and the types of risk Assessment that might be employed. The purpose of this document is to describe how Assessors should test whether the criteria that applies to the predictive aspects of COMAH Safety reports have been met.

3 It provides an interpretation of the criteria based on useful examples. The information supplements rather than supplants that in the Safety Report Assessment manual. The initial sections provide important background information, particularly on ALARP decisions and the application of the proportionality principle to the Assessment of Safety reports. Contents List 1 Introduction Fundamental Considerations Role of the Assessor Consistency and Proportionality Determination of Proportionality Deciding Whether the Risk is ALARP? How the Predictive Criteria Should be Used Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion

4 Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion Assessment Against Criterion List of Tables Table 1 Off-site Accident Initiators Table 2 Accident Initiators Requiring Consideration in a Safety Report Table 3 Typical Failure Frequencies Table 4 Check List of Accident Initiators Table 5 Systematic Process for Criterion Table 6 Effect of Input Parameters on Predicted Accident Consequences Table 7 Typical Uncertainties in Consequence Modelling Criteria 1.

5 Introduction The purpose of this document is to describe how the Competent Authority s Assessors test whether COMAH Safety reports meet the criteria that apply to the predictive aspects of COMAH. The information supplements rather than supplants that in the Safety Report Assessment manual. It is assumed that the Assessor is fully familiar with:- HSC/E s enforcement policy, the application of the ALARP principle and associated publications. COMAH Remodelling Policy and when this applies. The COMAH Training Manual. The contents of the HID Safety Report Assessment Manual (SRAM), particularly the guiding principles, and the procedures for handling and assessing Safety reports.

6 The sections below provide important background information, particularly on ALARP decisions and the application of the proportionality principle to the Assessment of Safety reports.. Fundamental Considerations Before assessing a Safety Report an Assessor needs to be clear about:- His/her role in the Assessment process and what the Safety Report Assessment Manager (AM) is expecting from the Assessment . The degree of proportionality that applies, this determines what can justifiably be expected from the Operator s risk Assessment (RA) - ie the depth of the arguments supporting the various demonstrations.

7 HSE s approach to the application of the ALARP principle to on-site (ie HSW Act Section 2), and off-site (ie Section 3) risks for new and existing establishments. How the Assessment criteria should be applied and factors which influence the depth of the Assessment process; an important consideration is the type of Report being assessed eg first submission, or an update Report . These issues are outlined in the remainder of this Introduction and are revisited as appropriate in later sections of the guidance. Role of the Assessor The predictive Assessment is pivotal to the demonstrations required under Section 4, Part 1, paragraph 2 of the COMAH Regulations; particularly the need to demonstrate that:- all major accident hazards (MAHs) have been identified; that all necessary measures to prevent and limit the consequences of these MAHs are identified and implemented.

8 The Assessor s role relates solely to the risks to people both on-site and off-site. Risks to the environment are for the Environment Agencies and are not addressed here. When the Assessment of the predictive aspects of a Safety Report is complete, the Assessor should return the completed Assessment form to the Assessment Manager giving conclusions about whether:- the process of the hazard identification and risk analysis is fit for purpose; all MAHs have been identified; any gaps must be recorded on the AF; the consequence Assessment is adequate for the purposes of COMAH ie the extent and severity of representative MAs must be quantified (Schedule 4, Part 2, Paragraph 4).

9 The Assessment form allows Assessors to comment against each criterion and subcriterion. This guidance is designed to help provide consistent comments and conclusions and is structured in terms of questions which relate to the criteria and help to identify any weaknesses in the Safety Report . These should help Assessors to write succinct deficiency statements and make clear what is required eg further information or analysis or both. When filling in the Assessment form the paragraph number and page number in the Report should be shown for cross referencing purposes. For example:- Criterion Safety Report Refs Comments Issue* Category The Safety Report should identify all potential major accidents and define a representative and sufficient set for risk analysis pxx para yy The Safety Report does not identify catastrophic vessel failure leading to total loss of contents as a potential MA.

10 The Report fails to meet criterion ; the Operator has to provide more information. Decided by team at final meeting * The Issue Category relates to the inspection plan only. The assessor must also provide input to the Assessment team conclusions on whether the prevention and mitigation measures make risks ALARP. Consistency and Proportionality The Assessment approach needs to be proportionate and consistent, therefore Assessors should come to a view on proportionality before starting to assess a Report against the predictive criteria. Consistency does not mean uniformity.