Mutual Joint Visit (MJV) Workshop on Seveso Inspections
Risk management and enforcement on ageing hazardous sites
Organised by the Malta Occupational Safety and Health Authority and
the European Commission Joint Research Centre
10-12 April 2019, Qawra, Malta
In the area of chemical accident risk, ageing of hazardous installations has been a source of considerable concern in the past decade, both in public authorities and in industry. Many installation have already reached or exceeded the end of their nominal design life which is typically set at 20 to 25 years. In particular, a substantial portion of the industrial infrastructure in the EU was established just after the Second World War, which means that some hazardous sites are over 75 years old and still in service. For this reason, the issue of ageing may be an important element of inspection and verifying risk management on certain sites.
Ageing affects all assets in the establishment. While the ageing of the physical infrastructure is the most visible element of ageing, the ageing of the organisation itself is a factor that constantly operates on the risk, because the people in the organisation are constantly chanaging. As people change, the competence, knowledge, experience set, and attitudes of the organisation will change accordingly. Procedures and documentation can also become outdated. In addition, it is now more than 40 years since computerization became a central part of process operations in many establishments. Ageing computer hardware and software are less visible but equally vulnerable as process equipment to malfunction, obsolescence and the loss of the knowledgebase on how they work and their limitations.
All of these ageing aspects, if ignored, can significantly elevate the risk that a serious chemical accident will be triggered on a hazardous site. As such, recognition of ageing as it relates to the equipment, controls and people in the organisation should be an explicit element of site risk management, properly addressed in the safety management system and reviewed in particular for its potential role in the prevention of potential accident scenarios and mitigation of their consequences. In essence, the management of ageing risk is a kind of management of change process that is both more persistent and complex than almost any other kind of change faced by any one hazardous site.
The MJV Workshop seeks to foster exchange of ideas and good practice among inspectors in Seveso competent authorities on how to effectively help to reduce risk from ageing hazardous sites in our societies using the monitoring and enforcement tools of the Directive. In particular, the workshop expects to generate tips on how to identify sites that may be vulnerable to risk from ageing factors and to build an awareness of conditions that may increase or reduce risk from ageing. It also aims to help inspectors identify evidence of strengts and weaknesses in the management of ageing risks on a hazardous site across the various ageing categories, using various inspection tools, such as checklists, performance criteria and standards, spotchecks and other methods.
Reference materials
OECD. 2017. Ageing of hazardous installations. Series on chemical accidents no. 29. Environment Directorate. Joint Meeting of the Chemicals Committee and the Working Party on Chemicals, Pesticides and Biotechnology.
United Kingdom COMAH Competent Authority. Ageing plant delivery guide.
