Chemical and Downstream Oil Industries Forum (CDOIF)
Meeting 7 March 2007

Minutes of the meeting held on 7 March 2007 in Room 6.1.26, Redgrave Court, Bootle

• HSE industry and topic advisory groups

Present:

Chair:	Kevin Allars	HID, CI
Secretariat:	Colin Harris Richard Lomax Paula O’Shaughnessy	HID CI4 HID CI4 HID CI4
Members:	Ian McPherson Bill Mayes Colin Chambers John Galbraith Doug Leech Martyn Lyons Jeff Watson Mark Scanlon Clive Tayler Richard Clarke Ron Wood	UKPIA Exxon/UKPIA CIA Sabic/CIA CBA TSA LPGA Energy Institute EEMUA EA TGWU
Other HSE:	Brian Fullam Steve Fairhurst Christine Flanagan Sally Hawkins Viki Beckett Ian Travers	HID SI5 FOD CHSD 1 HID CI4 HID CI4 HID CI4 HID CI4
Guests	Chris Hunt Dave Mercer Aidan Whitfield	UKPIA Vopak/TSA EA

1.  Welcome and introductions

Kevin welcomed everyone and introduced Brian Fullam who was attending his first CDOIF meeting as Head of HSE’s Process Safety Corporate Topic Group. Kevin explained that the meeting would be followed by presentations and discussions on the COMAH Competent Authority’s draft Containment Policy Statement on Handling Bulk Hazardous Liquids.        

2.  Apologies

Apologies were received from Phil McNulty (TGWU), Mike Murray (ABPI), Wayne Smith (BCF), Peter Emery (Federation of Petroleum Suppliers) and Roger Ward-Dutton (SEPA).

3.  Minutes and actions from the previous meeting

There were no amendments to the CDOIF minutes from 11th October 2006.

Item 4.1:  Colin Harris updated the members on progress with the implementation of the Regulatory Reform (Fire Safety) Order 2005 and Fire (Scotland) Act 2005 at COMAH sites. This legislation had come into force the previous October. The main change for COMAH sites was that local Fire Authorities would assume responsibility for overseeing general fire precautions, while HSE would continue to oversee process fire precautions. Colin explained that the demarcation between the two types of fire precautions was detailed in the HSE guidance OC 217/05. This guidance was fully open and would be available on the HSE website in a few weeks time. In the meantime HSE would see how the new arrangements were working in the field by joint site visits with the Cheshire Fire Authority and would report back to CDOIF.

Action – Secretariat to inform members when OC 217/05 became publicly available.

Mark Scanlon announced that the Energy Institute had recently produced a new publication on process fire precautions, including fire detection and deluge systems.

Action – Mark to send the Secretariat a link to the publication

Items 6.2, 8 and 10:   Paula had previously sent members copies of the Powerpoint presentations on Tank Floor Scanning Research and Human Factors and details of the joint CIA/HSE Major Hazards symposium.

4.  Members’ issues

Doug Leech raised the issue of the status of HSL document FR/05/09. This document deals with the storage of flammable liquid in Intermediate Bulk Containers. Doug reported that the associated DVD was being used by some inspectors during site audits. Kevin explained that the document’s status as an HSE Research Report was now being made clear to inspectors.

Action – Kevin to discuss this issue further with Doug to move it forward.

5.  Regulation and recognition

Kevin gave an update on this initiative to target HSE, EA and SEPA inspections at premises where they would have most impact. He explained that the project plan had gone before the DTI-chaired Chemicals Regulatory Forum and that the initiative was being piloted at HSE’s Leeds office. The pilot would involve the use of the site scoring matrix at COMAH and sub-COMAH sites handled by this office and would run from June 2007 for about a year. This was presently only an HSE trial. The CIA Responsible Care Cell in the area would be consulted. The Project Team had agreed that COMAH sites would be charged for inspections at a maximum of 2 hours of charging time.

6.  Reach competent authority (CA) update

Kevin introduced Steve Fairhurst who would be managing the UK’s REACH CA on a day-to-day basis when the new Regulation came into force in June. Steve explained that the CA function would be carried out by HSE with funding from DEFRA and input on environmental issues from the EA. He explained that during the first year of its operation the work of the UK CA would include gearing up with its counterparts across the EU and promoting awareness of REACH among duty holders.

