Major Accident Hazards Regulations Research Articles

Control of industrial major accident hazard regulation in Malaysia: second decade in examination

The Control of Industrial Major Accident Hazards (CIMAH) regulations was introduced in 1996 to regulate workplaces with hazardous chemicals in their facilities. The Regulations provide a minimum standard to ensure precautionary measures related to major hazard risks are taken. Although the Regulations have been enforced for more than two decades in Malaysia, there have been limited efforts to review related information, trends and data since its inception. The study aimed to provide an overview of the position of CIMAH regulations after two decades of being enacted in Malaysia. Data were extracted from the published and unpublished reports and documentations by Department of Occupational Safety and Health of Malaysia (DOSH), as well as available publications from literary journals. Analysis of the contents revealed three categories of data: i) CIMAH regulations’ administrative governance changes; ii) major hazard industries–categorization and registration trends; and iii) CIMAH regulations’ punitive activities. The findings provide an overview of relevant trends and data related to CIMAH regulations in the past two decades, and may provide stakeholders such as policymakers, practitioners, and researchers a groundwork for improvement initiatives.

A Case Study of Asset Integrity and Process Safety Management of Major Oil and Gas Companies in Malaysia

Asset integrity is closely intertwined with process safety where the latter is often perceived to be equivalent or a subset of the former. In Malaysia, the requirements for offshore process safety are set by Petronas assuming exclusive rights to petroleum in the nation. It imposes and enforces these requirements on oil and gas companies entering into its production sharing contracts via the common law. Process safety management in Malaysia is strongly influenced by the US OSHA 3132 with elements comprising process safety information, process hazard analysis, operating procedures, employee participation, training, contractors, pre-startup safety review, mechanical integrity, hot work permit, management of change, incident investigation, emergency planning and response as well as compliance audits. These elements are largely included in the Mandatory Control Framework of Petronas and the trio of design, technical and operating integrity adopted in the process safety management of other oil and gas companies. These management practices align with the reiterative plan-do-check-act model. Process safety performance is also gauged with indicators suggested by international institutions such as the American Petroleum Institute. On top of the Control of Industrial Major Accident Hazards Regulations 1996 for onshore processes, this study deems that establishing statutory law for offshore installations will be beneficial to propel offshore safety in Malaysia to a greater height.

The meaning and importance of process safety competency

Process safety competency is subject to regulation in some jurisdictions, such as in the United Kingdom by the Health and Safety Executive (UK HSE) under the Control of Major Accident Hazard regulations. Process safety competency is one of 20 elements in the risk-based process safety (RBPS) management system developed by the Center for Chemical Process Safety (CCPS). However, competency as used in this RBPS element is not the same as the competency regulated by the UK HSE. The RBPS competency element addresses managing a knowledge base of process information and not competency as defined by other CCPS publications which use the term with a similar meaning to the UK HSE. This makes for a confusing situation for companies interested in improving their management of process safety competency. The scope of the RBPS element should be revised to address true competency. Currently, the U.S. Occupational Safety and Health Administration's Process Safety Management Standard and the U.S. Environmental Protection Agency's Risk Management Program rule do not address competency. However, both regulators are considering revisions to these regulations, including the incorporation of additional elements from the CCPS RBPS management system that are not currently in the regulations. One of these elements is process safety competency, as defined in the CCPS RBPS management system. This action would result in an inadequate treatment of competency. If a competency element is incorporated into the regulations, it should address true competency. © 2015 American Institute of Chemical Engineers Process Saf Prog 35: 171–175, 2016

From Aberfan to the ‘Canvey Factor’: schools, children and industrial disasters

Children, and schools, are potent symbols of victimhood in industrial disasters. In the case of historical industrial disasters such as Aberfan and Flixborough, and in terms of preparation for future industrial disasters under Control of Major Accident Hazard regulations, communities are seen as passive responders to accidents. Moreover, following industrial accidents, communities are frequently accused of culpability or profiting from the disaster. There is hence a double pathologisation in play, with communities seen as comprising passive victims and manipulative survivors. Using an historical approach, the official accounts of the Aberfan and Flixborough industrial accidents are challenged with a focus on schools and children. Rather than being passive victims of these accidents, schools and children demonstrated agency in terms of their tacit knowledge, reporting potential accidents and recording their consequences. This provides a lens through which to interrogate current policy on industrial safety as it relates to schools and communities.

