Use of Gap Analysis in Making the Transition to Seveso II

Abstract

Operators in the position of having to prepare Safety Reports as required by the Seveso II Directive face a demanding task. For those who prepared reports previously under the Seveso I regime, the changes in the requirements for the contents of Safety Reports must be considered. For those having to prepare Safety Reports for the first time, the prospect of producing such a document is even more daunting.

For the purposes of this paper, operators of "top-tier" establishments are divided into three categories:

Category 1: Those having to produce Safety Reports for the first time under Seveso II;

Category 2: Those with existing Seveso I Reports, where parts of the establishment not covered by Seveso I now have to be covered; and

Category 3: Those with existing Seveso I Reports, where the parts of the establishment covered under Seveso II are the same as those covered under Seveso I.

This paper describes the use of "gap analysis" as a helpful first step in preparing Safety Reports by operators in all three categories. In each case, the output of the analysis is a summary of the key "gaps" and a programme of work for filling them, ultimately leading to the production of a Safety Report.

In the case of Category 1, although the operator has no previous Seveso I Report to use as a starting point, there may be other useful documents or studies available within the organisation upon which to build. For example, Preliminary Hazard Analyses or HAZOPs may have been performed which could form a useful basis for the identification of possible major accident scenarios. As an aid to the gap analysis in these situations, checklists have been developed, based on the guidance to the legislation.

For operators in Category 2, the gap analysis initially consists of a careful comparison of the contents of the existing Report with the new Report requirements as specified in the legislation and accompanying guidance. However, this alone is insufficient. The parts of the establishment not previously covered by the existing Report have to be considered. In order to address this, the remainder of the gap analysis is similar to that conducted for Category 1 situations.

Finally, for Category 3 operators, the gap analysis comprises a careful comparison of the contents of the existing Report with the new Report requirements as specified in the legislation and accompanying guidance.

full text (in word format)

Dr. A. P. Franks, Mr. M. L. Middleton and Mr. G. Bennett

DNV

Highbank House

Exchange Street

Stockport SK3 0ET

Cheshire

Tel +44 (0) 161 477 3818

Fax +44 (0) 161 477 3819

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