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Work in major hazard industries


3.1 Much of HSE's work is about the management of health and safety in high hazard industries and the control of major hazard events - the prevention of major incidents where the health and safety of many people, whether workers or members of the public, is affected.

3.2 The approach to regulation of major hazards is characterised by requiring the duty holder to identify the main hazards, the likelihood of them happening, and the measures in place to eliminate or control and mitigate them, setting these out in a report (often called a Safety Case). HSE evaluates the adequacy of these measures through assessment of the safety case or report and inspection. In the case of Offshore, Gas Conveyance in pipelines and Railways, the safety case has to be accepted by HSE prior to operations commencing at the major hazard sites. Should the safety case prove inadequate formal enforcement action may be invoked to prohibit the operation.

3.3 HSE has recently published a discussion document (DD) on regulating higher hazards. This explores the issues and principles underlying the legislative framework for major hazards as exemplified by the offshore, chemicals, rail and nuclear regimes. The DD had the objective of increasing transparency, stimulating discussion and seeking views on the approaches adopted. In light of the views submitted we will look again at the principles followed and consider if we need to review aspects of them.

3.4 The ultimate goal is to have no incidents with catastrophic effects. The rarity of major incidents in these industries highlights the importance of identifying proxy measures to provide assurance that risks are under control. HSE therefore needs to measure the frequency of events which might trigger a major hazard incident.

3.5 The sorts of measures which may be used include the frequency of incidents with the potential to escalate to major incidents eg signals passed at danger (SPADs) or RIDDOR dangerous occurrences such as hydrocarbon releases on offshore installations. More work is being done to refine these measures of initiating events.

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3.6 In 2001/02 and beyond, our work in seeking to secure improved standards of health and safety on the railways will be driven forward by a major review of working methods and by operational work targeted at the prevention of catastrophic failures and the improvement of compliance. In short, seeking, through duty holders, to ensure best practice is applied much more widely across the industry. Our activities will be facilitated by a further expansion in the size of the Railway Inspectorate, to around 200 staff in post, and improved targeting of resources based on better intelligence concerning the operation of the railway system. This expansion will place considerable demands upon HSE in terms of ensuring that arrangements for management, training and development are in place.

3.7 HSE will play its full part in current initiatives to improve the operation of the railways being taken forward by the Strategic Rail Authority (SRA) and the Office of the Rail Regulator (ORR). Both these organisations are required by legislation to consult HSE on safety aspects of their work. Memoranda of Understanding (MoU) between the three organisations have been developed to ensure good communications. For example, the SRA has consulted HSE on re-franchising proposals and the ORR consults HSE on its periodic reviews on charging arrangements within the industry. HSE will also be taking forward major initiatives on trespass and vandalism and, jointly with the Department for Education and Skills (DfES) and the SRA, on the improvement of arrangements to secure competent and skilled staff within the railway industry. In taking forward these initiatives HSE will remain mindful of its duty to use the law to secure good practice within the context of what is reasonably practicable.

3.8 The railway industry is currently undergoing a considerable period of development and our plans will have to be reviewed in the light of several factors:

3.9 Four particular themes under which our work will be driven forward are:

3.10 We will be working with stakeholders to set baselines, agree monitoring procedures and targets for the outcomes in each of the themes.

Prevention of catastrophic failures

Train Protection strategy

3.11 Work will include:


Establishment of a national train protection strategy with targets for reducing the consequences of SPADs including the development of regulations if appropriate.

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Securing compliance through the New Railway Safety Case Regime

3.12 Following the introduction of the new Railway (Safety Case) Regulations 2000, HSE will take forward a programme for assessing new and revised safety cases for compliance with the new regulations, and an inspection programme of key issues to check duty holders' compliance with their accepted safety cases. We will engage with duty holders and other stakeholders to:


More meaningful, measurable and usable safety cases from the railway industry, and better compliance with the railway safety cases.

Initial integrity (safe by design) of new and altered works

3.13 The aim is to ensure that duty holders have processes and standards in place for the introduction of new and altered railway works, plant, and equipment that is safe, reduces risks and protects people. Also that such works are delivered to these standards. HSE will seek the above assurance through the administration of statutory obligations in respect of 'Approval' under the Railways and Other Transport Systems (Approval of Works, Plant and Equipment Regulations) 1994 (ROTS). The future of this work will be reviewed in the light of the HSC's discussion exercise on permissioning regimes and the introduction of legislation implementing European Directives.


