1. SAFETY MANAGEMENT SYSTEMS IN APPLICATION OF THE SEVESO II DIRECTIVE LESSONS LEARNT FROM IMPLEMENTATION IN SMEs O. Salvi, I. Vuidart, M. Caumont, F. Prats Institut National de l ’Environnement Industriel et des Risques Parc Technologique Alata, BP 2, F- 60 550 Verneuil-en-Halatte, France Phone: +33 3 44 55 61 01, fax: +33 3 44 55 62 95, email: Olivier.Salvi@ineris.fr Recommandations and proposal Improving the interest in major hazard prevention  need to convince top management with arguments  Reduction of financial loss in case of an accident, due to the destruction of the production equipment and the loss of production, and of market shares  Preserving the image of the enterprise (media impact)  Diminution of insurance costs  Building a communication policy with the stakeholders þInvolving the personal in the MAPP  MAPP is the foundation of the SMS for both ‘low tier’ and ‘high tier’  Commitment of the enterprise / direction  Long term objectives with continuous improvement process  Structures and means to fulfil the objectives  Involvement of all employees (consulting them with questionnaires, debates) þReinforcing the responsibility of the operator  self-controlled systems based on PDCA principle  Operator has the best place to identify the hazards and to allocate the means to prevent them  Inspection to guarantee the good functioning of the SMS  Inspection to perceive safety culture þUsing risk analysis as a fundamental tool  use input data to identify potential accidents, evaluate their likelihood and severity, determine reducing measures  Gathering various persons involved in the functioning of the enterprise  Ranking to define priorities for actions  Reiteration of the evaluation Based on the results of the enquiry, INERIS has developed a tool to analyse risks linking both technical and organisational aspects. This risk analysis method is called ATOS, for Analyse of Technical and Organisational Safety. The model used in ATOS considers that the organisation is seen as the interaction of three elements : the safety technical elements (tools, equipment…), the system (activities, processes, procedures) and the people. The SMS is described as the structural aspect of the organisation, in other words, the treacability of the prevention system in place, called the FORMAL, see figure 3. The Human Factor is approached from the sociological angle, using a tool called “l’analyse stratégique” that aimed at assessing the organisation efficiency, integrating power plays and cultural aspects of the organisation. This represents the INFORMAL side of the organisation. Practically the analysis with ATOS is operated by teams composed with engineers and sociologists through the following steps : - a classical technical risk analysis, - the identification of the activities required to be assured for the efficiency of the line of defence identified through the risk analysis, - a sociological analysis to assess what truly happens, beyond what is written. At the moment, the concept is developed and it is intend to implement it in the forthcoming months with industrialists, particularly SMEs working in chemical industry. 1. The enquiry Enquiry progress and results To carry out the enquiry, a working group has been constituted. During one year, it met several industrialists and expose them the requirements of the directive and collect their reactions. To facilitate the discussion, INERIS elaborated a manual with slides to address the following points : Context and objectives An informal enquiry was launched to anticipate the implementation of Major Accident Prevention Policy (MAPP) and Safety Management Systems (SMS) required by the Seveso II Directive. The objectives of the enquiry was to better know the needs of industrialists, in particulare SMEs, to propose solutions : tools, methodologies, information… Risk Control Technical risk control measures Policies, various structures:QHSE Safety management STRUCTURE Procedures for risk control Organisational culture FORMAL policies structures procedures INFORMAL culture(s) relationship powers... (tangible and intangible features) L.O.D ORGANISATIONAL ACTIVITIES FOR L.O.D ASSURANCE Resources Output « Safety » culture, relationship, strategic games. 2. Perspectives Roles, responsibilities Decision making Communications Skills Monitoring, continuous improvement Management Co-operation INFORMAL sociological approach FORMAL SMS structure 1 Organisation and personnel Identification and evaluation of major hazards Operational control Management of change Emergency preparedness Learning from experience Audits & Review 2 3 4 5 6 7 1 2 3 4 5 6 7 Figure 2 : formal and informal components of safety organisation Figure 3 : risk control model in ATOS A risk analysis linking technical and organisational aspects The SMEs are structured to produce. Regarding safety, they bet on their reactivity and on the informal component of their organisation. Due to the regulation requirements, their strategy should evolve, but they can’t adopt full formal safety management systems. See Figure 1 and 2. Figure 1 : various efficient organisational safety approaches þObservations and objectives related to SMS implementation þPresentation of the contents of the Seveso II directive þBrief description of operator’s documents that could be part of the PPAM and SMS Constitution of a working group at INERIS We identified some recurrent success factors : þStrong implication of the top management right from the beginning þExistence of a Management Systems : ISO 9000 or 14000 þExistence of a safety culture