Proactive inspection of major hazards is one of the tools used to contribute to the overall major hazard objective of minimising the risks and effects of major hazards. Specifically this activity:
This activity contributes in part to:
This programme relates to:
Policy and Approach
The COMAH, Offshore, Gas Safety, Explosives and Mining regimes are essentially safety report/case/licensing systems based upon submissions by operators (see notes relating to permissioning/licensing). Inspection is fundamental to ensuring the success of this approach, allowing for validation of information submitted by the operator and assessment on site of risk control systems.
Proactive inspection offshore is carried out in line with the policy and procedures contained within the OSD Inspection manual which is based upon the annual review of a duty holders risk profile and safety performance which informs a duty holder intervention strategy plan.
Proactive inspection in the chemical sector onshore is carried out in line with the HID (CI 1-4) Inspection Manual.
A significant amount of support is required to help target proactive inspection effort.
Delivery is by planned and targeted site visits. Targeting is guided by elements of operational policy, intelligence gathering, research and guidance but fundamentally is aimed at those parts of a site (installations or equipment) which present significant major accident risk and the systems/procedures in place to ensure that those major accidents do not happen. Depending upon the sites, installations and systems involved there can be a significant need for specialist support (electrical safety, process engineering, human factors, etc.) for inspectors.
The specific nature of aspects of the offshore sector, for example equipment congestion, evacuation/escape requirements and the marine environment requires that much support for major hazards inspection is provided from within OSD resource although there remains a significant call upon HID CD and external consultancy support.
The resource put to proactive inspection varies depending on where we are in the permissioning cycle, however, presently (04/05) around 31% of HID's total resource is put to this activity.
HID recovers the full cost of proactive inspection work on major incidents. The amount recovered depends on the permissioning cycle, and whether HID are in the assessment or inspection phase. Currently (04/05) we are in the inspection phase and can expect to receive around 6.5 million.
Why it works
Proactive Inspection:
Offshore, the overall number of major hazard related accidents/incidents is gradually falling but in line with the declining numbers in the industry, the performance of the UK offshore industry on worldwide comparison is (perhaps erroneously) perceived as being poor. In the period 1999 to 2003 there were eight fatalities relating to drilling and deck operations and this activity includes a specific OSD programme to address this. Two fatalities associated with a major hazard risk have occurred in 2003.
There continues to be a high level of serious incidents at our major chemical establishments, although the number of EU reportable major accidents under COMAH has fallen significantly to 2 (for the year 2002/3). RIDDOR DO figures have plateaued over the last few years.
This programme addresses all major hazards risks.
There is little or no scope for HID to reduce the effort spent on inspection, since this underpins the safety case/report/licensing regime. 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 abandonment or pruning of this programme is likely, over time, to leave an unintended message about our view of the importance of major hazards control, potentially leading to a drop in standards and an increase in risk of such accidents over time.
The evidence that this programme will meet the objectives is based upon a history of inspection bringing about recommendations for change on sites, leading in turn to changes in guidance and HID procedure. The main assumption is that lack of inspection means that HID will fail to validate the paper submissions made by operators, fail to evaluate their installations and systems as they are on site and potentially fail to ensure compliance with regulatory requirements. Targeted inspection in addition to achieving these aims sends a message to duty holders about the importance attached to compliance with major hazards regimes which paper submissions alone do not achieve.
Other options have not been considered.
The main priority business risks are:
These risks are managed by maintaining a significant programme of staff training and making the best use of specialist skills across HSE as a whole. Procedures are in place to ensure that inspections are targeted by agreement with other parts of the CA and to support inspectors in identifying sites, installations and systems to target. HID is developing a risk management system currently being piloted by OSD.
Approximately 197 staff years is directed to Proactive Inspection of Major Hazards at an estimated cost of 9,445,370 (8,400,720 staff costs and 1,044,650 GAE).
This programme is partially self-funding - see income projection in part 2.
Key stakeholders of this programme include: our CA partners, operators, contractors, workforce (directly and via unions), industry representative bodies (UKOOA etc.) and trade associations.
Offshore all manned installations should be inspected annually.
Onshore all COMAH Top Tier Sites should be inspected annually.
HID is responsible for delivering this contribution to HSE's Major Hazard Strategic Programme. There is no single programme manager within HID. Heads of Division (primarily OSD, SID and CID - also CD for elements of business and technical support work) are responsible for delivery of their contributions to the HID programme.
The programme detail is put together from HID's OG Core operating plan - resources are allocated to it at Unit level. The aggregation of this is shown above under resources and costs.
The latest Greenstreet Berman report concludes that proactive inspection, supported by enforcement, is an effective tool in meeting our objectives.
HID has developed a programme of planned impact evaluation work which will cover its major permissioning activities.