update on eu issues 10 th march 2010 manchester conference centre health and safety executive major...
DESCRIPTION
Aligning the EU and UN systems Annex One determines the scope of the Seveso Directive The EU CLP Regulation implements the UN GHS of classification No simple formula for aligning the old and new systems TWG established to consider this issue Changes to Seveso Annex 1TRANSCRIPT
Update on EU Issues
10th March 2010Manchester Conference
Centre
Health and Safety Executive
Major Hazards Policy Team
Paul Edwards
• The review of the Seveso Directive
• The alignment of Seveso with GHS
• The Critical Infrastructure Directive
Summary
10th March 2010Manchester Conference
Centre
Aligning the EU and UN systems
Annex One determines the scope of the Seveso Directive
The EU CLP Regulation implements the UN GHS of classification
No simple formula for aligning the old and new systems
TWG established to consider this issue
Changes to Seveso Annex 1
The UK wants minimal change to the overall scope:– No increase unless justified by safety– No decrease if there remains the risk of a major
accident– The link between CLP & Seveso to be as clear &
straight forward as possible– Admin burdens kept to a minimum
Changes to Seveso Annex 1
Bringing GHS into Seveso – the UK’s aims
The EU wants to ensure at least the same level of protection to man &
the environment throughout Europe
Changes to Seveso Annex 1
Bringing GHS into Seveso – the EU’s aims
Analysis of Current Position
Greatest discrepancy exists with the human toxicity category
Other issues with ‘physical hazard’ and ‘environmental hazard’ categories
Changes to Seveso Annex 1
Comparison of Toxic Properties
4
T+ T XnEU
1 2 3Oralmg/kg
1 2 3 4inhal.vapourmg/linhal.aerosolmg/l
1 2 3 4
2 3 4inhal. gasmg/lppm
1 32 4Dermalmg/kg
0 25 200
0 5 25 50 200 300
0
0,1
0
0
0
0,5
2
2
20050 400 1000
0,50,05 0,25 1
500 25001000
10
1+2 +3+4 for T
comparing line to old legislation
1+2 +3+4 for T+
1
A1 A2
A5
A3
A7A6
A4
A2b
really precautionary
alignment
Impact of GHS on COMAH
Changes to Seveso Annex 1
HSE undertaking research to better determine impact of proposed changes
EU expected to produce draft proposal in 2010
Final system required before June 2015, when current system lapses
http://ec.europa.eu/environment/seveso/review.htm
Aligning the EU and UN systems
A more general undertaking than the alignment of Annex 1 and CLP
Aims to assess the effectiveness of Seveso and identify possible improvements
Carried out through two questionnaires…
Review of Seveso
Review of Seveso
EU Seveso surveys• F-Seveso survey - investigated the implementation of Seveso
- identified no need for legislative change
• Public authority survey - no fundamental changes necessary
- some possible improvements in implementation and enforceability
http://ec.europa.eu/environment/seveso/review.htm
Formal proposal in late 2010Formal negotiations across Europe in 2011Changes then implemented in UK through
COMAH & HSC RegulationsUltimate deadline for completion is June 2015
Proposed Schedule
Review of Seveso
Inclusion of Carbon Dioxide?
Possibility of including CO2 as a named substance
UK considers CO2 to have major hazard potential
UK aims to include CO2 only where it is part of a CCS process
Review of Seveso
Security issues within Seveso?
Review of Seveso
Some interest among other member states
UK currently waiting to see where these discussions lead
BUT CA is not committing to a definitive position on the issue at this stage
• Extension of the derogation rule
• Comitology for Annex 1 changes
• Clarification of underground gas storage
• Clarification of domino effect provisions
• Mixtures & preparations (‘M’-factors)
Other Issues Under Discussion
Review of Seveso
Likely next steps…Formal EU proposal to amend Seveso in 2010
On-going engagement with UK stakeholders
Consultation and EU Impact Assessment
Final system must be in place by June 2015
May require new or amended COMAH Regulations and LUP legislation
Changes to Seveso Annex 1
Reduction of Administrative Burdensi) Computerised notification
- national websites for operators to submit notifications
ii) Co-ordinated inspections
- between Seveso and IPPC regimes
Review of Seveso
UK agrees with these proposals in principle
Critical Infrastructure Directive
Critical Infrastructure DirectiveAdopted in December 2008
‘Critical Infrastructure’ – assets that destruction/disruption of which would have a serious impact on health or well-being of a
population
Currently limited to the energy and transport sectors
Upcoming Event
Workshop on Emergency Planning
21st April, Madrid
Event open to a wide audience
Aims to share experiences and identify good practice in the development of External Emergency Plans
Provide details to HSE if interested in attending
CCA Meeting, Madrid
How to contact HSEFurther information on HSE’s website:
http://www.hse.gov.uk/seveso/index.htm
Contact details: [email protected]
Infoline: 0845 345 0055 [email protected]
Contacting HSE