Lessons learned from a fuming sulfuric acid tank overflow incident

Fuming sulfuric acid (oleum), is a highly corrosive solution of sulfur trioxide (SO 3 ) in concentrated (98%+) sulfuric acid. Commercial concentration of free SO 3 can range from 10 to 70% depending on the use and manufacturer. Fuming sulfuric acid reacts violently with water and is a strong irritant to any tissue. While it may be easy to handle in small, laboratory scale amount, spills of fuming sulfuric acid are difficult to control because of the corrosivity and reactivity. Sulfur trioxide has been added to the list of substances under the CIMAH 1 (Control of Industrial Major Accident Hazards) regulation [The Control of Industrial Major Accident Hazards Regulations 1984, SI 1984, No. 1902, HMSO] 1 for which installations are required to prepare safety reports. This paper reviews and discusses the response to an overflow from an oleum storage tank during unloading from an over-the-road tanker.

Development of a functional model which integrates human factors, safety management systems and wider organisational issues

The UK Health and Safety Executive’s Hazardous Installations Directorate (HID) has specialist inspectors who make up a team that support the assessment and inspection of major hazard chemical sites covered by the Control of Major Accident Hazards Regulations (COMAH). This paper describes preparatory groundwork for the development of a practical holistic model to help key stakeholders (inspectors, chemical companies) understand how human factors, safety management systems and wider organisational issues fit together. The process was to break down the three areas into simpler components (taxonomy) and to use these smaller components as building blocks in an integrated reconstruction. To guide the reconstruction for the major hazard context, the taxonomy was used to analyse a small sample of major chemical accidents. The results were used to look for logical patterns of associations which could form a basis from which to develop further guiding principles of integration. The idea is that, once identified, the patterns can be used in the applied contexts of inspection and auditing. If the patterns can be found in practice they can be used to identify weaknesses that could initiate major accidents. Similarly, the patterns can be used to understand accident causation during accident investigations. The paper describes the key concepts and the development process. The proposed model derived during this work has not yet been validated.

Health-Related Environmental Indices and Environmental Equity in England and Wales

This study developed small-area health-related environmental indices for England and Wales in the context of an investigation into socioeconomic inequity in the distribution of environmental risk. Selection of environmental hazards, relevant datasets, and their attribution to standard small-area geography using a geographic information system are described. Four indices for 1991 Census wards are proposed, relating to ambient air quality, atmospheric chemical releases from large-scale industrial processes, landfills, and sites registered under Control of Major Accident Hazard regulations. Ecological measures of association between these indices and the Carstairs material deprivation index and its components are presented in the context of variations by urban–rural status. Based on these analyses, the study generally supports previous findings of environmental inequity in England and Wales, but highlights that associations are dependent on the environmental and deprivation measures under consideration, and urban–rural context. It is proposed that environmental indices such as those described here should be included in considerations of area deprivation, could assist with equitable environmental decisionmaking and planning, and that measures of environmental inequity could be considered as indicators of progress towards sustainable development.

A Risk-Based Model to Establish Threshold Planning Quantities of Hazardous Substances

The Threshold Planning Quantity (TPQ) is the minimum quantity of any hazardous substance stored or processed at an industry that can pose a defined level of risk up to a certain distance from the industrial premises should an accidental release occur. These are recommended by the concerned government departments of the respective countries. Often, concerned regulatory authorities focus on simple screening tools to prescribe TPQs of hazardous chemicals rather than on more detailed technical aspects. This is illustrated with the help of TPQs presently administered in India, which are followed based on Control of Industrial Major Accident Hazard regulations of the United Kingdom. In this paper, the risk ranking matrix (RRM) approach is described to evaluate the recommended TPQs and prescribe these for some extremely hazardous chemicals (EHS) commonly used in industries. The RRM presented here is unique in the sense that various acceptable risk criteria are reviewed to appropriately rank the risk potential and provide suitability criteria in terms of individual risk factors and geosoci-etal risk factors (GSRF). Based on this concept, an attempt has been made to develop a risk-based model to determine the TPQs of various EHS (acrolein, ammonia, chlorine, hydrogen fluoride, and phosgene).