Assessment of approximately 400 to 500 schemes including Thameslink 2000, Channel Tunnel Rail Link, West Coast Main Line, the East London Line of London Underground, Virgin Cross Country and West Coast new trains. Most of these will be subject to staged and final inspection before qualifying for approval.

Improving the health and safety of those working on or using the railways

3.14 A risk based inspection programme to monitor compliance with health and safety legislation will be implemented which will be based on information received under the new safety case regime. Field inspectors will undertake a substantial programme of work, targeting resources to greatest advantage. The objectives will include reductions in incidents, injuries (to passengers, workers and other members of the public) and to promote best practice. The programme will include:


Enhanced awareness among school age children of the dangers of trespass and vandalism and a consequent reduction in related accidents and incidents.


To ensure the industry has an appropriate maintenance regime to secure safety of the infrastructure.


A reduction in the number of accidents to passengers whilst boarding and alighting from trains.

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Policy and strategic development

3.15 Major reports setting out a range of fundamental recommendations have been, or are in the process of being, prepared and published, and the HSC will be taking forward action, in conjunction with Government, the other railway regulatory bodies and the industry. Over the next three years we will:

3.16 Health and safety policy issues relating to the railways are not viewed in isolation from the similar issues that arise in respect of other transport modes. We are working to ensure that so far as possible a consistent approach is taken, thus assisting wider Government policy on transport issues. We thus take forward within an integrated organisational structure policy on occupational aspects of road safety, marine safety, aviation safety and railway safety. We seek to align our general policy approach with that of relevant Government Departments and other regulatory bodies, including the Civil Aviation Authority (CAA), Maritime and Coastguard Agency (MCA), ORR and SRA.


Development of action plans based on the railway safety reports by Professor Uff and Lord Cullen.

3.17 RIAC is currently the most broadly representative body within the industry involving operator, unions and passenger representatives. The HSC is currently reviewing the operation of its advisory committees and will consider ways of enhancing the operation of RIAC.


Improved working methods within RIAC.

Changing attitudes: improving the safety culture

3.18 Developing the competence of those working within the railway industry is a key challenge for the next few years. The HSE will work closely with SRA, DfES, the Railway Industry Training Council and industry stakeholders to develop appropriate plans and schemes of competency assessment. We will also review the operation of the Railways (Safety Critical Work) Regulations 1994.


Increased numbers of railway workers holding relevant National Vocational Qualifications (NVQ) or assessed against appropriate schemes.

Gas Conveyance and on shore major hazard pipelines

3.19 The Gas Safety (Management) Regulations (GSMR) aims, by a safety case permissioning regime, to ensure the integrity of the gas distribution network and ensuring emergency arrangements are in place to deal with a major gas leak. HSE assess the safety of major hazard pipelines by examining their design and integrity under the Pipeline Safety Regulations.

Control of Major Accident Hazards Regulations (COMAH)

3.20 COMAH was introduced on 1 April 1999 and aims to prevent and mitigate major chemical accidents which could harm people and the environment. It is enforced by the HSE and the Environment Agency (EA) in England and Wales and HSE and the Scottish Environmental Protection Agency (SEPA) in Scotland, acting jointly as the Competent Authority (CA). The CA has a statutory duty to:

3.21 Over the last ten years there have been 50 major accidents at establishments now covered by COMAH. Of these, six involved death or serious injuries to workers, 14 less serious injuries to employees, and four injuries to people off-site. The number is expected to rise because of the extended scope of COMAH and the inclusion of accidents to the environment. The occurrence of near miss serious incidents is much higher and it is largely a matter of chance whether they result in injury.

3.22 There are currently 450 top tier sites and 1200 lower tier sites. More establishments will be brought into scope with the full application of COMAH to explosives and the extension of the dangerous classification to other substances. The priority for the next three years is to implement and enforce COMAH working effectively with the constituent parts of the CA. The work we plan to do will include:


By 2004 a reduction of 20% in RIDDOR dangerous occurrences and COMAH Regulation 21 major accidents (accident of sufficient seriousness to require notification to the European Commission).