Bill Mayes asked whether any help for complying with REACH was being particularly targeted to small businesses. Steve replied that REACH would not require much more from chemical users than the current legislation, but it was important that all chemical suppliers should be aware that they could form consortia with other suppliers during the pre-registration phase of REACH. Colin Chambers mentioned that the CIA had set up REACHReady, an information service particularly aimed at small businesses. Ian McPherson declared that if the CA wanted to use the trade associations to raise awareness of REACH, UKPIA were keen to help. Ian asked for clarification of the registration procedure. Steve explained that registration would be with the central agency in Helsinki, rather than with individual CAs.   

7.  HSE website update

Richard Lomax gave details of some changes being made to the Chemical Industries pages. These included new pages on lessons from loss of containment incidents, safety alerts and notices, mechanical containment integrity, legislation and Process Safety Performance Indicators. Richard explained that feedback on the site’s contents and format would be very welcome. Mark Scanlon thought that it would be useful to identify which parts of a set of legislation were still in force after parts of it had been replaced. Ron Wood suggested making it clear that the web pages related to the downstream oil industry as well as sectors of the chemical industry.

8. Disease reduction programme

Sally Hawkins gave a presentation on HSE’s Disease Reduction Programme for preventing occupational health issues due to exposure to chemicals, in particular respiratory disease, dermatitis and cancer. Sally explained that the programme was being driven by the Government’s Public Sector Agreement targets to reduce the incidence of work related ill-health. In relation to the chemical and downstream oil sectors HSE’s Chemical Industries Division had allocated resource for a series of intervention campaigns and stakeholder events under Key Goal 3 of its Divisional Strategy. Sally explained that the Division had recently run a campaign of inspection and enforcement in the North West on control of Legionella in wet cooling systems. She added that future priorities for the Division’s field teams would include asthma and stress.

Dave Mercer commented that sometimes employers felt it was difficult to demonstrate to their employees that effective measures to prevent work-related diseases were already in place. Sally commented that HSE was aware of this issue and suggested that Dr Dil Sen of HSE’s Corporate Medical Unit would be interested in discussing it further with any members.

9. Human factors – an industry view

Mark Scanlon gave an informative presentation on how the Energy Institute was using its Technical Programme to increase human factors expertise in the oil and gas industries. Mark explained how the EI’s Human and Organisational Factors Working Group had been working with multinational oil companies, HSE and consultants to address human factors issues such as safe manning levels at major hazard sites. The EI Health Technical Committee was addressing similar issues at other sites. The outcome of this work was a series of guidance documents, briefing notes and training resources available from the EI website.  The Institute had also sponsored two PhD studentships on human factors issues and commissioned research reports on topics such as the management of fatigue.

Mark also listed several other industry organisations working to raise awareness of human factors issues. Clive Tayler reminded the members that EEMUA would be issuing the second edition of its publication 191 on the management of alarm systems in the coming weeks. This included more information on alarm systems in batch plants. The second edition of EEMUA’s publication 201 on control desks and human-machine interfaces would be out later in the year.

10. Influence network

Christine Flanagan introduced the Influence Network, a concept that some of HSE’s Divisions had been using to identify and rate factors controlling risk in the major hazard industries. Following positive results from HSE’s Offshore Division, the Major Hazards Strategic Programme Board had agreed to fund the use of the model for the chemical industry. Christine explained that an external consultant had been contracted to run three industry workshops and to compare the findings with those of HSE workshops, with the aim of improving the means of collectively influencing health and safety issues.

Bill Mayes asked whether the ratings were related to PSPIs. Kevin replied that this was not the case, the aim being to produce a ranking order rather than absolute values. He encouraged members who were interested in taking part in the workshops to signal this to the secretariat, although he acknowledged that the downstream oil sector was already very busy with the Buncefield follow-up work. Clive Tayler thought that the sector he represented might be interested in the project, as did several others at the meeting.

11. Incidents/events

Buncefield

Kevin announced that the Buncefield Major Incident Investigation Board (MIIB) had met the previous day, and its Design and Ops Report should be out in the public domain by the end of March. The Board were planning to issue further reports on emergency response and land use planning. The COMAH CA was planning to put out their Inspection Findings Report after the present draft containment policy had been agreed ready for consultation.

Action – Secretariat to inform members by email when these documents were made available.

Mark Scanlon asked whether the MIIB’s recommendations would be worked on by the Buncefield Task Group. Kevin replied that the Task Group would continue to sit and take some issues forward, but not Land Use Planning issues.

Terra Nitrogen

Kevin announced that the Investigation Board for the Terra Nitrogen incident had also been looking at the incidents and near-misses at GlaxoSmithKline, Invista and ConocoPhillips and was nearing the point of concluding its work. The Policy and Procedures Review was scheduled to be completed by the end of March.

