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Health and Safety Executive Health and Safety Executive CD277 Proposals on the review of the Dangerous Substances in Harbour Areas regulations 1987 (DSHAR), Approved Code of Practice (COP 18) and guidance HSE(R27) Reply Form Completing this Questionnaire You can move between questions by pressing the ‘Tab’ / ’Shift-Tab’ or ‘Page Up’ / ‘Page Down’ keys or by clicking on the grey boxes with a mouse. Please type your replies within the rectangular grey boxes, or click on the square grey boxes to select an answer (e.g. ‘Yes’ or ‘No’). Respondent’s details: Name: Email: Town / City: Telephone: Job Title: Postcode: Page 1 of 20

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Health and SafetyExecutive

Health and Safety Executive

CD277 Proposals on the review of the Dangerous

Substances in Harbour Areas regulations 1987 (DSHAR),

Approved Code of Practice (COP 18)

and guidance HSE(R27)

Reply Form

Completing this Questionnaire

You can move between questions by pressing the ‘Tab’ / ’Shift-Tab’ or ‘Page Up’ / ‘Page Down’ keys or by clicking on the grey boxes with a mouse. Please type your replies within the rectangular grey boxes, or click on the square grey boxes to select an answer (e.g. ‘Yes’ or ‘No’).

Respondent’s details:

Name:      

Email:      

Town / City:      

Telephone:      

Job Title:      

Postcode:      

Street address:      

Organisation:      

Page 1 of 17

Health and SafetyExecutive

Fax:      

Size of organisation:

Choose one option:

Not applicable 1 to 9 employees

10 to 49 employees 50 to 249 employees

250 to 1000 employees 1000+ employees

Self-employed

Type of organisation:

Choose one option:

Academic Charity

Consultancy Industry

Local government Member of the public

National government Non-departmental public body

Non-governmental organisation Pressure group

Trade association Trade union

If you chose ‘Other’ please specify:      

Is your response being made in your capacity as:

Choose one option:

An employer An employee

Health and safety professional Trade union official

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Health and SafetyExecutive

Training provider

Other – please specify:

     

Confidentiality

Please indicate below whether your comments can be made available to the public or if you want them to be confidential. (NB if you do not indicate your choice they will be made available to the public. This takes precedence over any automatic notes on e-mails that indicate that the contents are confidential.)

Public

Confidential

Q1. Do you agree or disagree with our proposals in paragraphs 18-26 of the consultation document to amend the definitions and scope of DSHAR?

Agree

Disagree

If you disagree, please state why?

     

Q2. Would the changes proposed to the exemptions to DSHAR mean you had to do anything different to comply with the regulations?

Yes

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Health and SafetyExecutive

No

If yes, please state why?

     

Q3. Do you agree or disagree with our proposal to retain part II of DSHAR?

Agree

Disagree

If you disagree, please state why?

     

Q4. Do you agree or disagree with the amendments we are proposing in paragraphs 30 and 31 of the consultation document to the notification duty in regulation 6 of DSHAR?

Agree

Disagree

If you disagree, please state why?

     

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Health and SafetyExecutive

Q5. Should we revoke Part III of DSHAR – Marking and Navigation of Vessels?

Yes

No

If not, please state why?

     

Q6. Should we revoke Part IV of DSHAR, on handling dangerous substances?

Yes

No

If not, please state why?

     

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Health and SafetyExecutive

Q7. Should we revoke Part V of DSHAR on liquid dangerous substances in bulk?

Yes

No

If not, please state why

     

Q8. Should we revoke Part VI of DSHAR on packaging and labelling of dangerous substances?

Yes

No

If not, please state why.

     

Q9. Should we retain the duties in regulations 26 and 28 of DSHAR (emergency planning and untoward incidents) in the new regulations?

Yes

No

If not, please state why

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Health and SafetyExecutive

     

Q10. Do you agree or disagree that we should replace the duty in regulation 27 of DSHAR with a duty on berth operators to inform the master of a vessel of the emergency arrangements at the berth?

Agree

Disagree

If you disagree, please state why.

     

Q11. Should we revoke regulations 29-31 of DSHAR?

Yes

No

If not, please state why.

     

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Health and SafetyExecutive

Q12. Should we retain the requirement currently in regulation 32 of DSHAR for a designated parking area for dangerous goods?

Yes

No

If not, please state why.

