The coronavirus pandemic is having an impact on Major Hazard Establishments across the world. The UK HSE have pre-empted some issues by providing guidance documents for managing major hazard facilities during this period or by giving advise on how compliance with legislative requirements can be adjusted during this period. Refer to the UK HSE website for full details applicable in the United Kingdom.
Some of the UK HSE ideas may be useful in the South African context and a summarized below:
Managing with less staff
For Major Hazard Establishments the HSE have issued guidance to help make quick risk assessments for on the potential overall increase in risk during the coronavirus outbreak from:
- reduced staffing
- loss of key staff
- increased staff fatigue
Operators should assess the risks to:
- ensure continued safe running of establishments
- determine worst-case scenarios when some or all operations may need to stop
Refer to UK HSE website for this new guidance document “Short-term variation to the assessment and management of fatigue and staffing”.
Safety Reports including Risk Assessments
While none of the regulators of Major Hazard Establishments around the world can generally relax the requirements for risk assessments and reporting on the management of major hazard establishments, nor issue exemptions, the UK HSE do recognize the difficulties during this period and have suggested pragmatic alternatives. For example, they suggest while new high-level major hazard establishments will need to follow full process during the correct time frame, those undertaking 5-year reviews of facilities where nothing much has changed, may be given some leeway in terms of due dates etc. Those existing establishments that are making modifications that require an update to the Safety Reports can approach the regulator and may be addressed on a case-by-case basis.
Full Scale Emergency Drills
The UK HSE suggests that due to the outbreak, emergency resources normally involved in testing external emergency plans are likely to have been diverted elsewhere and will be unable to participate in tests. Emergency planners may still need to check the resilience and continuing operability of their plans and should explore alternative ways to do this, for example a limited desktop exercise or other virtual communication between involved parties. Full testing of external emergency plans should resume once circumstances permit.
Major Hazard Notification Processes
Many Major Hazard Establishments are making modifications to support a coronavirus response, for example modifying facilities to produce alcohol-based hand sanitizers. The UK HSE has suggested that a simplified and shorter notification process can be applied. This approach is also being followed in South Africa on a case by case basis.