mhfr major hazard facilities regulations

8/12/2019 MHFR Major Hazard Facilities Regulations

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Major Hazards DivisionNovember 2001

OccupationalHealth and Safety(Major Hazard

Facilities)Regulations

Overview


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WorkCovers Role

a)reduce the likelihood of a major incident occurring; andb)reduce the consequence to health and safety and damage to

property in the event of a major incident

Victorian WorkCover Authoritys mission statement is

To work with all Victorians to progressively reduce theinc idence , sever i ty and co s t to the com m uni ty of w ork- related injury and disease.

The objectives of the Major Hazard Facilities Regulations is toprovide for the safe operation of major hazard facilities inorder to -


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Support Program for the MHF Regs

Guidance Notes

Facilitate production of Exemplar Safety Cases

CEOs Briefing Safety Case Officers

Stakeholder Education

Meetings with Industry Groups

MHAC

Website


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Aims and Objectives of today

Introduction to MH Control

Introduce the MHF Regulation

General Duties and obligations

Safety related duties and obligations

Outline key success factors in initial steps

HSR Consultation requirements

Introduce the key concepts


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Occupational Health and Safety(Major Hazard Facilities)

Regulations

Background to Major HazardsControl


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Why Major Hazards Control

The need for specific Control of MajorHazards

Changing scale & complexity of chemical facilities Advanced technology - unforseen hazardsChanging community perceptionsRange of Major Accidents that have occurredPrescriptive approach has proven inappropriate

This has lead to Regulation where:The operator decides on the appropriate means of majorhazard control for the facility, and prepares a Safety Casedemonstrating thisThe Regulator assesses and audits against the Safety Case


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What are MHFs

Need for Control of Major HazardsChanging scale and complexity of facilitiesAdvanced Technology (possible unforseen hazards)

Changing Community perceptionsA range of Major Accidents that have occurredPrescriptive approach has proved inappropriate

Sites that store, handle or process dangerous goodsin large quantities and have the potential for majorincidents, the consequences of which may potentiallyrival this of natural disasters in terms of loss of life,

injury and damage to property.


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History of Major Hazards Control

1970s (mainly Onshore Europe)

DRIVERSFlixborough UK (explosion and fire, 28 fatalities)

Seveso Italy (severe environmental contamination)

RESPONSESUK HSE establishes Major Hazards Advisory UunitUK CIMAH Regulations (~10 years to implement)European Seveso Directive

The Safety Report approach. Operator has to describe safety management to the Regulator.


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1980- 90s (Onshore USA & Europe)

DRIVERSBhopal India (toxic release, several thousand fatalities)Phillip 66 Texas (explosion, 23 fatalities)

Basle Switzerland (environmental contamination of Rhine)

RESPONSESAlChemE Center for Chemical Process SafetyUS Government OSHA Process SafetyEmergency Management Plans. Community right -to- know Seveso II and COMAH. Integration of safety & environment

The Safety Case approach. Operator has to convince Regulator on safety management.


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1980- 90s (Other Industry Applications)

DRIVERSPiper Alpha oil platform ( explosion & fire, 167 fatalities)Herald of Free Enterprise Ro-Ro ferry (capsize, 193 fatalities)

Kings Cross Railway Station (fire, 31 fatalities); and ClaphamJunction (crash, 35 fatalities)

Cross-industry communication

RESPONSES

Offshore Safety CasesIMO International Safety Management (ISM) CodeRail Safety CasesGas System Safety Cases


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International History

A base of Safety Law was in effectPrescriptive regimes were in placeThere was no real focus on Major Hazards

Common Findings & Recommendations

Conclusion : I mplement Performance Based Approach

Major Hazard AccidentsFlixborough 1974Piper Alpha 1988

Clapham Junc 1990Coode Island 1991

Legislative DeadlineCIMAH (UK) 1984Offshore SC (UK) 1993

PSLA Safety Case 1996 Rail Safety Case (UK) 1994National Standard 1996

History of the Safety Case


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Evolution in Victoria

1991 Coode Island Fire

1991 WorkSafe commenced National Standard

1996 National Standard for Control of MHF published

1997 Amendment to Storage & Handling Regulationsallowing adoption of National Standard

1998 Longford Incident

1999 Longford Royal Commission Report2000 Major Hazard Facilities Regulations enacted

(Enhanced legislative arrangements - like Seveso II)


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Regulations

Introduction to Regulations


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Key Principles of MHF Regulations

Places the responsibility of the facility operator

Focus on major hazards (catastrophic events)

Proactive Risk Based Approach

Operator actively has to demonstrate safeoperation

Regulator peer review of this, tied to a licence

Addresses both on-site and off-site safetyConsultation required at all critical stages

Change culture towards major hazards


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Link to other VWA Regulations