COMAH and the Environment: Lessons Learned from Major Accidents 1999–2000

In April 1999, the Control of Major Accident Hazards Regulations 1999 (COMAH), came into force in Great Britain, implementing the requirements of the Seveso II Directive 96/82/EC. The Competent Authority (CA) for the COMAH regulations in England and Wales comprises the Health and Safety Executive (HSE) working jointly with the Environment Agency (EA) (and in Scotland, the HSE working with the Scottish Environment Protection Agency (SEPA)). This arrangement reflects the requirements to ensure the protection of both persons and the environment. The COMAH regulations superseded the Control of Industrial Major Accidents Hazard Regulations 1984 (CIMAH), which were implemented by HSE alone. The first COMAH major accident with environmental consequences was in July 1999 at a chemicals storage facility operated by Tees Storage, at Seal Sands, Middlesbrough. Sixteen (16) tonnes of sodium cyanide solution leaked from a storage tank into the ground, polluting the groundwater and the River Tees. This incident occurred only four months after the regulations came into force and provided an early test for the workings of the CA. It was one of the 13 COMAH major accidents which were reported to the European Commission in the first year of operation of the regulations (1999/2000). Another COMAH major accident with environmental consequences occurred in October 2000 at a waste management and treatment facility operated by Cleansing Services Group (CSG), at Sandhurst in Gloucestershire. A major fire started in the early hours of the morning, during a severe storm, and approximately 60 local residents were evacuated. The fire service were unable to gain access to fight the fire and the police set up a ‘Gold Control’ to manage the incident. Three days later the River Severn burst its banks flooding the site and the local residents were evacuated for a second time. The CA deployed significant resources to investigate the incident, make the site safe and handle the public concern about health impacts. This paper examines the causes of the incidents, their investigation and the regulatory actions taken by the CA. It also considers some of the longer term lessons learned.

Development and Implementation of an HSE Management System in Exploration and Production Companies

Summary This paper describes the experience to date with safety management systems (SMS's) and describes their implementation after the Piper Alpha disaster and Lord Cullen's report. It also shows the gradual expansion of these systems toward fully integrated health, safety, and environment (HSE) management systems. Our company policy, which was clearly stated before publication of Lord Cullen's report, is that work should not start until the appropriate controls are in place. Work based on this policy and on objective-setting SMS's within Shell IntI. Petroleum Mij. (SIPM) E&P coordination started in earnest soon after the publication of the report in Nov. 1990 and has continued without interruption since that time. Objective-setting systems may be defined as systems where the company management sets its own objectives or goals on the basis of functional rather than prescriptive requirements and then goes on to demonstrate how such goals have been, or are being, met. The paper ends with a projection of what may be expected in the future. Introduction Following the Piper Alpha disaster and the in-depth public inquiry led by Lord Cullen, the recommendation was made that all offshore installations on the U.K. continental shelf should have safety cases similar to those already required under the U.K. Control of Industrial Major Accident Hazards Regulations. This recommendation was given effect by means of the safety-case regulation within the U.K. with a Nov. 1993 deadline for the submission of safety cases. Shell Expro, as a major operator in the U.K. sector of the North Sea, had already begun work on its safety cases before publication of the Cullen report and was one of the companies that contributed to the so called "voluntary" safety cases before this date. It was apparent to E&P management within SIPM that the SMS and the safety case provided better assurance of safe operation and were of real value to Shell operations worldwide. (In this paper, Shell is sometimes used for E&P companies of the Royal Dutch/ Shell group in general, and Shell E&P is used if experience was gained through technical service agreements supported by SIPM E&P). It was also clear that a worldwide move toward such systems would take place. Thus, application of these systems was both good business and appropriate for all Shell E&P operating companies. As a direct consequence, an integrated project team (both project engineering and operations) was set up to implement SMS and safety cases throughout Shell upstream operations worldwide.