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Appendix 2 - Previous HSE and SEPA involvement

Post - Incident Review of HSE Involvement

Following the series of incidents a ‘Level 1’ Major Accident Investigation was instigated by the HSE.

As part of the ‘Level 1’ Major Accident Investigation, it is standard HSE practice to investigate the "prior role" at the Complex to check if HSE/HID procedures were adequately followed, and if any lessons can be learned.  The investigation leader was the Head of Land Division Unit 3 based in Liverpool to give independence from the unit in Edinburgh which routinely inspects the Complex.

The investigation concluded that the inspection team had delivered an inspection programme broadly in line with the HID requirements but it was limited by the resources available (this had previously been identified and steps taken to resolve HSE Inspector resource). The Refineries Industry Group (RIG), an HSE group, who meet to share experience on inspection activity at refineries, had previously expressed concern over the inconsistency of strategy for the refinery industry and work was underway to increase the impact of inspection across the refinery industry.

The BP Group and Grangemouth inspection strategy and plan was found to be in line with other refinery inspection resourcing and systems and was considered an adequate system of inspection under COMAH Regulation 19.

It was recognised in HID that refineries and petrochemical complexes are amongst the most complex and challenging inspection systems for a regulator to deliver impact. For this reason allied with Lord Cullen’s report into the Ladbroke Grove rail crash, which examined the safety inspection regime, HID took the opportunity to review COMAH Regulation 19 inspection systems via an Inspection Working Group of RIG.

Current HSE National Initiatives

"Revitalising Health and Safety" Strategy

The "Revitalising Health and Safety" strategy document from the HSE sets a goal to "prevent major incidents with catastrophic consequences occurring in high-hazard industries" and sets a target of "a 20% reduction in RIDDOR dangerous occurrences and COMAH Regulation 21 major accidents (accidents of sufficient seriousness to require notification to the European Commission)" by 2004.

Loss of Containment/Pipework Initiative

A pipework maintenance and loss of containment initiative for on-shore facilities (mirroring the HSE/Industry offshore hydrocarbon release reduction project) was started in April 2002.

Occupied Buildings National Project

Concerns over the standards of occupied buildings on major hazards sites were raised first in the UK following the Flixborough (Nypro UK) major explosion accident (1st June 1974) and were also a major issue in the major accident at Hickson & Welch Ltd, Castleford, Yorkshire (21st September 1992).

CIA Guidelines were first published in 1979 (An approach to the categorisation of process plant hazard and control building design).

The complexity of the issues, the potential costs of resolution and the need for development of a risk assessment methodology resulted in a time lag until 26th June 2001 when further CIA guidelines were issued with the agreement of HSE.

Under the "Revitalising Health and Safety" strategy a target has been set for "all occupied buildings to comply with Chemical Industry Association guidance on the design of occupied buildings for chemical manufacturing sites" by March 2006.

Competent Authority Steering Group

Competent Authority tripartite steering group (HSE/EA/SEPA) meetings have been regularly held since implementation of the COMAH regulations. A number of important national projects have been compiled under the umbrella of the single implementation project (SIP). 

Examples include – Lead Unit / Industry sectors work planning; joint enforcement policy; major accident investigation policy; emergency planning strategy; domino strategy; national security. 

In addition in Scotland there has been a Competent Authority (HSE/SEPA) working group operating prior to the implementation date of the regulations, to give practical effect to the formal Memorandum of Understanding between the two organisations. Examples include agreements on inspection methodologies and priorities, and ways to ensure consistency of approach between the two parts of the Competent Authority.

Human Factors Team Initiatives

The HID Human Factors team was set up in 1999 to focus on an area recognised to represent significant opportunities to improve industry importance. The Human Factors Team, whose experience includes a mix of psychology, ergonomics and industrial safety management; is a "one-stop-shop" for the directorate involved in:

Areas where there has been particular demand for the Human Factors Team’s support have included:

The team also support the HSE’s Field Operations Directorate, particularly the Railways Inspectorate.