Safety Alert to operators of COMAH oil/fuel storage sites
The following Safety Alert is primarily for the attention of those companies operating similar oil/fuel storage facilities.
The Buncefield incident on 11th December 2005 has demonstrated the capability of a very large hydrocarbon leak to create a massive explosion with a destructive power beyond the typical 'worst case' normally used for on- and off-site emergency planning purposes, and as the basis for advice to planning authorities on off-site development options. The incident is a reminder of the need for operators to maintain the highest levels of plant integrity and operational capability. There are nearly 100 sites around Great Britain with consent to store quantities of oil or other fuels that make them subject to the Control of Major Accident Hazards (COMAH) Regulations 1999.
Whilst the precise causes of the incident at Buncefield have not yet been fully identified, HSE advises that operators of similar installations:
- review the safety of their operations and plant to ensure that major accident hazards are being well managed,
- ensure that staff are adequately trained and competent to manage these hazardous operations,
- ensure that management systems are robust, and subject to effective review,
- ensure that relevant good practice precautions are in place and fully operational, and
- ensure that there are appropriate measures in place for responding to, and dealing with, emergencies involving loss of containment.
In order to ensure that this happens HSE has formed an inspection team charged with developing a staged programme comprising:
Step 1: Meeting with key trade associations, UKPIA, TSA, CIA, BCDTA and others as appropriate, to identify a set of issues that operators should review, so as to ensure relevant good practice precautions are in place. Also to continue to encourage the trade associations to work with their members to promote sharing of, and learning from information from major accident precursor events.
Step 2: Developing a targeted and nationally consistent action plan.
Step 3: Writing to all operators requesting they review their operations, informing them of the forthcoming inspection programme, and asking them to report the outcomes of their reviews to HSE by Easter 2006.
Step 4: Inspections at all sites covered by this alert, to:
- Confirm the pattern of storage of flammable substances in the tanks on the sites.
- Encourage operators to review storage tank utilisation so as to minimise the potential for off-site risks, whilst also maintaining high standards of on-site safety.
- Review preventive and mitigation measures in place, including appropriate safety management systems, to ensure they represent good practice.
- Review the adequacy of maintenance arrangements for storage tanks and bunds, and their associated safety critical equipment such as level measuring and alarm systems.
- Check that operators have revisited their assumptions for provision of equipment for detecting and dealing with loss of containment and flammable atmospheres.
- Continue to encourage operators to review and to promote sharing of, and learning from information from precursor events, so as to ensure continued learning of lessons applicable to major accident prevention.
Visits to ALL oil/fuel storage sites that fall under the COMAH Regulations will be undertaken without delay, and, if practicable, before the operators complete their further assessment (Step 3 above).When HSE Inspectors visit the sites, or speak to the operators, they will expect the operators to have made progress with reviewing their arrangements in line with the Easter completion, and will discuss any reasonably practicable improvements that should be made at that time. If necessary, HSE will use its enforcement powers to ensure that timely site-based improvements are made.
When more precise information on the cause of incident is determined, further advice will be issued to the industry, together with a plan for HSE and, if appropriate, the relevant environment agency staff (either EA or SEPA) to follow up on key issues aimed at preventing a re-occurrence of a similar incident to that which occurred at Buncefield.
Head of HSE's Chemical Industries Division
21st February 2006
This SAFETY ALERT has been copied to ALL COMAH operators, together with UKPIA, TSA, CIA and BCDTA trade association headquarters. It has also been copied to members of the Chemical and Downstream Oil Industry Forum (CDOIF), and to COMAH Inspectors in HSE, EA and SEPA.