Seveso II and the EC Administrative Burdens Programme

The Seveso Directive is included in the European Commission's Action Programme for Reducing Administrative Burdens within the European Union.

An 'administrative burden' is a cost a business may incur in collecting and providing information either to public or private organisations which they would not do if they were not legally required to. The EC's Action Programme aims to reduce administrative burdens in the EU by 25% by 2012.

How does this relate to Seveso?

A Consortium hired by the EC to assist with this work made a number of suggestions relating to the Seveso Directive, two of which are being looked at in more detail:

Sending notifications of dangerous substances to the Competent Authority (Article 6)

The Consortium suggests making it easier for operators to send or update a notification through the use of national websites.

These websites could include standard forms, pre-filled with previously submitted information, that could be completed online and automatically forwarded to the relevant authority. The Consortium estimates that electronic notifications could save businesses 1.5 million euro/year.

Coordinating Seveso and IPPC inspections

The Consortium estimates that around half of the sites that fall under the Seveso Directive are also subject to IPPC legislation (Integrated Pollution Prevention Control Directive). They suggest that coordinating or integrating inspections, based on the frequency requirements set out in Seveso, could reduce the administrative burden on operators especially in work they spend preparing for and undergoing inspections. They estimate this could save businesses 1.5 million euro/year.

The Commission has set up a High Level Group of Independent Stakeholders to advise the Commission on the Action Programme. The HLG has called on the EC to promote the suggestions relating to Seveso.

What is the UK Competent Authority's view of the suggestions?

The UK Competent Authority supports these suggestions in principle. We agree that a system of electronic notifications could help operators (and also the Competent Authority) provided that it is easy to use and keeps data secure.

With regard to coordinating inspections, we already have a programme of work underway to fundamentally review how we implement the Seveso Regulatory regime - the 'COMAH remodelling' programme. This is working towards greater "joined up" working across the Competent Authority by organising joint COMAH (but not IPPC) inspections, based on joint intervention plans.

Opinions of the High Level Group

The HLG has published two reports on the environment priority area:

• First report of the High Level Group 17 April 2009 - contains opinions on the recommendations relating to Seveso.
• Second report of the High Level Group 20 May 2010 - no new opinions relating to Seveso