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One year after the Lubrizol accident, regulations on industrial risk prevention and accident management have been tightened.
These changes are part of the government's Lubrizol action plan, which aims to provide feedback on the major accident that occurred in Rouen on September 26, 2019.
We present the main measures affecting Seveso establishments, which operators of these sites must take into account.
Changes to the operating plan
Extended scope of application
The Internal Operation Plan (POI) will be mandatory for Seveso low threshold plants from January 1, 2023.
For these facilities, the POI is tested at intervals not exceeding three years, and updated if necessary.
POI content and testing frequency
The content of the POI of Seveso establishments is now specified, in particular with regard to :
- the means and methods planned for restoring and cleaning up the environment after a major accident;
- measures to ensure the availability of equipment for initial environmental sampling and analysis in the event of a major accident.
This content applies to POI updates made on or after January 1, 2022.
For Seveso high threshold plants, POIs must now be tested every year, rather than every 3 years. However, updating remains mandatory at least every 3 years.
Risk training and incident/accident management
The various operators and participants must be trained in the risks associated with the facilities, in what to do in the event of an incident or accident and, if they contribute to it, in the use of the plant's own response resources.
This training also applies to staff from outside companies.
Lubrizol action plan modifies certain frequencies
The frequency of the following actions has been specified:
- inventory of hazardous substances, preparations or mixtures on sites by operators
- completion, review and updating, if necessary, of hazard studies (*)
- review and update of the major accident prevention policy
- providing the public with information on major accidents that may occur.
(*) reminder: only concerns 'Seveso high threshold' classified sites
Hazard studies for Seveso plants
New information to be included in hazard studies
From 2023 onwards, hazard studies will have to mention the types of decomposition products likely to be emitted in the event of a major fire. This should include (where appropriate) contributions attributable to storage conditions and locations (containers, buildings, etc.). Products should be prioritized according to the quantities likely to be released and their toxicity to man and the environment.
This list must be sent to the prefect when a hazard study is drawn up, revised or updated, and, when the study is subject to review, no later than June 30, 2025.
Re-examination of the hazard study
During this review, the operator must :
- take into account proven and adapted technologies which, at an economically acceptable cost, could lead to a significant improvement in risk management;
- prioritize these technologies according to the probability, severity and kinetics of the potential accidents they help to avoid, as well as the cost proportionate to the expected safety gain,
- decide on the technologies selected and specify their implementation schedule.
The notice reviewing the hazard study, the summary of the technology survey and, where applicable, the revised hazard study must be forwarded to the Prefect. The Prefect then decides whether the applicable requirements need to be updated by decree.
Substantial or significant changes?
Substantial modifications are defined as :
- modifications that could have significant consequences in terms of major accident hazards;
- modifications that result in a Seveso low threshold facility becoming a Seveso high threshold facility.
All non-substantial modifications satisfying the following conditions are considered significant modifications:
- any significant increase or decrease in the quantity or any significant change in the nature or physical form of the hazardous substance present, which has been identified by the operator, or any significant change in the processes using it;
- changes resulting in a Seveso high threshold facility becoming a Seveso low threshold facility.
Information made available to the public by the prefect
Following the Lubrizol action plan, this information has now been defined.
Note: not applicable to certain classified facilities operated by the Ministry of Defense.
For all Seveso establishments, this information includes: the corporate name of the operator, the address of the establishment, the common name or hazard category of the dangerous substances requiring Seveso classification of the establishment, appropriate information on the behavior to adopt in the event of a major accident, details of how to obtain any relevant information, etc.
Additional information is provided for Seveso high threshold establishments. For example: general information on the nature of major accident hazards, a summary of the main types of major accident scenarios and associated hazard control measures, relevant information on the specific intervention plan drawn up to combat the possible off-site effects of an accident, etc.
Conclusion
Major industrial accidents (Seveso, AZF, etc.) have often led to stricter regulations. Manufacturers must therefore be vigilant in identifying these developments in their monitoring activities.
As part of the Lubrizol action plan, operators of Seveso sites are particularly affected, and must take account of the developments described in this article in their accident risk management.
Changes in regulations following the Lubrizol experience do not only concern Seveso sites. Fire prevention at combustible materials warehouses has also been significantly modified. We'll be coming back to this subject shortly.