DG Act

OH&S Act

AsbestosRegulations

CertificationRegulations

Confined SpacesRegulations

IssueResolution

IncidentNotification

ManualHandling

NoiseRegulations

Major HazardFacility

Regulations

PlantRegulations

DG Transport Act

Dangerous Goods(S&H) Regulations

ExplosiveRegulations

Haz SubstancesRegulations


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Overview of Structure ofRegulations

IntroductionApplication 1. Preliminary2. General Provisions

3. Safety Duties of Operators4. Safety Case5. Consulting, Informing,

Instruction & Training

6. Duties of Employees

7. Registration8. Licensing

9. Protection of Property

Operator

Obligations

Obligations ofEmployees

Administration

Property

OH&SAct

10. Amendments toDangerous

GoodsRegulations

ExemptionsDG Regs

DGAct

Main Parts


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Structure of MHF Regulations

Schedules(contain detailed requirements or specifications)

1. Materials at major hazard facilities (and theirthreshold quantities)

2. Additional matters to be included in SafetyManagement System

3. Matters to be included in Emergency Plans4. Additional matters to be included in Safety Case

5. Licence Fees


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Major Hazard Focus of theRegulations

Frequency

OHS risksalreadyregulated

Very high risks

should alreadybe eliminated

MinorRisks

Major Hazards

risks focus ofMHF Regs

The focus of the Major Hazard Facilities Regulations is on thehigh consequence (catastrophic) but low frequency incidents


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Scope and Boundary ofRegulations

Major Hazards Only

Schedule 1 materials only (from National Standard)

Primarily sites exceeding the aggregate threshold

Both On-site and Off-site risk

Coordination between sites as necessary

Includes material in process

Includes material that could escape on-site from aconnected pipeline, not not the pipeline itself

Excludes ships. Excludes road and rail vehicles, unless on-site for extended periods. Includes goods loaded and

unloaded from transport.

Objective of the Regulations is to provide for the safe operationof Major Hazard Facilities.


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Structure of the MHF Regulations

101 Objective102 Authorising Provisions103 Commencement:

104 Definitions105 Application of Regulations

106 Application of Regulations to Employees (+contractors) 107 Application of Part 3, 5 & 9

2) Compliance must be so far as practicable for the first 30 months 3) Compliance must be complete thereafter.

(1) These regulations (other than regulation 801) come into operation onthe day on which they are made.

(2) Regulation 801 (Only licensed or registered MHF to be operated) comesinto operation 1 September 2000 .

1. PreliminaryIntroduction/ Application


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2. General ProvisionsIntroduction/ Application

201 Authority may require information202 Process for certain decisions of Authority

Provisions that Apply Generally

Only applies to: refusal to grant, renew or transfer a licence refusal to register variation of Terms and Conditions cancellation or suspension of licence decision steps, not basic safety obligations

203 Exemptions from Parts 3 to 8 .

Authority must conduct an inquiry notify any person affected by the decision invite them to make submission must consider decision VCAT appealable by Operator only (OHS Act limitation) decision stayed during appeal


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This requires the Operator to establish a comprehensive RiskManagement structure for the facility including:

Hazard Identification (R302)

Risk Reduction (Control Measures) (R304)

Safety Management System (R301)

Safety Assessment (R303)

Emergency Planning (R305)

Review of Risk Controls (R306)

3. Safety Duties of OperatorsOperators Obligations


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Part 4 Safety Case defines, in conjunction withSchedule 4, what must be in a Safety Case.

Part 4 separates the reporting obligation related tothe Safety Case from the obligation (under Part 3) toestablish and maintain systems for safe operationof the facility.

This is to ensure the focus appropriately remains onthe primary objective of the regulations, which is to p rom ote the safe operat ion o f MHFs .

4. Safety CaseOperators Obligations


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501 Consultation with health & safety representativesif practicable include requirement of the Act

502 Informing, instructing and training employees

503 Further information and access to documents

504 Non-employees at the facility

505 Local communitysummary of the safety casecopy of licence including terms and conditions

506 Further information on request

4. Consulting, Informing,Training & InstructingOperators Obligations


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Part 6 requires that

(1) Employees must follow operators proceduresregarding major hazards control

Employees must follow operators emergencyprocedures

Employees must immediately inform theoperator of any circumstances that could lead to a

major incidentCorrective action must be taken if this ispossible and safe to do so

(2) The above should be done

in good faith

6. Duties of EmployeesAdministration


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Part 7 deals with:Notification by existing MHFs to the Authority

Notification by intended MHFs to the Authority

Notification by sites with greater than 10% of threshold

Content of Notification

Ability for Authority to determine 10% plus sites

Inquiry before making determinationRegistration

Obligation of Registration - Safety Case OutlineExpiry of Registration 30 months

7. RegistrationAdministration


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To obtain a license to operate a MHF an operator must:prepare a Safety Case in accordance with the requirements;

provide the Safety Case within the prescribed timeframe

(24 months) & in accordance with the safety case outline; andpay the prescribed fees

To issue a MHF license the Authority must be satisfied that:the safety case has been prepared in accordance with regulation 402;

the operator has complied with Part 3;the operator has the ability to operate the MHF safely; and

the operator has complied with Part 5.

