Posted on: March 17, 2010 Posted by: Diane Swarts Comments: 1

Process operators and consultants called for a standardised risk assessment process, in comment on the Major Hazard Installation (MHI) Regulations 2010 review.

Business commentators also asked legislators to consider compiling a guidance on emergency response planning appropriate to risks on and off site.

Business input to a tripartite technical committee set to make recommendation to the legislator, proposed these MHI Regulation principles;

•    Definitions of ‘major incident’ and ‘MHI’ in the OHS Act and regulations to be reviewed to allow innovative approaches. Business called for an immediate recommendation to the legislator via ACOHS.

•    A tiered approach to MHIs to differentiate different levels of risk.

•    Provision for specific types of activities, like production, storage, conveyance, installations, to allow smaller commercial installations and pipelines carrying hazardous chemicals to be classified as MHIs, with risk mitigation to be assessed according to location.

•    Listing chemicals against threshold quantities under the MHI Regulations, instead of under separate legislation.

•    Contractors to be considered employees regarding relevant compliance requirements.

•    A process safety management standard or guidance should be adopted to prescribe key elements of risk assessment, risk management, and emergency response

•    Roles and responsibilities of local authorities should be reviewed and clarified, including relationships between MHI Regulations and land use management.

•    Relationships between MHI regulations and EIA Regulations should be clarified, including public participation requirements and how representations from interested parties are dealt with.

•    Distinction between requirements for protecting employees, and for protecting the public.

•    Notification should be linked to required actions by recipients, installation MHI owners, and relevant government agencies.

•    Duplicate reporting and notification should be eliminated.

•    Termporary and permanent installations should be subject to the same requirements, although the relevant risks may differ.

•    SANAS guidance to be reviewed after the MHI Regulations review.

•    Reaffirm the need for accredited inspection bodies and Department of Labour approval of inspection bodies.

•    Consider a guidance on emergency response planning appropriate to risks on and off site.

•    Extension of scope to prevention of incidents not only response to them.

The Major Hazard Installation (MHI) Regulations, originally published as a Notice under authority of Section 43 of the Occupational Health and Safety Act or 1993, were promulgated in 1998 and revised under GNR 692 of 30 July 2001.

The regulations were modelled on Seveso Directive 96/82/EC of 1996 on the control of major accident hazards involving dangerous substances, a European Union directive.

The SA Advisory Council on Occupational Health and Safety (ACOHS) had initiated the MHI review under a tripartite Technical Committee. Meanwhile the Hazardous Chemical Regulations are also under review, and the committee undertook to note relevant recommendations to ACOHS, said MHI consultant Nigel Coni.

Business organsations, led by the Chemicals and Allied Industries Association, Caia, also commented that the nature of chemical substances that pose a risk of major incidents, may differ from substances that pose health risks by ongoing exposure at work.

PHOTO: Emergency response processes, roles and responsibilities are ill defined, said owners of major hazard installations.


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