CCA Workshop on SR SEVESO II The Major Accidents Hazards Bureau (MAHB) of the EC Joint Research Centre (JRC) Safety Reports: Approaches and Challenges Observations from the MJV Programme Maureen Wood

CCA Workshop on SR Inspections (Art. 18) Mutual Joint Visits Programme Designed to exchange best practices amongst Member State Inspectors, thereby ensuring a consistent implementation of the Seveso II Directive First round almost complete

CCA Workshop on SR Inspections (Art. 18) Mutual Joint Visit (MJV) Programme on Seveso II Inspections –Launched in 1999 with a visit to the Netherlands –Technical exchange for Seveso II inspectors –12 countries have hosted a meeting ( ) –Over 175 different inspectors from Member States, Candidate Countries and EEA/EFTA –Over 70 competent authorities (national, regional, local) –Industry - the European Process Safety Centre (EPSC)

CCA Workshop on SR MJV Links to Safety Reports In numerous MJVs, a frequent subject of discussion has been the production, use and review of safety reports.

CCA Workshop on SR MJV Links to Safety Reports The Seveso Directive makes a direct link between inspections and the safety report...Such inspections or other control measures shall be sufficient for a planned and systematic examination of the systems being employed at the establishment, whether of a technical, organizational or managerial nature, so as to ensure in particular:...that the data and information contained in the safety report, or any other report submitted, adequately reflects the conditions in the establishment, occurrence, prevention and mitigation of major accidents. Seveso II Directive, Article 18 on Inspections

CCA Workshop on SR Additional MJV Links to Safety Reports In addition to the explicit link between safety reports and inspections in the Seveso II Directive, safety reports are also discussed in MJVs because, among other reasons: –Many MJVs have featured extensive overviews of their Seveso implementation practices, including safety report review and guidance. –In some countries the inspectors also play a strong role in the review of safety reports.

CCA Workshop on SR MJV - Special Topics

CCA Workshop on SR Recurring Themes Criteria for judging adequacy of safety report How much documentation is required Limits of responsibility of the competent authorities Management of resources for reviewing/inspecting against safety reports Is the review/inspection process effective or is there a better way?

CCA Workshop on SR Safety reports and inspections Differences noted between Member States in: Influence of inspectors over safety report content (proactive vs. hands-off) Role of inspectors in safety report review (lead role vs. collaborative vs. no role) Emphasis placed on safety reports vs. inspections

CCA Workshop on SR General Implementation Issues Differences in Member States noted in: Documentation requirements (What is essential? how much is too much?) Who reviews safety reports (third parties; number of involved competent authorities;) Length of review process (turn-around time, number of steps in the review process, etc.) Final status of safety reports (dynamic vs. static, i.e., can be revised frequently vs. once every 5 years or for major changes)

CCA Workshop on SR General Implementation Issues Common challenges noted: How to define an adequate safety report What is the appropriate level of detail? Uniformity of requirements imposed on each establishment (how does the system encourage or discourage consistency?) Dealing with installations that have not submitted safety reports Co-ordinating safety report evaluations between competent authorities

CCA Workshop on SR Final Reflections The development of safety reports is still in the process of maturation. At the moment many Member States are still refining and testing their procedures and thus may be particularly receptive to feedback from other programmes. Differences in approaches to Seveso requirements, such as safety reports and inspections, are often representative of differences in safety culture and priorities in Member States but not effectiveness. Nonetheless, comparisons can offer insights necessary for identifying what makes a programme effective. Over time it should be possible to push exchanges (in MJVs and other forums) more towards focusing on key success factors and solutions to common problems.