Inspection of Explosive Sites Group 4 Break-out session 3 Inspection of Explosive Sites Group 4

Questions for discussion B3-1 INSPECTIONS Main Question: How do you carry out inspections? How do you plan your inspections; choice of sites, frequency, topics and focus? Do you use the Seveso report as the basis of your inspections? How do you identify and inspect lower tier sites? What topics have you chosen for your inspections? How do you inspect lower tier sites and do you have the power to enter an unregulated site? How do you inspect ancillary sites and activities such as test ranges and disposal facilities? B3-2 FINDINGS Main Question: What are the main findings from your inspections? Are there significant differences between explosives and pyrotechnics/fireworks sites; culture, SMS, adherence to regulations? What are the main causes for concern arising from your inspections; culture, SMS and technical? Have you prosecuted and shut down operations and why? Has Seveso 3 made a difference to the operations on the sites? B3-3 RECOMMENDED GOOD PRACTICE Provide a list of bullet points which offer advice and good practice it other inspectors for inclusion in the final MJV report. How you inspect What you look for What you have found What actions you have taken and what do you suggest You may prepare this as you answer the previous two questions

B 3-1 Inspections Main Question: How do you carry out inspections? All countries do annual planning Some use Sevesoreports as a basis for inspections, others not Topics are chosen based on the countries priority systems, sms imprtant Most countries have a popwer to enter an unregulated sites, but not many unregulated sites (we think) Some UT sites have test ranges and disposal facilities, some are military , others are outside Seveso How plan? Germany: Database is fed by inspectors, plan inspections in november Questionloists sent to company beforehand, they must send in answers f\before inspection The inspector evaluates the answers – follows up things they dont like in inspections Follow up afterwards with new lists the companies has to work with and answer. Within set deadlines. Main topic always SMS, technical process safety, some topics chosen every year. Extraordinary inspections in case of incidents: Otherwise not coming unnanounced. Italy: Frequencies not always followed, prioritation criteria Multitask teams from 3 authorities CA makes inspection plans 3 – 5 days inspections + report must be completed within 3 months Plan is made based on list of criteria, based on the combination of critical points the prioritation is done Have a checklist to follow – from SMS and down into details. Training, control and procedures, maintenance, emergency most important points Croatia: Yearly plan, coordinated and thematic inspections. Inspections are coordinated. Inspectors must do 15 inspections per year. According to Slovenia: Yearly plan of inspection, only 3 explosives sites, frequencies as SIII, different topics every year, every 3. year a more in depth sms- inspection. 1 day inspections, 1 inspector pr inspection. Estonia: 2 authorities cooperate, have made a treat prognisis to set frequencies, cooperate on planning of inspections, they do unannounced inspections for pyro before christmas. Topics are: sms –based. Norway: Planned together 5 authorities every year in November, DSB coordinating authority – divide , questionlist common, SMS must always be basis for inspections (systematic approach), annual mandatory themes decided by coordinating committee, joint question list with 13 themes, always mandatory to follow up of last Seveso inspection report (also when other authorities did the Seveso-inspection), Sweden: Regional inspections, common checklist for all the country, Seveso frequences, coordinated by MSB, Seveso report as basis for inspections? Germany sometimes Italy one of main elements Croatia: Yes Slovenia: Yes in combination with permits Estonia: sometimes Norway: always in combination with permits Power to enter unregulated sites? (most countries do not think they have, because they need permission to buy) Germany: have the right, but will not do Italy Yes under TULPS Slovenia: Yes Estonia: Yes Norway: Yes, according to law on flammables and explosives Test ranges and disposal sites? Sweden, and Norway - some upper tier sites do this Croatia: they have sites like this, but not under Seveso Italy: no such sites

B3-2 Findings Main Question: What are the main findings from your inspections? Weaknesses sms Too much stored (pyrotechnics) Explosives storage better organized Italy : reference to her presentation Norway have a report from 2015…. How plan? Germany: Database is fed by inspectors, plan inspections in november Questionloists sent to company beforehand, they must send in answers f\before inspection The inspector evaluates the answers – follows up things they dont like in inspections Follow up afterwards with new lists the companies has to work with and answer. Within set deadlines. Main topic always SMS, technical process safety, some topics chosen every year. Extraordinary inspections in case of incidents: Otherwise not coming unnanounced. Italy: Frequencies not always followed, prioritation criteria Multitask teams from 3 authorities CA makes inspection plans 3 – 5 days inspections + report must be completed within 3 months Plan is made based on list of criteria, based on the combination of critical points the prioritation is done Have a checklist to follow – from SMS and down into details. Training, control and procedures, maintenance, emergency most important points Croatia: Yearly plan, coordinated and thematic inspections. Inspections are coordinated. Inspectors must do 15 inspections per year. According to Slovenia: Yearly plan of inspection, only 3 explosives sites, frequencies as SIII, different topics every year, every 3. year a more in depth sms- inspection. 1 day inspections, 1 inspector pr inspection. Estonia: 2 authorities cooperate, have made a treat prognisis to set frequencies, cooperate on planning of inspections, they do unannounced inspections for pyro before christmas. Topics are: sms –based. Norway: Planned together 5 authorities every year in November – divide , checklist common Sweden: Regional inspections, common checklist for all the country, Seveso frequences, coordinated by MSB, Seveso report as basis for inspections? Germany sometimes Italy one of main elements Croatia: Yes Slovenia: Yes in combination with permits Estonia: sometimes Norway: always in combination with permits Power to enter unregulated sites? (most countries do not think they have, because they need permission to buy) Germany: have the right, but will not do Italy Yes under TULPS Slovenia: Yes Estonia: Yes Norway: Yes, according to law on flammables and explosives Test ranges and disposal sites? Sweden and Norway - some upper tier sites do this Croatia: they have sites like this, but not under Seveso Sweden: Yes

B1-3 Recommended Good Practice Inspections Provide a list of bullet points which offer advice and good practice it other inspectors for inclusion in the final MJV report. Inspect pyrotechnics sites more often than others Focus on SMS in inspections, CEOs are important to have on board Follow up your inspections, without pressure from authorities the companies might not follow up Look for repeated non-conformities from earlier inspections in the same company, this can be an indicator of good/bad quality of the safety management systems. Recommended good practice: Italy: Improvements followed up in the next inspections Typical findings: in her presentation. Have you found something unusal? Precense of incompatible materials in same building. Pyrotechnics needs more frequent inspections Germany: They look for differences in technical documentation, what is documented by the facility, checking of internal inspections, no legal actions, quite satisfied with their E + P facilities, more challenges with transport. Interesting findings? No Croatia: Coordinated inspections with other bodies. Mostly look in the safety report and withing their authorities field of work, check up follow up from inspections, will always come back and check improvememnts, can give fines or close if not followed up. Have not closed any sites yet, try to settle with the operator, Slovenia: Inspections – one under ground site UT, two bodies inspect. 5-10 people work in the facility. biggest problem is the smaller Pyrotechnics companies, who might not need a licence. Typical findings? Estonia: Look mat sms, technical surveillance, Typical findings: not good enough sms, Actions taken? Do not know Sweden: No actions taken as far as she knows Typical findings? Pyro: too much stored, Explosives companies better,