EuropeAid/131555/C/SER/RS Major Accident Prevention Policy Safety Management System Ernst SIMON, Styrian Regional Government, Austria Belgrade, December 2013

Hierarchy&Relations MAPP Safety Management System Underlying documents Safety Report Documentation of establishment Risk analysisMeasuresInternal EP

SMS versus MAPP Upper tier: MAPP + SMS, lower tier MAPP only MAPP is not a „small“ or „reduced“ SMS – it is a different document with different aims and formal requirements For upper tier establishments: SMS - in accordance with Annex III – is one of the means by which the operator has to demonstrate that a MAPP has been properly implemented. For lower-tier establishments, the obligation to implement the MAPP may be fulfilled by other … and management systems, proportionate to major-accident hazards, taking into account the principles set out in Annex III. Every operator has to have a management system; upper tier a SMS, lower tier at least „some“ management system. Each system has to be in accordance with Annex III. Each system has to be proportionate to the major-accident hazards.

Major Accident Prevention Policy Operator must establish a written policy (may not exceed 3-4 pages) setting out overall aims and principles with respect to the prevention and control of major accidents ensuring a high level of protection for man and the environment Operator must make MAPP available to the CA’s for the purposes of inspection and control No decision on the quality and content of the MAPP by the authority required MAPP describes the overall aims, not the actually measures taken MAPP is valid for the whole corporation; no direct link to the particular establishment MAPP is not a “Mini Safety-Report”

Comparison MAPP for Upper Tier SEVESO III Art. 8 Member States shall require the operator to draw up a document in writing setting out the major-accident prevention policy (MAPP) and to ensure that it is properly implemented. … The MAPP shall be implemented by appropriate means, structures and by a safety management system, in accordance with Annex III, … It shall be proportionate to the major- accident hazards. SEVESO II Art demonstrating that a major- accident prevention policy and a safety management system for implementing it have been put into effect in accordance with the information set out in Annex III... = NEW

Comparison MAPP for Lower Tier SEVESO III Art. 8 Member States shall require the operator to draw up a document in writing setting out the major-accident prevention policy (MAPP) and to ensure that it is properly implemented. … For lower-tier establishments, the obligation to implement the MAPP may be fulfilled by other appropriate means, structures and management systems, proportionate to major-accident hazards, taking into account the principles set out in Annex III. SEVESO II Art. 7 & Annex III Member States shall require the operator to draw up a document setting out his MAPP and to ensure that it is properly implemented. The MAPP established by the operator shall be designed to guarantee a high level of protection for man and the environment by appropriate means, structures and management systems. The document must take account of the principles contained in Annex III. The requirements... referred to in Article 7 should be proportionate to the major-accident hazards presented by the establishment. =

Safety Management System Demonstration of transposition of the MAPP Content and issues to be addressed laid down in Annex III of the Directive Not part of the SR, only a reference is sufficient Must have clear relations to the particular establishment (persons in charge, operating procedures,...) Inspection of SMS: One aim is to scrutinize / verifiy if the management loops exist (plan – do – check – act) Using check-list for interviews showed to be very useful In most cases it is useful to split technical inspection from SMS-inspection

Annex III – Content of SMS The SMS should include the part of the general management system which includes the organizational structure, responsibilities, practices, procedures, processes and resources for determining and implementing the MAPP; The following issues shall be addressed by the SMS: Organization and personnel — the roles and responsibilities of personnel, identification of training needs, involvement of employees and subcontractors; Identification and evaluation of major hazards — procedures for systematically identifying major hazards, likelihood and severity; Operational control — adoption and implementation of procedures and instructions for safe operation; Management of change — adoption and implementation of procedures for planning modifications; Planning for emergencies — adoption and implementation of procedures to identify foreseeable emergencies by systematic analysis, to prepare, test and review emergency plans to respond to such emergencies; Monitoring performance — adoption and implementation of procedures for the ongoing assessment of compliance with the objectives set by the operator's major- accident prevention policy and safety management system; Audit and review — adoption and implementation of procedures for periodic systematic assessment of the MAPP and the effectiveness and suitability of the SMS.

Management Systems Safety Management Systems SCC (Safety Certificate for contractors) BS 8800 OHSAS 18001, (Occupational Health and Safety Assessment System Quality Management Systems ISO 9000 – 9004 Environmental Management System EMAS ISO Operators are not obliged to apply or practise these systems, but it could facilitate the assessment and inspections

Guideline for SMS and MAPP In Austria, the Permanent Working Group “Seveso” developed two checklist for inspecting SMS and MAPP. The checklist for MAPP is not so comprehensive and detailed. Available on the Internet Sent to the operator in advance for preparation and “pre-filling out” Checklists can be used as a guideline for establishing an appropriate MAPP/SMS In the recent Twinning-Project a checklist was developed as a tool for Serbian inspectors covering MAPP, SMS and some selected technical issues Example QuestionAnswerRemarks YesNoPartlyn.a. MAPP and SMS Has the MAPP been communicated to the workforce? Is the MAPP communicated to the contractors and third parties undertaking activities on site? Are the MAPP and SMS fully implemented regarding (followed by the issues acc. Annex III)

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