BASF Seal Sands

Kevin gave a summary of the loss of containment incident at the Seal Sands hexamethylenediamine production plant in January. This had involved the release of hot, pressurised material from a water jacketed line, causing chemical burns to the maintenance crew and affecting other workers by inhalation. The incident had been caused by staff removing a flange on the live system, rather than the water jacket, because the diagrams of the plant pipework were incorrect.

Texas City

Kevin explained that the US Chemical Safety Board had finished its investigation into the fatal accident at the BP Texas City refinery. Carolyn Merritt had informed him that the report would be published on March 20th. Ron Wood asked whether HSE had changed its guidance for inspectors in the light of the lessons from recent accidents, to which Kevin replied that this had already happened for Buncefield but not yet for Texas City, although targeted inspections had been undertaken to look for circumstances similar to those at Texas City.

Kevin announced that HSE was also planning to arrange a high level conference with stakeholders from the chemical, nuclear and oil industries to discuss safety culture and process safety issues at major hazard sites. The meeting would be held in London early in 2008. UKPIA, CIA and TSA all indicated that they were keen to work with HSE to make this initiative a success.

12.  Information items

Kevin gave details of two new Consultation Documents from HSE.

The first Consultation Document deals with Land Use Planning around large petrol storage sites and was put out for a 3-month consultation on February 27th. It includes three options for revising the land use planning advice HSE gives to Local Planning Authorities in the light of Buncefield, and seeks public comment on a revised set of Objectives and Principles underlying these policies.

Jeff Watson asked for clarification of the status of the document RR511 “Revised land use planning arrangements around large scale petroleum depots” which had been recently commissioned by HSE. Brian Fullam replied that RR511 was a research report which had been used to inform the Consultation Document. Ian McPherson asked if there had been any information on the mechanism of the explosion at Buncefield. Kevin replied that the Buncefield MIIB had still to state their conclusions on this issue. As the MIIB were independent, HSE couldn’t set their agenda, although HSE and EI had already offered to take this issue forward. Chris Hunt recalled that the MIIB had previously stated that the explosion mechanism was an important issue that they would address.

The second Consultation Document would deal with COMAH sites as a whole and would set out proposals to take account of Societal Risk when looking at safety measures and land use planning. Kevin explained that although this second document had originally been planned for release in May, this might be brought forward to ensure an overlap of the consultation periods for the two documents.

Richard Lomax gave details of a leaflet [PDF 280kb] on controlling Legionella in wet cooling systems at chemical installations. This was prompted by findings of poor conditions at several sites visited by HID inspectors.

Richard also reported that the health and safety statistics for 2005/06 were now available. The industries with the highest rates of non-fatal major injury were still agriculture and construction, followed by transport and manufacturing. The industrial sector with the highest rate of non-fatal major injury was waste recycling, including chemical waste treatment and storage sites. This sector had an injury rate eight times the national average.

Clive Tayler announced that the European standards organisation, CEN, had been developing a draft standard for Risk Based Inspection, CWA 24. Clive explained that the document would be put out for 60-day public consultation at some time between now and the next CDOIF.

13. Loss of containment initiative and european refineries website

Viki Beckett gave an update on the Loss of Containment Initiative, and reported some findings from the 2005/06 data. For incidents in both the chemicals and refineries sectors the Risk Control System found to be deficient most often was operating procedures. For refineries pipework continued to be the commonest site of release. Ron Wood commented that although operator error was often put down as the cause for a loss of containment incident, this did not mean that the operator was directly to blame, as there tended to be deeper underlying causes.

Viki explained that from the next work year onwards the Loss of Containment data would be collected by HSE inspectors rather than being self-reported by industry. Bill Mayes asked why the reporting scheme had been changed from a voluntary one. Viki explained that in practice inspectors collected information on the root causes of loss of containment incidents anyway, and HSE was now able to record this on a newly introduced IT system against an agreed dataset, thus allowing analysis. John Galbraith asked whether this meant that companies would no longer have the opportunity to report incidents which did not meet the RIDDOR Dangerous Occurrence criteria. Viki confirmed that although this was the case, in practice there would be little change as companies had only been reporting incidents which met the RIDDOR criteria.

Viki also gave some information on a European Refineries website being set up following the Mutual Joint Visit of European regulators. The website would include the facility to enter data and share it in a more coordinated way. More details would follow in due course.

14. Any other business

There was no other business. The next CDOIF would be held in Rose Court, London, and the date had been changed to Wednesday 4th July 2007.