8. LicensingAdministration


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805 Terms and Conditions 806 Transfer of licence

807 Availability of Licence

808 Suspension and cancellationIf the SMS is no longer a comprehensive way of maintaining controlsIf control measures are deficient3 prosecutions in life of licenceOperator no longer understands content of safety assessment

Licence obtained on basis of false or misleading information or failure todisclose

809 Surrender of Licence810 Notification in Government Gazette

8. LicensingAdministration


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1001 Modifies the existing exemption ability of 110 inthe DG (Storage and Handling) Regulations 1989

Exemptions from the Explosives regulations were moved to thenew Dangerous Goods (Explosives) Regulations 2000.

The new Dangerous Goods Regulations remove generalrequirement for licensing of dangerous goods storages.

10. Amendments to DGRExemptions


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Demonstration in Safety Case

The Safety Case must demonstrate that the:Control measures are adequate to eliminate or reduce as far aspracticable risks associated with Major Incidents; and that theSMS is a comprehensive management system for all controlmeasures.

This is the key understanding the purpose of the Safety Case.

Demonstration is typically achieved through:

Reference to Codes of Practice, Standards, Guidance, etc.(although the appropriateness of these to the particular facilitymust be established)Through risk assessment (qualitative or quantitative)


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What Makes a Good Safety Case?

It must demonstrate that the operator: Understands their process / systemsUnderstands and communicates their risksSelects and implements appropriate control measures to reduce risksas far as practicableWill keep the control measures workingWill review and revise if necessary

Ownership

Answer the question :Why should I be allowed to

operate this facility


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Key Success Factors

Commitment of right resources

Early momentum

Effective Real Consultation

Preparedness to challenge established norms orparadigms

Focus in improving safety not simply compliance(regulatory or internal) or the paper trail

Transparency

All these need to be driven from the top


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Ultimate Objective

Safer Sites


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Regulations

Fundamentals of Major Hazards -HAZID and Safety Assessment


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Safety Case Methodology (indicative)

Hazard Identification

Define Safety Critical Activities

Major Incident Events

Performance Standards

Systems Integrity

Risk Analysis

S af e

t yM

an a g em

en

t S y s t em

Implementation

Non-MIE (ie OH&S)

D em on

s t r a t i on of

A d e q u a c y


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HAZID and Safety Assessment

Recurrent ThemesA trigger (eg operations and maintenanceprocedures incorrect or violated)

Other latent failures Other process/storage areas vulnerableEmergency systems vulnerable/inadequatePeople unnecessarily exposed to risk

Inappropriate emergency responseFAILURE TO IDENTIFY AND UNDERSTAND ALLTHE HAZARDS, AND TO IMPLEMENT ANDMAINTAIN SUFFICIENT CONTROLS


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HAZID and Safety Assessment

The MHF Regulations respond to this by requiringcomprehensive and systematic identification andassessment of hazards

HAZID and Safety Assessment must haveparticipation by employees, as they haveimportant knowledge to put in, and also will gainimportant learning

These employees MAY BE the H&SRepresentatives, but DO NOT HAVE TO BE

However, the H&S Representatives should beconsulted in selection of appropriatepersons


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Hazard and Incident Identification

What can go wrong?

What incidents or scenarios could arise asa result of things going wrong?

What could cause or couldcontribute to these incidents?


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General Approach to HAZID (GN13)

Existing studies

Define boundary System description

Divide system into sections

Systematically record all hazards

Independent check

Revisit after safety assessment

Hazard Register

Selected methods

asset or equipment failureexternal eventsprocess operational deviationshazards associated with all materialshuman activities which could contribute to incidentsinteractions with other sections of the facility

Analyse each section


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Examples of HAZID Techniques

General MethodsChecklists - identifies whats on the list!

Brainstorming - whatever anyone can think of

What If Analysis - possible outcomes of change

Historical records - what has happened in the past

Specialist Methods

HAZOP - identifies process plant type incidents Task Analysis - maintenance etc incidents

FMECA - equipment failure causes

Fault Tree Analysis - combinations of failures

Consider the Past Present and


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Consider the Past Present andFuture

Existingconditions

Futureconditions

Historicalconditions

What has gone wrong in the past?

What could go wrong currently?

