Industrial parks and the Seveso Directive

Category	Lectures
Sub-Categories	n/a
Year	2014
Author(s)	Haakon Vennemo
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Industrial parks and 	the	 	Seveso Directive 
 Haakon Vennemo, Vista Analysis Beijing, 18 November 2014 Training Workshop 	on	 management 	of	 environmental	 risk

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Seveso Directive 
• In 1976 	industrial	 accident	 in 	Seveso, 	Italy	 	• 	Fire in 	chemical	 plant, 	acute	 	emissions	 of	 hazardous	 chemicals	, 	exposure	 to 	dioxins	 	• In 1982, Seveso Directive: 	Much	 stricter	 industrial	 safety	 	regulations	 	• 	Current	 version	 is ”Seveso 	III” (2012). • 	”Seveso II” 	also	 still 	applies

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Seveso Directive 
• Industry operators and relevant 	authorities 	must have policies 	and systems 	to prevent and 	handle major accidents. • 	The larger the quantities of 	dangerous substances in an establishment, the stricter the rules.

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Chemical parks in Europe

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Chemical parks in Europe 
• A 	chemical	 park = a 	site	 accomodating	 several	 	chemical	 companies	 that	 are	 legally	 separate 	entities	. 	• 	Major 	user	 park run by 	the	 major 	user	 	• 	Closed	 park	 run by an 	infrastructure	 company	 	• 	Open park	 run by 	the	 participating	 companies	 in 	cooperation	 	• 	Clusters	 of	 chemical	 factories	 next	 to 	each	 other	, 	sharing	 	some	 of	 the	 characteristics	 of	 a proper park 	• 	Not a 	clear	 definition	 of	 industrial	 park 	• 	Most parks 	contain	 one	 or more «Seveso 	establishments»

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Chemical parks in Europe 
• 	Open parks 	are	 the	 most 	common	 	Source:-Larsen-et-al,-2012-

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Challenge: 	divided	 	responsibility	 	
Source:-Larsen-et-al,-2012-

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Challenge: The domino 	effect	 	
• 	The 	environmental	 risk 	of	 an 	industrial	 park may be 	higher	 than	 the	 sum 	of	 risks from 	each	 plant 	• 	One 	important	 channel	 is 	the	 domino 	effect	 – 	one	 	event	 sets	 off	 a 	chain	 of	 similar	 events	 elsewhere	. 	• 	Explosion	 at 	one	 establishment 	causing	 a 	projectile	 that	 	rips a hole in a tank 	holding	 dangerous	 substances	 and 	belonging	 to a different establishment

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Divided	 	responsibility	 is 	the	 	core	 	problem 
• 	Challenge I: 	Divided	 responsibility	 	• 	Challenge II: Domino 	effect	 	• 	Divided	 responsibility	 is 	the	 primary	 one	, 	since	 single 	responsibility	 reduces	 the	 risk 	of	 domino 	effect	 	• 	Some	 problems 	that	 by and 	large	 arise	 from 	divided	 	responsibility	 	• 	Which	 enterprise	 is 	the	 source	 of	 a 	specific	 pollution	 incident	 	• 	Complicated	 legal 	structure	 between	 entities	 in 	the	 park; 	who	 is 	liable	 	for 	what	? 	• 	Different standards; 	many	 big	 companies	 have 	their	 own	 internal	 risk 	management systems 	that	 may not ”	communicate	 well	” with	 others	 	• 	Fragmented	 information	; many	 different 	entities	 have 	information	 	relevant for 	assessing	 overall risk – 	how	 to 	get	 it? 	• 	High risk 	site	 = risk 	of	 terrorism

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Policies	 and systems 	of	 	Seveso Directive	 	
• 	Notification * 	• 	Major Accident Prevention Policy (MAPP) * 	• 	Safety reports 	• 	Emergency plans 	• 	Land-use planning 	• 	Information to the public 	• 	Public consultation and participation in decision-making 	• 	Inspections * 	 • 	Upper-tier establishments (i.e. high risk, due to bigger 	quantities) need to comply with all the requirements above. • 	Lower-tier establishments (i.e. low risk, due to lower 	quantities) only need to comply with Notification, MAPP, and Inspections. (With star).

