Investigation of major hazards is one of the tools used to contribute to the overall objective of minimising the risks and effects which they present. Specifically this activity:
Sub outcomes and targets to which this activity will contribute include:
This programme covers the investigation of all major accidents/incidents involving major hazard substances at COMAH sites.
Onshore - the following CID key/topic programmes are also relevant to this work:
Offshore - the following OSD key/topic programmes are included within this activity:
Policy and Approach
The Control of Major Accident Hazard Regulations 1999 requires that for all major accidents at COMAH sites, the Competent Authority "make a full analysis of the technical, organisational and managerial aspects of the major accident and collect, by inspection, investigation or other appropriate means, the information necessary for that purpose". Guidance on what constitutes a major accident at a COMAH site is contained in SPC/Permissioning/19. The investigation of incidents is undertaken in accordance with CID policy set out in the HID (CI 1-4) Inspection Manual.
Offshore, the investigation of incidents is undertaken in line with the OSD policy as detailed in the OSD Inspection Manual, i.e, all major incidents must be investigated, all non major incidents where it is apparent that there is likely to have been a serious breach of H&S legislation should be investigated and all other incidents should be investigated on a selective basis.
Delivery is substantially via investigation backed up as required by support from specialists where necessary, also from research (internal and external agencies). The nature of investigation is such that support required cannot be pre-judged. Investigation activity is both guided by and influences operational policy, intelligence gathering and guidance provision.
Investigation by its nature cannot be accurately planed for; plans are based on previous experience on the number and scale of incidents. About 9% of HID's inspector resource is directed at investigation of major hazards.
The cost of CID time spent investigating major accidents at COMAH sites is recovered from the operator.
Investigation cannot be accurately planned, but based on previous experience, it is likely that income from investigation would equate to approximately 1.8 million.
Why it works
Legal requirements:
Investigation of incidents is a key tool used by HSE in ensuring:
COMAH Regulation 19(4) requires the Competent Authority to "make a full analysis of the technical, organisational and managerial aspects of the major accident and collect, by inspection, investigation or other appropriate means, the information necessary for that purpose". This applies to all major accidents at COMAH sites and is likely to involve investigation by HSE, except for those incidents with only, or mainly, environmental consequences, which EA or SEPA are likely to take the lead in investigating.
Onshore - in 2001/2002, there were 243 Dangerous Occurrences at COMAH sites (including those identified as potential indicators to major accidents); this figure fell to 208 in 2002/2003. The number of major accidents at COMAH installations required to be reported to the EC under COMAH Reg 21 fell from 10 in 1999/2000 to 4 in 2001/2002 and 1 in 2002/2003.
Offshore - the overall number of major hazard related accidents/incidents is gradually falling but inline with declining numbers in the industry, the worldwide performance of the UK offshore industry is perceived as being poor.
This programme addresses all major hazard risks.
There is little or no scope to reduce the effort spent on reactive investigation at major hazard sites.
The risk of significantly reducing this activity would be major, with a direct impact on revenue, reputation, ability to influence and an inevitable increase in harm and loss.
The evidence that this programme will meet the objectives is based upon a history of investigation bringing about recommendations, procedures and guidance etc. to prevent recurrence. The main assumption is that major hazard incidents will continue to happen and that abandonment or reduction of this programme will inevitably contribute to an increase in such occurrences with resulting increase in harm and loss.
Other options have not been considered.
The main business risks are:
Approximately 54 staff years is directed to Investigation of Major Hazards at an estimated cost of 2,621,290 (2,335,290 staff costs and 286,000 GAE).
The cost of time spent investigating major accidents at sites is recovered from the operator.
There are numerous stakeholders covering both discrete industry groups and activities, employers and trades unions. Some established industry-HSE fora exist, such as the Chemicals and Downstream Oil Industry Forum (CDOIF), which will be maintained and developed as the main links to industry. Other established external relationships such as those with the CIA (particularly through the Chemicals Enforcement Meeting Action Plan - CEMAP), DTI, UKPIA, EA/SEPA and BDCTA will continue. Offshore key stakeholders of this programme include: operators, contractors, workforce (directly and via unions), industry representative bodies (UKOOA etc), media - local and national, HSE/C DWP.
The performance indicators for this programme are:
The programme is reactive and so is dependent upon the number and severity of the accidents reported by operators.