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M. Gerbec , B. Kontić Jožef Stefan Institute, Ljubljana, Slovenia ( marko.gerbec@ijs.si )

Implementation of the Seveso II D irective in Slovenia: survey of implementation and opinion s of operators regarding its safety benefits. M. Gerbec , B. Kontić Jožef Stefan Institute, Ljubljana, Slovenia ( marko.gerbec@ijs.si ). Scope. Background Questionnaire & Results

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M. Gerbec , B. Kontić Jožef Stefan Institute, Ljubljana, Slovenia ( marko.gerbec@ijs.si )

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  1. Implementation of the Seveso II Directive in Slovenia: survey of implementation and opinions of operatorsregarding its safety benefits M. Gerbec, B. Kontić Jožef Stefan Institute, Ljubljana, Slovenia (marko.gerbec@ijs.si)

  2. Scope • Background • Questionnaire & Results • Comments from the authorities (pending) • Wider industrial safety perspective • Conclusions

  3. Background • Seveso II Directive (96/82/EC) has been transposed into national legislation by two Decrees • Decree on prevenion of major acidents (2002); General provisions within the Environmental Protection Act (2001) • Decree on emergency planning(2002); General provisions within the Protection Against Natural and Other Disasters Act (1996) • Two ministries involved (Environment & Defence) • Updates of Decrees in 2005 and 2006 (involve 2003/105/EC)

  4. Today legal status On reduction of risks: • Decree on the prevention of major accidents and mitigation of their consequences (Uredba o preprečevanju večjih nesreč in zmanjševanju njihovih posledic),OG.RS No. 88/2005 Competence: Ministry of the environment and spatial planning (CA) • On emergency planning: • Decree on the contents and drawing up of protection and rescue plans (Uredba o izdelavi načrtov zaščite in reševanja),OG.RS No. 3/02, 17/02, 17/06. Competence: Ministry of defence, Administration of the RS for Civil Protection and Disaster Relief

  5. Number of Seveso establishments in Slovenia • 24 upper tier • 39 lower tier • Total: 63 • Source: CA (30.9.2005) (http://www.sigov.si/mop/podrocja/uradzaokolje_sektorokolje/nevarnosti_velikihnesrec/seznam_virov_tveganja.pdf)

  6. Questionnaire survey • Goals: • status of the implementation of Seveso II Directive • opinions of operators regarding its benefit to safety • Survey performed: April 2006 • # of establishments involved: • 63 (upper + lower tier) • alltogether 49 operators • Response: 63%

  7. Organization of the survey • Estabishments’ responsible persons first identified and then contacted via phone - announcement of survey • Qustionnaire sent to responsible persons via e-mail as Excel file • Responses received by e-mail (filled questionnaires) – timeframe of three weeks • Analysis done in May-June 2006

  8. Organization of the questionnaire • Altogether 37 questions • Five main topics: • General info on compliance • Approaches used to reach compliance • Relationship with ISO/OHSAS standards • Opinion on association between legal requirements and level/measurement of safety • Comments and suggestions

  9. Response • 49 responsible persons contacted (asked to fill-in questionnaires) • 31 positive responses • Difference (18): • Unreachable (no answers to phone calls & e-mail messages): 2 • no more Seveso II establishments: 3 • operator’s policy not to provide data: 1 • no response: 12

  10. RESULTS • General info on compliance: • Notifications to CA 100% • Upper tier 18 (58.1%), Lower: 13 (41.9%) • Most operators (28) responsible for one establishment • One responsible for 6 establishments • One responsible for 4 establishments • etc... See details in the Appendix

  11. 87% of SR submitted (38% within legal deadline) 19% yet accepted by CA control questions applied RESULTS 71% related SMS with standards 80-87% with SMS& MAPP 97% with ERP 81% sent to local community 29% yet approved 61% send info for LUP • Approaches used to reach compliance • Safety Report • SMS, MAPP • Emergency Planning • Relationship with ISO/OHSAS standards • # of certifications • Integration among QA/QC, and management standards • Opinion on association between legal requirements and level/measurement of safety • Contribution of SR, MAPP, SMS, and ERP to actual safety level • Need for SR, SMS, and ERP • Comments and suggestions 84% are willing to participate again in questionnaire update! See details in the Appendix 87% with ISO 9001 71% with ISO 14001 26% with OHSAS 18001 80-90% positive 80-85% positive, 65% complains on paperwork Strong opinion on cooperation, less paperwork and apply CA's monitoring of safety goals!