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Occupied buildings

3.23 A key programme will be carried out to improve the siting and design of occupied buildings on major hazard sites. This is to ensure:

3.24 We will assess the design and location of occupied buildings at approximately 300 top tier COMAH establishments for compliance with the Chemical Industries Association guidance.


By 2005 all occupied buildings to comply with Chemical Industry Association guidance on the design of occupied buildings for chemical manufacturing sites.

3.25 At licensed explosives sites distances between process and storage buildings in explosives factories are set out in the licence. But there are many instances of 'remote' operation when workers are located in, for example, an annex or compartment within the licence distance. There are no standards for the construction and location of such places and there have been explosions resulting in injuries to workers.

3.26 In consultation with the Explosives Industries Forum, we will carry out a survey of all buildings to identify those to be targeted, site licensees will be required to provide a risk assessment within an agreed time. standards will be set and a model for assessment developed, a programme of improvements will be agreed with industry, and guidance on standards of construction, distances and mitigatory features will be produced. This will reduce the risk to approximately 200 workers to an extent where there is a negligible risk of serious injury.


To reduce the risk of serious injury to 10-30% of workers in remote operations.

Mining industry

3.27 Mining legislation requires an on-going commitment by HSE to ensure health and safety in mining and associated activities. Failure to properly control the coal mine environment can result in high consequence incidents. This is a key area of the management of risk in mines. We will undertake a programme of 400 planned inspections at large coal mines which includes investigation into the effectiveness of the control of risks from explosive dusts and gases. All reportable fire or ignition incidents will be investigated.

3.28 Other key programmes of work include:

Offshore industry

3.29 Major offshore initiatives to be carried out include:


By 31 March 2004 a 50% reduction in major and significant releases against a baseline of 139 major and significant releases.


25% reduction in shuttle tanker loss of station keeping events by 2004.


To improve management of safety in design, leading to 10% reduction in adverse findings in the assessment of design safety cases.

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Nuclear industry

3.30 HSE is responsible for regulation, through licensing, of the nuclear industry to ensure protection of the public and workers. The nuclear industry continues to present fresh challenges to effective regulation, particularly through the ageing of plant, the shift towards decommissioning and waste management programmes, the impact of electricity market reforms, and HSE's increasing responsibilities relating to Ministry of Defence (MOD) sites. HSE have authorised an increase in Nuclear Installations Inspectorate's (NII) complement, from 159 to 179 inspectors, to respond to these and other demands. We will work with others and seek advice from Nuclear Safety Advisory Committee (NuSAC), as necessary, on the implications of these trends for the effective working of the nuclear licensing regime.

3.31 Under the nuclear licensing regime inspectors will continue to inspect all 40 licensed nuclear sites in Great Britain to monitor compliance with all of the 36 nuclear licence conditions which includes the safety cases for operation of the sites.

3.32 HSE will continue to apply resources to carrying out enforcement responsibilities including the control of design, construction and commissioning of new plants and major modifications.

3.33 Our top priority will be to ensure that operating nuclear installations and those undergoing decommissioning, are operated, maintained and dismantled in a way which minimises the risks to workers and the public so far as reasonably practicable.

3.34 We will continue to support international nuclear safety initiatives. Following the entry into force of the Joint Convention on the Safety of Spent Fuel and Safety of radioactive waste (for which the UK's ratification is impending) HSE will complete the UK report on compliance. HSE will also assist DTI in completing the second national report on compliance with the Convention on Nuclear Safety. We are currently looking at best practice in the nuclear industry and other nuclear regulators in order to develop performance indicators which will demonstrate whether risks are being adequately managed in the nuclear sector.

3.35 We will continue to deliver, in conjunction with nuclear operators, an agreed programme of nuclear safety research.

3.36 Key programmes of work over the next three years include:


The maintenance and improvement of safety standards at nuclear installations so as to prevent a major nuclear accident and to protect workers and the public from unnecessary exposure to ionising radiations.

Table 3.1 Selected outputs

'new' and revised safety cases
- - 237 218 201
assessment of safety cases
121 170 124 124 124
nuclear licence actions
385 380 380 380 380
Onshore (chemicals, gas, explosives)
assessment of safety cases
185 100 277 90 25
Updated 2009-01-06