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Following the Longford gas plant explosion in 1998, the state of Victoria in Australia has mandated a safety case regulatory regime for all major hazard facilities. Complying with the requirements has proved to be a rewarding but also a challenging and time-consuming process, and the deadline for completion is fast approaching.

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Neil Hubber, Australian Vinyl's Laverton plant manager.
Penny Drew, Dow Chemical's safety, health and environmental manager at its Altona facility.
The accident at the Longford Gas Facility resulted in two fatalities and left the whole state without gas supply for several weeks. The Longford Royal Commission, which involved DNV experts on safety management systems, put forward several recommendations for safer operation of major hazard facilities. One was to implement a mandatory safety case regime. Another was to establish an autonomous governmental Major Hazard Division (MHD).

Implementing a mandatory safety case, or report, is regarded as an effective means of risk management where reliance is in part placed upon self-regulation. Luke Chippindall, DNV risk engineer, explains Implementing a safety case means that companies have to demonstrate to the authorities, in this case the Major Hazard Division of the Victorian Workcover Authority (VWA), that their management of process safety is effective, comprehensive, commensurate with the risks, and auditable. For many companies, the deadline for complying with the requirements is June 30 this year while for some it is even sooner.

Elevating standards for safety
Australian Vinyls, assisted by DNV Melbourne, completed the first safety case in Victoria for its Laverton plant outside Melbourne in late 2001. Says Neil Hubber, plant manager, We wanted to get a head start on the process, since the regulations were coming anyway. At the plant our workforce has always displayed a healthy attitude towards safety, but the safety case allowed us to identify critical processes and explain to a wider circle of people exactly why they are critical. As a result a few things improved quite markedly, and the general level of understanding has been raised. DNV assisted us with interpreting the regulations and providing guidance, which has been helpful as the safety case process is quite complex. The next time this will be much easier due to all the work that has already been done.

Australian Vinyls is the country's only manufacturer of PVC (polyvinyl chloride) resin, which is used in vinyl products. The company's safety case is currently under government review. When approved, the safety case licence may last up to a maximum of five years.

A time-consuming process
The around 50 facilities that were determined to be major hazard facilities by the MHD all have in place their own safety management system. The challenge is to mesh this system with the governments requirements. DNV, which has been assisting Dow Chemical since late 1999, has brought its global experience to provide local advice. Says Penny Drew, Dow Chemicals environment, health and safety manager in Australia, 'The process has clearly been of value to us, but it has also been costly and time-consuming. One of the advantages of the safety case is that its flexible. We have therefore been able to draw on our own experience and base it on the Dow Chemical safety culture. The Altona plant is the first in Dow Chemicals to implement certain aspects of the new corporate safety management system. As we are one of the smallest Dow Chemical plants, the safety case work has given our plant a higher profile in the company than it otherwise would have had.

Demonstrating safety
Qenos, a joint venture between the Australian company Orica and ExxonMobil Chemical, has several plants in Australia, which primarily produce polypropylene, synthetic rubber, engineering plastics and a diverse range of speciality polymers. Qenos started the safety case work with the intention of learning as much from the process as possible. Says Paul Kennedy, safety engineer at the Altona facility, Our safety, health and environment operating system has been in operation for 10 years. DNV helped in interpreting the regulations and showed us how it would impact on our operations. What we have learned from the process, which is a lot, will be transferred to our other plants.

Joseph Micallef, safety engineer advisor, confirms that Operating safely is as natural to us as breathing, so it was never a matter of just writing a safety case. Having to explain to the government that we do what we say we do has been a challenge, especially since the outcome has to do with our licence to operate the facility. However, the ultimate aim of the safety case is to achieve a safe and good working environment, which is something we all want.

Date: 15 April 2002

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Safety Case in brief

(From the Longford Royal Commission's report)
" The safety case method of risk management emerged in Europe after the occurrence of disasters involving the release of flammable chemicals at Flixborough in the UK in 1974, and of toxic chemicals at Seveso in Italy in 1976. A directive of the European Commission, known as the Seveso Directive, published in 1982, required member states to develop and implement regulations directed to the safety of major hazard sites. The directive did not extend to offshore facilities.

" After a series of catastrophic explosions and fires on the Piper Alpha platform in 1988, an inquiry, chaired by Lord Cullen, focused attention upon the safety case method by recommending the extension of its application to offshore facilities. This is now mandatory for UK North Sea operations.

" Using a safety case, or report, as a risk management tool is now spreading not just to other states in Australia, but also internationally. Shell has applied this approach on its oil and gas installations in the Gulf of Mexico, and the Norwegian government has mandated the safety case for oil and gas installations on the Norwegian continental shelf.

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