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Safety	 reports 	identify	 	domino 	effects	 	
• 	“Most authorities identify and monitor potential domino 	effects establishments through the evaluation of safety reports, through site inspections, use of digital maps and notifications from the establishments.” (Larsen et al, 2012)

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Land 	use	 planning used to 	reduce	 domino 	effects	 	
• 	The Seveso Directives 	require	 countries	 to 	specify	 	safety	 distances	 between	 Seveso plants and 	its	 	neighbours	. 	• 	A separate 	lecture	 will	 talk 	about	 this	 	• 	In 	principle	 the	 concept	 of	 safety	 distance	 applies	 to 	internal	 neighours	 inside	 the	 park as 	well	 as to 	external	 neighours	 outside	 the	 park. 	• 	The European Court 	of	 Justice	 has 	recently	 reaffirmed	 	this	, 	but	 says	 that	 socio-economic	 factors	 should	 play a 	role	 in 	addition	 to 	safety	.

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Land 	use	 planning and 	industrial	 parks 	
• 	“If it transpires that smaller separation distances are 	accepted for certain (socioeconomic) reasons, then nobody can overturn such a permit by way of legal action.” • Prof-Dr.-	jur	-Hans&Jürgen-	Müggenborg	,-on-chemietechnik.de-	website	-

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Inspections	 	
• Seveso	-directives specify the following: 	• For upper-tier establishments, inspections 	every 	year • For lower-tier establishments, 	every 3 years 	• Non-routine inspections 	are carried out to 	investigate serious complaints, serious accidents and “near misses” accidents • If the inspection reveals shortcomings, the 	establishment has to implement the actions proposed by the authorities.

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Inspections	 	
• Inspections are aimed at the individual 	operator, and infrastructure company if relevant. • Inspectors and regulators have the power 	to request cooperation between operators. Practice varies between countries of the EU.

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Good	 	practice	 in 	inspections	 	and 	regulation	 	
• 	Identify	/inspect	 the	 management 	of	 some	 utilities	, 	such	 as pipelines 	• 	Require	 that	 a legal 	entity	 be 	responsible	 for operating 	the	 industrial	 park 	• 	Enforce	 the	 establishments’ 	duty	 to 	exchange	 	information	 	• 	Focus	 inspections	 on	 the	 overall 	safety	 level	 of	 the	 	park • 	Require	 establishments to have a joint 	emergency	 	plan, joint 	analysis	 of	 domino 	effects	 and joint 	emergency	 response	 organisation

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Lessons	 for China 	
• 	Even 	with	 single 	responsibility	 an 	industrial	 park 	increases	 the	 risk 	of	 domino 	effect	 and 	increases	 	environmental	 risk 	through	 this	 channel	. 	• 	The 	disadvantages	 of	 an 	industrial	 park must be 	weighted	 against	 advantages	 	• 	Economic	 benefits	 and «	circular	 economy	» 	benefits	 	• 	Shared	 monitoring	 and management 	• 	Shared	 emergency	 response	 	• 	Shared	 environmental	 technologies

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Lessons	 for China 	
• 	Estimated	 that	 over 35,000 petroleum and 	chemical	 	companies	 over 	designated	 size	 produce	 over 40,000 	different types 	of	 products	. 	• 	35 	national	 level	 chemical	 industrial	 parks and 309 	provincial	 level	 chemical	 parks. 	• 	Like European parks 	they	 may 	encounter	 domino 	effects	 and 	divided	 responsibility	 	• 	Tools for 	reducing	 domino 	effects	 are	 	• 	Land-	use	 planning 	• 	Enterprise 	level	 safety	 reports and 	policies	 requiring	 	cooperation	 	• 	Inspections

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Thank	-	you	!-

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Rasmus Raabo Reinvang
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