     

Q13. (i) Should we replace the licensing requirement for harbours where ships carrying explosives are merely passing through, with a notification requirement on the ship?

Yes

No

If not, please state why.

     

Q13. (ii) We have assumed that this would make no difference to what ships carrying explosives through harbours would need to do in practice. Do you agree or disagree with this assumption?

Agree

Disagree

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Health and SafetyExecutive

If you disagree, please state why.

     

Q14. Should we replace the current military exemptions with an exemption for explosives under the control of Secretary of State and visiting forces, as set out in regulation 12(2)(e) of the proposed new regulations?

Yes

No

If not, please state why.

     

Q15. Do you agree or disagree with our proposals in paragraphs 94–98 of the consultation document to amend the explosives safety and security requirements in DSHAR?

Agree

Disagree

If you disagree, please state why.

     

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Health and SafetyExecutive

← Q16. If we reduce the record-keeping requirement from 5 to 3 years as proposed in paragraph 99 of the consultation document, would this lead to any cost savings for you, compared with what you do now?

←←

Yes

No

If so, please provide an estimate of any savings and explain your answer

     

← Q17. Should we keep the current provisions enabling statutory harbour authorities to make byelaws relating to dangerous substances in their harbour area?

←←

Yes

No

If not, please state why

     

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Health and SafetyExecutive

Q18. Do you have any comments on the proposal to retain the current enforcement arrangements in DSHAR?

←←

Yes

No

Please explain

     

Q19. Should we withdraw COP18 and HSR27 and replace these documents with a single consolidated ACOP?

←←

Yes

No

Please state why

     

Q20. Is the draft ACOP and associated guidance sufficiently clear for you to be confident about how you can comply with DGHAR?

←←

Yes

No

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Health and SafetyExecutive

Please state why

     

Q21. Are there any impacts from the revision of the guidance and ACOP that we should be aware of?

←←

Yes

No

If so, please explain

     

Q22. Do you agree or disagree with HSE’s estimate of the industry sectors and the number of enterprises affected in Table 1 on page 23 of the consultation document?

←←

Agree

Disagree

If you disagree, please provide further information

     

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Health and SafetyExecutive

Q23. HSE has assumed that the enterprises referred to in Table 1 (other than those involved in the transportation of freight by rail and road) may, at some point, come into contact with Dangerous Goods?

a) Is this reasonable?

←←

Yes

No

b) If not, what would be a reasonable estimate of the proportion of these enterprises that would come into contact with dangerous goods? Please state why

     

Q24. HSE estimates that 10% of enterprises undertaking freight transport by road are involved in the transport of dangerous goods to harbours and harbour areas. Is this assumption reasonable?

←←

Yes

No

If not, what would be a reasonable estimate of this proportion?

     

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Health and SafetyExecutive

Q25. Do you agree or disagree with our assumption that the proposed changes will be largely cost-neutral?

←←

Agree

Disagree

If you disagree, please state why

     

Q26. HSE estimates that familiarisation costs for businesses in the road and rail freight industries would be minimal. Do you agree or disagree with this assumption?

←←

Agree

Disagree

If you disagree, what would be a reasonable estimate? Please provide a basis for your answer.

     

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Health and SafetyExecutive

Q27. Is HSE's assessment of the process of understanding and communicating duties under DSHAR, as outlined in paragraphs 124 and 125 of the consultation document, reasonable?

←←

Yes

No

If you have said no, please state why.

     

Q28. How do businesses in your sector receive information about their obligations under DSHAR?

     

Q29. How often do businesses in your sector refer directly to the regulations and/or the guidance or ACOP documents?

     

Q30. Do you agree with the assumption that it will take approximately one hour of a Health and Safety Manager’s time, at a cost of £36.22 per hour, to understand and make provisions to communicate changes under the proposal?

←←

Yes

No

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Health and SafetyExecutive

← If not, what would be a reasonable estimate?

     

Q31. Do you have any other comments on the impact on businesses, including other assumptions made, that are not covered by questions 22-30?

←←

Yes

No

← Are there any further comments you would like to make on the issues raised in this consultative document?

     

Is there anything you particularly like or dislike about this consultation? Please provide comments.

     

Please send your response by 23 December 2015 to:

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Health and SafetyExecutive

DSHAR review teamHealth and Safety Executive

5S.3.18 Redgrave CourtMerton Road

BootleMerseyside

L20 7HS

E-mail: [email protected]

Thank you for taking the time to complete this questionnaire

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