1. 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

2. 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

3. 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

4. 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

5. 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)

6. 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)

7. 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

8. 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

9. 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

10. 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

11. Pont de Claix situation map

12. 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)

13. 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

14. 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

15. 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