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Experiences off the Netherlands with the the implementation of the Seveso Council-2 Directive : Learning lessons for Slovakia Theo de Gelder Dutch Ministry of Environment
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Safety Management System (Theo) 2 Dutch experiences with the implementation of the accident act 2003: a national evaluation four years after the implementation of the act Common need to improve the compliance of the accident act Safety performances can only be achieved by cooperation between authorities and cat. A & B operators
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Safety Management System (Theo) 3 Dutch experiences with the implementation of the accident act Responsives: 95 operators category A & B 47 municipalities 7 provinces 28 labour inspectors 37 regional fire departments 9 environmental agencies 11 others
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Safety Management System (Theo) 4 Dutch experiences with the implementation of the accident act Identified elements 1. Knowledge, information, tools, documentation 2 One counter desk thought (focal point) 3. Capacity / workload 4. Publicity 5. Time 6. Safety management system 7. Safety report 8. Inspections 9. Common conclusions 10. Recommendations for Slovakia
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Safety Management System (Theo) 5 Dutch experiences with the implementation of the accident act 1. knowledge, information, tools, documentation: Lack of know-how mostly at the enterprises, municipalities and fire departments Labour inspectors are more skilled No applicable instrument to determine domino-effects Authorities not always able to answer questions how to do by enterprises. Report of information requirements, assistances, national helpdesk and other guidelines much used
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Safety Management System (Theo) 6 Dutch experiences with the implementation of the accident act 2. One counter desk thought (focal point): Start: great intention for cooperation Not always feasible Sometimes contrariety and conflicts in assessments Problem: planning coordination Different cultures/point of views between ministries National versus regional differences
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Safety Management System (Theo) 7 Dutch experiences with the implementation of the accident act 3. Capacity / workload: 90% enterprises supported by consultants Extra capacity needed for governmental offices and enterprises Extra costs for 1/3 of all cat. A and B operators 5000-65000 euro’s 45% 100000-250.000 euro’s 40% 500.000-1.000.000 euro’s 15%
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Safety Management System (Theo) 8 Dutch experiences with the implementation of the accident act 4. Publicity: Active information supply to the public Recommendable: two versions of the safety report beceause of confidential information Doubts about the use and effectiveness of information supply to the public “Sensitive” information for terrorism ?
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Safety Management System (Theo) 9 Dutch experiences with the implementation of the accident act 5. Time: Complaints: all governmental work / actions takes too much time Enterprises: we comply the legal time schedules
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Safety Management System (Theo) 10 Dutch experiences with the implementation of the accident act 6. Safety management system: The interest of the introduction of a SMS is agreed Contribution to a greater awareness of risks Complaints enterprises: parts of a safety report does not connect to existing management of quality systems
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Safety Management System (Theo) 11 Dutch experiences with the implementation of the accident act 7. Safety report: The assessment by the authorities is too much theoretical in stead of practicable Parts seems to be very useful Drawing up a safety report according to Seveso takes more effort than the former internal and external safety reports Too much details (avoid to create a paper tiger) Agreement about enforcing but no exaggeration ! ! Labour demands more than the Report Information Requirements (own documentation) Interregional differences The term acceptable risk mentioned in the dutch act is difficult to judge
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Safety Management System (Theo) 12 Dutch experiences with the implementation of the accident act 8. Inspections: Very first inspections coordinated and cooperated Coordination and rejection are declining now Assessments by authorities are mostly fair and reasonable The final notification to the management takes too long Inspection frequency was too high. Nowadays realistic
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Safety Management System (Theo) 13 Dutch experiences with the implementation of the accident act 9 Main conclusions Improvement of awareness of risks, scenario’s, means to be taken, sms, observable reduction of risks Improvement on emergency planning, plans, disaster and fire fighting, learning effect with cooperation was disappointing Lack of capacity (time and know how) Lack of rejection for regulation, developing criteria standards and policy Lack of willingness and responsibility to achieve a solid cooperation and safety performance Lack of guidelines, assistances, standards, instruments The implementation needs time and money Focal point and coordinating body did not work proper but is necessary !!
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Safety Management System (Theo) 14 Dutch experiences with the implementation of the accident act RECOMMENDATIONS Agreement about goal safety performance Achievement by common approach and cooperation between operators and authorities Unification of common work-processes to improve cooperation Development of standard specifications SR, SMS, skills etc Focal point / national helpdesk / centre of expertise Development of common training programmes Foundation of an “’Industrial University” (exchange platform) Industry should make use of the line of business they belong
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Safety Management System (Theo) 15 Dutch experiences with the implementation of the accident act RECOMMENDATIONS Organise regional work conferences for all parties (operators and authorities) Coordinating body is responsible for the assessment report Avoid peak loading and inefficiencies by double work Parties involved: do give feed back on policymakers in order to adjust the accident act and legislation and to develop or improve tools As EU-member make use of the IMPEL-network ! Thank you good luck !
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