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

Priority for Intervention

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

Example – Draft 5

Inherent Hazard based on PLL

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

Offshore inspection rating topics

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)

Operator Performance

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

The concept of Indicative Resource Levels

Inspection plan progress report

Any further questions