What could go wrong due to change?

Root CauseHistorical RecordsProcess ExperienceNear Misses

IdentifiedHazardsHAZID Workshop

HAZOP StudyScenario DefinitionsChecklists

Change ManagementWhat-If JudgementPrediction

unforeseeable


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The HAZID must be Realistic

It is tempting to disregard Non -Credible Scenarios BUT Non -credible scenarios have happened to others Worst Cases are important to emergency planning

You should consider combinations of failures/eventsequipment can be off-linesafety devices can be disabled or fail to operateseveral tasks may be concurrentprocedures are not always followedpeople are not always availablehow we act act is not always how we plan tothings can take twice as long as plannedabnormal conditions can cross section limits


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The HAZID must be realistic

Conversely:

do not consider things that are clearly hypothetical

try to place a limit on how deep you go in the HAZID, or youwill never finish

dont spend time discussing trivial events

The way things should work is not always the way thingsactually do work.

Any such assumptions should be challenged during thecourse of the HAZID.


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The HAZID Team

No single person can conduct a HAZID.

A team approach is required.

A typical team composition would be:Facilitator

Safety Manager or Safety Engineer

Persons from Operations and Maintenance teams

H&S Representative

Others as needed

Technical Scribe


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The HAZID Meetings

Hold on-site if possible

Avoid interruptions if possible

Schedule within the normal work pattern, orwithin the safety case activities (say 3 hours perday, 3 days per week)

Meetings less than 3 hours are not effective

Meetings that last all day are also not effective

Dont underestimate the time required


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Safety Assessment (GN14)

Any analysis or investigation that contributes to theunderstanding of any or all aspects of the risk of majorincidents, including their:

Operators must carry out Safety Assessments in orderto have a comprehensive and detailed understanding ofall these aspects for all major incidents and theircauses.

causes

likelihoodnatureconsequencesmeans of control


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Typical Risk Matrix

Likelihood -> Never heard of Has occurred Has occurred Occurs often Occurs often

Consequence in industry in industry in company in company at site

No Injury LOW LOW LOW LOW LOW

Slight injury LOW LOW MED MED MED

Minor injury LOW MED MED HIGH HIGH

Major injury MED MED HIGH HIGH VERY HIGH

Fatality MED HIGH HIGH VERY HIGH VERY HIGH

Multiple fatality HIGH HIGH VERY HIGH VERY HIGH VERY HIGH

VERY HIGH Rectify immediatelyHIGH Rectify with urgency, unless clearly impracticableMED Reduce risk as far as practicableLOW Accept, but manage through competency and awareness


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Types of Safety Assessment

QualitativeAssessment

Quantitative Risk Analysis Asset Integrity Studies

Plant Condition Analysis Human Factors Studies

Consequence AnalysisLikelihood Analysis

Technology Studies

HazardIdentification

Detailed Studies

How Much and What Type of


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How Much and What Type ofAssessment?

Greater Assessment detail providesmore quantitative information andsupports decision-making

Strike a balance between increasingcost of Assessment and reducinguncertainty in understanding

Pick methods that reflect the nature ofthe risk, and the decision options

Stop once all decision options aredifferentiated and the requiredinformation compiled

Significant differences of opinionregarding the nature of the risk or thecontrol regime indicate that further

Assessment is needed

Qualitative Assessment

Semi-Quantitative Assessment

Quantitative Assessment

Simple, subjective,low resolution,high uncertainty,low cost

Detailed, objective,high resolution,low uncertainty,increasing cost


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Identify the Control Measures (GN10)

Proactive Controls Reactive Controls

IncidentsHazardsCauses Outcomes


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Identify the Control Measures

Eliminationmeasures

Preventionmeasures

Proactive Controls

Mitigationmeasures

Land-use planning

Reactive Controls

IncidentsHazardsCauses Outcomes

Emergency ResponseReductionmeasures


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Assessing the Control Measures

There must be control measures in place for eachhazard and potential incident, that reduce risk as faras practicable

The number, range and effectiveness of control

measures for each hazard/incident should beproportional to the risk

The hierarchy of controls must be followed whereverpossible (ie elimination - prevention - reduction -mitigation)

Each control measure should have definedperformance standards, against which actualperformance can be tracked


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Control Measure Performance

Capability/Functionalityspeed of operation and leak-tightness of shutdown valvecompetence, experience and training of personnelspeed of response or fire brigade

Reliability/Availabilityavailability of fire pumpsreliability of emergency lightingreliability of operator emergency actions

Vulnerability/Survivabilityspeed of operation and leak-tightness of shutdown valvecompetence, experience and training of personnelspeed of response or fire brigade

The Control Measures must be supported by the SMS, thathave to have its own Performance Standards


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mhfr major hazard facilities regulations

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