Multi-operators sites Some French case studies Legal framework and context Main difficulties - solutions typical situations Case studies a cooperative spin-off in Lauterboug chemical “association” in Pont de Claix warehouses

Legal framework « Operator » : a broad definition (Seveso, 76 law) when opposed to « third party » Which framework for a « SEVESO » site with many little non-seveso operators ? A permitting and control system designed for one-operator sites

Main difficulties Structural changes in companies => an establishment splits into independent units with no consistency BUT : No change in installations => complex and intertwined facilities shared utilities, often operated by a subcontractors voluntary spin-off of split to fall below thresholds (permit legislation or SEVESO) specific businesses with undefined operators

Challenges : clarify responsibilities Clearly identify responsibilities of each operator => separate permits but (utilities, pipework….) Domino effect evaluation and prevention co-ordinating SMS, emergency plans.. cumulated impact on the environment and on health of the surrounding population : who is responsible for an excessive of accidental pollution ? Land use planning

Typical situations Former establishment => spin-off of minor activity (specialty chemicals…) development of derived activities using a by-product subcontracting utilities (hydrogen plants, liquified air, steam and power generation..) shared utilities (water or waste treatment plant, steam, fire-department) self-service gasoline storage (no staff)

Some practical solutions Co-contracting : shared units and utilities (Lauterbourg) Creating a general structure to run the park (Pont de Claix) More stringent measures to gain flexibility (warehouses)

Rohm&Hass and Rohmax Lauterbourg (Alsace) Specialty chemicals (spin-off in 1997), only one remaining SEVESO contract defining units and responsibilities co-ordinated SMS, training and common emergency plan site SHE review (domino…) shared audit and learning on incident system

Pont de Claix : a chemical Park chlorine soda hydrogene Power, steam chlorine phosgene TDI / HDI phosgene Carbon monoxide agro Chlorohydric Acid liquid and gaseous waste

Pont de Claix : a real park manager entitled by a detailed convention A HSE convention based on regulation and commitment of each operator : principles subcontractors and suppliers submitted to it process safety, training, monitoring of incidents, security, intervention and exercises : all HSE emergency plans and information to the public effluents, waste monitoring control of access to the site dangerous good transport

SPIRAL : HSE operator of the park Co-ordinates implementation of HSE action-plans, security, intervention and exercises Runs safety equipment and staff (Gas & fire detection and mitigation - sirens - operational room..) Runs effluent monitoring and reporting to the authorities offers a service of waste collecting and recycling Monitors nuisances and deals with complaints Each operator remains responsible for each accident he may cause

Pont de Claix situation map

Storage and warehouses Logistics : a growing business operating warehouses as subcontractors for chemicals, car and food industry. =>identify real “decision-markers” => avoid dilution of responsibilities => dealing with ever-changing inventories (nature and quantities of products and risks)

Warehouses : common principles for “subcontracted activities” Identify at all times substances and risks Demonstrate that safety measures are designed, maintained and operated according to “actually stored” products on the long run: fire detection and sprinklers as a minimum Use flexible water, air and waste collecting and treatment Information and Management : staff and executives aware of risks : training, procedures, 24 hrs security team… Pragmatic, but realistic

Conclusion Separate technical and regulatory Q and A Technical : main pb remains management of shared facilities, pipes, intervention and domino effects Regulatory speaking : topmost difficulty is sorting responsibilities and corresponding permits In all cases : a single “site” risk and pollution manager helps for all parties and authorities

Lavera : petrochemicals Napthachimie created in 1950, revamped and restructured in 1980 : “park co-ordinator” steam-cracking, chlorine, alcohols, PP, ethoxylates 2 main companies : Atofina and BP Chemicals, => 8 operators, of which 5 are SEVESO, 8 permits => 8 parties convention (interactions, responsibilities, safety measures common training for all staff, shared fire-fighting equipment, common emergency plans and waste treatment) => common “management of change” procedure : a change in 1 establishment triggers a revision of all safety reports and SMS