Health and Safety Executive Health and Safety Executive Energy Division’s Proposed Policy on Targeting and Prioritisation WIG Conference 18 September 2013 Susan Mackenzie [2013/326517]

HSE’s Intervention Policy Enforcement Policy Statement –Targeting, Proportionality, Consistency, Transparency, Accountability HID guiding principle (2012) –Major hazard intervention programme should be based on a systematic approach based on inherent hazard and performance of duty holder in controlling risk

Major Hazard Sites in UK 288 operational installations “COMAH” Sites 500 Biohazard Laboratories 500 Licensed Explosive Sites 300 Major Hazard Pipelines 50 Gas Distribution Networks 6 Major Hazard Mines

Priority for Intervention Risk Ranking Inherent Hazard Operator Performance Other Intelligence

Examples of onshore Inherent hazard models EXAMPLE INTRINSIC HAZARD FACTORS COMAHMinesPipelinesBiological agents Nature of substanceFlammable atmosphereLength of pipelineAgent Installation typeToxic gasesNature of fluidNature of work On & offsite populationInrushFlammabilityComplexcity Societal risk factorRock fallToxicityHigh containment work SafetyShaftsMajor accident hazard EnvironmentMass transport U/G population Escape distance

Inherent Hazard Model Offshore Offshore Working Group (March 2013) Principles Broad classification Information readily available Preferably based on industry’s own information Major hazard focussed

Broad Classifications on Inherent Hazard High Medium Low Pictorial view Not based on a mathematical algorithm Will require some professional judgement

Example – Draft 5

Inherent Hazard based on PLL

Operator Performance Operator’s performance in complying with the law to control Major Hazard risk will influence the depth and frequency of regulatory scrutiny. Operator Performance against single inspection topics –Strategic areas –Key risk control systems –Based on standards

Offshore inspection rating topics

Inspection guides Cover strategic and sector topics Define what we look at The standard/benchmark against we rate performance Performance score Enforcement expectations How we record (COIN requirements)

Operator Performance

Overall Operator Performance Work in progress across HID Individual scores of are compliance gaps Do not intend to “average” out compliance gaps. A full picture of performance will be built up over a number of years We will continue to feedback performance at each inspection in usual way

Other intelligence may include [Nothing New] Time since last inspection Issues arising out of other regulatory contact such as –safety case assessment –incident investigations –complaints Incident data Emerging issues

The concept of Indicative Resource Levels

Inspection plan progress report

Any further questions