  12. Role and competences of CA • Conformity and compliance to standards & regulation • No clear mechanisms and procedures in both Decrees how to reach compliance • Open issues • evaluation of the level of safety? • link to licensing (EIA) for both new and existing establishments • land use planning: form of risk assessment results, cross-discipline collaboration, uncertainties in RA at strategic planning level

  13. Wider industrial safety perspective

  14. Major and occupational accidents in Slovenia Known (past) accidents and near misses: • KIK Group d.d. (gunpowder/explosives factory): • 1852 - 2002: 72 accidents, 35 casualties, 39 wounded • Nafta Lendava, Color-Medvode, Helios Domžale (synthetic resins): • several cases of batch reactor physical explosions with one casualty and other damage • Acroni, 2001 (steel works): • CO poisoning: 3 casualties as an occupational accident • various near misses involving LOX, LPG • Teol, Ljubljana, 2005: • minor NOx release, no consequences, covered by media • Fenolit d.d., Borovnica, 21.8.2006 • phenol release: 1 casualty, 1 injured (maintenance workers)

  15. Statistics and comparisons Work related accidents and fatalities in Slovenia by year Note: FAR – Fatal Accident Rate per 100,000 employees per year Source: Statistical Office of the Republic of Slovenia (http://www.stat.si/eng/index.asp )

  16. Breakdown by activity (exactly: 2.61) Conclusion: Forestry and construction workers among the most hazardous professions (similar as in other countries)

  17. Breakdown by activity (Manufacturing) Note: Code: DG - Manufacturing of chemicals, prod.&man-made fibres - with no casualties at all in time period considered

  18. Comparison with other countries • (whole national economy considered) • Sources: • Chemical Process Safety, 3rd Ed., R.E. Sanders (ed.), Elsevier, 2005 • Markowski A.S., J.Loss Prev., 18 (2005). • http://stats.bls.gov/fls/home.htm

  19. Conclusions • Operators (industry) and CA still struggle with the situation of “standing on different banks of the river” • Safety culture should be built in cooperation between public, industry and CA; authorities should check conformity with safety goals • “command and control” approach in safety arena is definitely obsolete • Uncertainty in RA deserve more attention • RA should be viewed in the context of “fit for purpose” by both industry and CA

  20. Appendix – detailed questionnaire answers

  21. a. General info on compliance Q1: Have you submitted a notification on your establishment to CA? Answers: YES: 31 (100%), NO: 0 Q2: How many establishments does your company manage?

  22. a. General info on compliance Q3: How is your establishment classified – upper/lower tier? • Upper tier: 18 (58.1%) • Lower tier: 13 (41.9%)

  23. a. General info on compliance Q4/5: Have you prepared and submitted Safety Report or Environmental Risk Reduction Policy (whichever is applicable)? Status: april 2006 10.6.2004 • YES: 27 (87.1%) 12 (38.7%) • NO: 3 (9.7%) 18 (58.1%) • no answer: 1 (3.2%) 1 (3.2%) (now) (legal deadline)

  24. a. General info on compliance Q6: Has a Safety Report or Environmental Risk Reduction Policy (whichever is applicable) been accepted by the CA yet? • YES: 6 (19.4%) • NO: 24 (77.4%) • no answer: 1 (3.2%)

  25. a. General info on compliance Q7: Does your company have approved MAPP? • YES: 27 (87.1%) • NO: 2 (6.5%) • no answer: 2 (6.5%) Q8: Have yourhave approved and implemented SMS? • YES: 25 (80.6%) • NO: 5 (16.1%) • no answer: 1 (3.2%)

  26. a. General info on compliance Q9: Have you prepared emergency plan at establishment/company level? • YES: 30 (96.8%) • NO: 1 (3.2%) • no answer: 0 (0%) Q10: Have you submitted data on risks (pertaining from SR) to local authorities for land use planning purposes? • YES: 19 (61.3%) • NO: 9 (29.0%) • no answer: 3 (9.7%)

  27. a. General info on compliance Q11: Have you submitted the emergency plan for approval to the local community? • YES: 25 (80.6%) • NO: 4 (12.9%) • no answer: 2 (6.5%) Q12: Was the emergency plan already accepted by a local community? • YES: 9 (29%) • NO: 19 (61.3%) • no answer: 3 (9.7%)

  28. a. General info on compliance Q13: Have you prepared an Information on safety measures (to the public)? • YES: 14 (45.2%) • NO: 14 (45.2%) • no answer: 3 (9.7%) Q14: Was the Information already supplied to persons liable to be affected by major accident? • YES: 10 (32.2%) • NO: 18 (58.1%) • no answer: 3 (9.7%)

  29. a. General info on compliance Q15: Have you received at least one visit from inspectorate for environmental protection in the scope of Seveso II yet? • YES: 23 (74.2%) • NO: 7 (22.6%) • no answer: 1 (3.2%) Q16: Have you received at least one visit from inspectorate for civil protection and disaster relief in the scope of Seveso II yet? • YES: 27 (87.1%) • NO: 4 (12.9%) • no answer: 0 (0%)

  30. b. Approaches used to reach compliance Q17: How was Safety report or Env. Risk Reduction Policy prepared? • not yet prepared: 2 (6.5%) • fully done by consultant: 1 (3.2%) • together with a consultant: 17 (54.8%) • fully done "in house" 11 (35.5%) • no answer: 0 (0%)

  31. b. Approaches used to reach compliance Q18: Safety Management System (SMS) was defined, approved and documented? • not yet prepared: 2 (6.5%) • fully done by consultant: 1 (3.2%) • together with a consultant: 13 (41.9%) • fully done "in house": 14 (45.2%) • no answer: 1 (3.2%)

  32. b. Approaches used to reach compliance Q19: How many full time employees at company level are working on safety, occupational safety and emergency preparedness? Info gathered: • Question was ambigous. • Only Safety engineers targeted. • Lesson: industry considers safety in a wider sense, including personnel for security, firemen, safety personnel, etc.!

