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Energy Division’s Proposed Policy on Targeting and Prioritisation

Energy Division’s Proposed Policy on Targeting and Prioritisation. WIG Conference 18 September 2013 Susan Mackenzie [2013/326517]. HSE’s Intervention Policy. Enforcement Policy Statement Targeting, Proportionality, Consistency, Transparency , Accountability HID guiding principle (2012)

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Energy Division’s Proposed Policy on Targeting and Prioritisation

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  1. Energy Division’s Proposed Policy on Targeting and Prioritisation WIG Conference 18 September 2013 Susan Mackenzie [2013/326517]

  2. HSE’s Intervention Policy • Enforcement Policy Statement • Targeting, Proportionality, Consistency, Transparency, Accountability • HID guiding principle (2012) • Major hazard intervention programme should be based on a systematic approach based on • inherent hazard and • performance of duty holder in controlling risk

  3. Major Hazard Sites in UK 288 operational installations + 800 “COMAH” Sites 500 Biohazard Laboratories 500 Licensed Explosive Sites 300 Major Hazard Pipelines 50 Gas Distribution Networks 6 Major Hazard Mines

  4. Priority for Intervention

  5. Examples of onshore Inherent hazard models

  6. Inherent Hazard Model Offshore Offshore Working Group (March 2013) Principles • Broad classification • Information readily available • Preferably based on industry’s own information • Major hazard focussed

  7. Broad Classifications on Inherent Hazard • High • Medium • Low • Pictorial view • Not based on a mathematical algorithm • Will require some professional judgement

  8. Example – Draft 5

  9. Inherent Hazard based on PLL

  10. Operator Performance • Operator’s performance in complying with the law to control Major Hazard risk will influence the depth and frequency of regulatory scrutiny. • Operator Performance against single inspection topics • Strategic areas • Key risk control systems • Based on standards

  11. Offshore inspection rating topics

  12. Inspection guides • Cover strategic and sector topics • Define what we look at • The standard/benchmark against we rate performance • Performance score • Enforcement expectations • How we record (COIN requirements)

  13. Operator Performance

  14. Overall Operator Performance • Work in progress across HID • Individual scores of 30-60 are compliance gaps • Do not intend to “average” out compliance gaps. • A full picture of performance will be built up over a number of years • We will continue to feedback performance at each inspection in usual way

  15. Other intelligence may include [Nothing New] • Time since last inspection • Issues arising out of other regulatory contact such as • safety case assessment • incident investigations • complaints • Incident data • Emerging issues

  16. The concept of Indicative Resource Levels

  17. Inspection plan progress report

  18. Any further questions

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