(148a) Differences in European States' Application of the Seveso 2 Directive on Major Accident Hazards

The Chemical Industry in Europe is governed by national and European level legislation. In particular, the Seveso 2 Directive is a legal instrument which has been adopted in all the 15 member states and is being progressed in the 10 new member states. This Directive has detailed requirements relating to lower (medium hazard) and upper (high hazard) tier establishments. These requirements range from establishment of a Safety Management System and Major Accident Prevention Policy and Emergency Planning, through to a Safety Report for the upper tier establishments detailing all process hazards and how they are controlled. Individual member states are free to add their own requirements to this already detailed process. These individual approaches are determined by many influences including the local legal frameworks, traditional enforcement and inspection systems, national standards and custom and practice. Typical variances can be found in the way that risk assessment must be done. Some member states look at worst possible scenarios, others do not. Some require Deterministic approaches, while others require a degree of or full Quantitative Risk Assessment. The paper gives a review of the systems used in several major member states and assesses the added costs and benefits which a company operating similar facilities in several European states experiences.

The author is a Process Safety professional operating across Europe. Membership of European Commission Technical Working Groups for the implementation of Seveso 2 allows an intimate knowledge of this subject.