  33. b. Approaches used to reach compliance Q20: How many employees at company level are working at safety, occupational safety and emergency preparedness as their basic task? Info gathered: • comparably less people devoted to safety (see Q19)

  34. b. Approaches used to reach compliance Q21: How many employees does a company have? • Info gathered: • No direct relation with quantities of dangerous substances • A number of upper tier establishments with only 35 – 100 employees

  35. c. Relationship with ISO/OHSAS Q22/26: Is company certified according to any ISO/OHSAS standard?

  36. c. Relationship with ISO/OHSAS Q27: How did you integrate the Safety Management System (SMS) within exisiting systems and standards for management? • SMS not yet implemented: 1 (3.2%) • SMS and standards not related: 6 (19.4%) • SMS related to standards: 10 (32.3%) • SMS fully within standards: 12 (38.7%) • no answer: 2 (6.5%)

  37. d. Opinion on asociation between legal requirements and level/measurement of safety Q28: How did introduction of SMS influence actual level of safety at your establishment? • no impact, only overburden: 3 (9.7%) • no impact: 2 (6.5%) • minor positive impact: 16 (51.6%) • certainly a positive impact: 9 (29.0%) • no answer: 1 (3.2%)

  38. d. Opinion on asociation between legal requirements and level/measurement of safety Q29: How did preparation of a Safety Report or ERRP influence actual level of safety at your establishment? • no impact, only overburden: 1 (3.2%) • no impact: 2 (6.5%) • minor positive impact: 19 (61.3%) • certainly a positive impact: 8 (25.8%) • no answer: 1 (3.2%)

  39. d. Opinion on asociation between legal requirements and level/measurement of safety Q30: How did preparation of Safety Report or ERRP influence safety measures, procedures, or devices at your establishment? • no improvements done: 2 (6.5%) • no improvements were necessary: 1 (3.2%) • yes, minor improvements done: 19 (61.3%) • yes, we are certainly safer: 7 (22.6%) • no answer: 2 (6.5%)

  40. d. Opinion on asociation between legal requirements and level/measurement of safety Q31: Did preparation of Emergency Plan impact in any way actual level of safety at your establishment? • no impact, only overburden: 0 (0%) • no impact: 2 (6.5%) • minor positive impact: 18 (58.1%) • certainly a positive impact: 10 (32.3%) • no answer: 1 (3.2%)

  41. d. Opinion on asociation between legal requirements and level/measurement of safety Q32: Are the legislation and documents considered needed? • no, completely unecessary: 1 (3.2%) • I have no opinion: 1 (3.2%) • yes, needed to minor extent: 9 (29%) • yes, certainly needed: 20 (64.5%) • no answer: 0 (0%)

  42. d. Opinion on asociation between legal requirements and level/measurement of safety Q33: Are the obligations and documents considered only a "paperwork"? • completely unnecessary: 3 (9.7%) • I have no opinion: 1 (3.2%) • needed, however duplications: 20 (64.5%) • needed, no matter of paperwork:6 (19.4%) • no answer: 1 (3.2%)

  43. d. Opinion on asociation between legal requirements and level/measurement of safety Q34: Legal framework should establish a required level of safety. As safety culture can not be a subject of prescription, what kind of cooperation among the public, indstry and CA do you expect/suggest in the context of developing safety legislation?

  44. d. Opinion on asociation between legal requirements and level/measurement of safety Q35: How do you evaluate existing safety regulation and support that competent authorities provide for its implementation?

  45. e. Comments and suggestions Q36: Please suggest detailed improvements related to previous question (Q35) – if applicable? interpretation: • Regulation is inconsistent, unclear and should be improved especially regarding measurements and indicators of safety • CA and inspectors should get familiar with the installation they evaluate and control (e.g. site visits compulsory in the framework of reviewing Safety Report) • Uncertainties in RA should be a question of open discussion between an operator and CA • Competence of CA in the field of RA should be improved (methods, tools, uncertainty evaluation, decisions) • ... additionally from direct communication: • Consultants should act as moderators between operators and CA • CA should promote support of consultants • Operators and CA should work together on risk research policy

  46. Is the questionnaire of this kind relevant and useful? Q37: Are you willing to participate in a similar survey after a certain period of time (a year, two, or more)? • YES: 26 (83.9%) • NO: 2 (6.5%) • no answer: 3 (9.7%)

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