Health and Safety Executive
Health and Safety Executive
Energy Division’s Proposed
Policy on Targeting and
PrioritisationWIG 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 + 800 “COMAH” Sites500 Biohazard Laboratories500 Licensed Explosive Sites300 Major Hazard Pipelines50 Gas Distribution Networks6 Major Hazard Mines
Examples of onshore Inherent hazard models
EXAMPLE INTRINSIC HAZARD FACTORS
COMAH Mines Pipelines Biological agents
Nature of substance Flammable atmosphere Length of pipeline Agent
Installation type Toxic gases Nature of fluid Nature of work
On & offsite population Inrush Flammability Complexcity
Societal risk factor Rock fall Toxicity High containment work
Safety Shafts Major accident hazard
Environment Mass 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
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
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)
Overall Operator Performance
• Work in progress across HID
• Individual scores of 30-60 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
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