The Control of Major Accident Hazards Regulations 1999 (COMAH) Regulation 19(4) places duties on the Competent Authority in the event of a report of a major accident to:
A separate investigation into the effectiveness and the implementation of the emergency plan was therefore carried out by the Competent Authority following the FCCU fire which was classified as a major accident.
BP also investigated the emergency response as part of the in-house investigation of the FCCU fire.
The BP Grangemouth Emergency Incident Management Plan was initiated as a result of the FCCU fire. (Note: The plan was also initiated following the MP steam main rupture). This plan sets out the procedures to be followed and the roles and responsibilities of staff to be involved in order to provide a structured response to incidents. As a result of the FCCU fire BP’s own on-site emergency fire service were in attendance. Following on from mobilisation of the on-site resources the off-site emergency resources were mobilised and incident management teams both on-site (BP Incident Management Team) and off-site (the Grangemouth Petrochemical Complex Major Incident Control Committee – MICC) were set up to deal with the incident.
In the course of the investigation carried out by the Competent Authority a number of documents (including COMAH safety reports, the on-site emergency plan and incident log printouts from the MICC, fire brigade and BP) were examined and key personnel from BP, the MICC and the fire brigade were interviewed.
Key Findings of the Competent Authority Investigation
The overall findings of the Competent Authority investigation in relation to the FCCU fire were that the on-site emergency response achieved what it was intended to do and the overall objectives of the on-site plan (as required by COMAH Regulations 9, 10 and 12 and Schedule 5) were met. However some difficulties and failings occurred. Key findings are given below:
BP have reviewed and improved the on-site incident management plan. Area fire plans have been updated to the agreed format. A full review of the on-site emergency support provision has been carried out and improvements to the team organisation and facilities have been implemented.