For a while now, the Castle Point Development Committee have assumed the role of the Hazardous Substance Authority (HSA).
It appears that Council committee members, charged with decision-making, have been offered no relevant training, simply expected to follow the “guidance” of officers. On this basis they were required last evening to consider the change of consent granted during 2012 to OIKOS.
Photo credit: Echo News
This would allow the importation, storage and blending of butane. The intention is to use the nearby Calor Gas jetty to unload the fuel, store and pump through to OIKOS as required.
For the first time the Council Agenda made clear that the HSA (committee members) were responsible for the decision.
The OIKOS representative also made clear that the area had been used for the importation of fuel for some 70 years (80 years according to the CPBC Agenda). The clear implication this underlines is that CPBC planning authority are responsible for allowing housing development near the site.
The proposal Case Paperwork stated: “The Calor Gas terminal has the ability to import and store butane. It therefore makes sense, and would entail least risk, for Oikos to import butane from Calor’s storage or the jetty at the Calor terminal, under the process consented by Calor’s HSC” – “It considers that there would be less risk in the importing of butane over Calor’s Jetty rather than Oikos existing No 1 jetty, which is closer to residential dwellings at Haven Quays and to the Oikos’s offices”
However there was no supporting documentation from the Calor Gas Company that shows support for this application. Given that the Calor Gas Company are solely responsible for the activities undertaken upon its jetty, it would not be unreasonable for the HSA to be able to question representatives of Calor, as to what additional measures have been put in place to secure safe operation of it’s now shared facility.
It could also be considered that the safety benefits of using the Calor Gas jetty in preference to the Oikos No 1 jetty is negated by the additional risk imposed upon the existing large residential caravan development within the middle zone of Calor Gas hazard range.
“Residual Risk Page 1 Even after all reasonable practical measures have been taken to ensure compliance with the requirements there will remain a residual risk of an accident which cannot entirely be eliminated. HSC controls ensure that residual risk to persons in the surrounding area and to the environment is properly addressed by land use planning”
This is the first time that residual risk and land use planning has been given the appropriate weight with regards to Hazardous Sites, previously the HSA has not been consulted when dealing with planning application in or around hazardous sites.
In effect the HSA (CPBC Councillor committee members) are being asked to take account of the totality of effect emanating from a major incident at the domino sites of Calor Gas and Oikos.
It would not therefore be unreasonable for the HSA to question its ability to understand the complexities and dynamics needed in the process of adequately assessing the TOLERABILITY of RISK, without having under taken the in-depth training in order to do so.
This point has now highlighted that previous decisions made within its capacity of Acting HSA may have been inappropriately concluded. There is a requirement to review and revise, as appropriate, COMAH site Safety Reports.
Unfortunately, it does not emphasis the significant importance that these documents have to the Planning, Emergency Planning and Hazardous Substance Authorities. Operators must present Safety Reports that include the severity of the consequences for the WORST CASE EVENT in terms of expected numbers of fatalities and serious injuries in their accident consequence analysis. Less severe injuries should also be considered.
Societal Risk consideration are implicit to the relation of the hazardous site in relation to off-site populations and the density and types of site population. (residential caravans)
This application cannot be treated in isolation give the combined use of the Calor Gas jetty. It is imperative that the HSA had all of the details contained in the Safety Reports of both Calor and Oikos before a suitable deliberation regarding the risk and tolerability of risk can be fully appreciated.
It is unlikely that any of the Officers or the members of the Acting Hazardous Substance Authority have viewed these document and although it is not expected that a full understanding of their contents could, without considerable training, be achieved, it would be relatively easy for the responsible persons to recognise those aspects that would give a clear indication of the expected hazard range and ramifications of a major incident emanating from the installation of Calor or Oikos.
It would not have been unreasonable for the HSA to have insisted that they have before them, last evening, all of the relevant documents made available in a timely manner for them to make the appropriate judgements.
The proposal for the use of butane was approved, with Canvey Island representatives requesting their names were noted as voting for rejection. The officer in summary made the point that OIKOS did not need the Council’s (HSA’s) approval to commence production.
The Out Line Planning grant to the Thorney Bay Site was not considered necessary to give due material consideration to the OIKOS application and that the situation of the fact that a considerable number of known caravan dwellings within the middle consultation distance of the LPG installation of Calor, has not warranted comment despite the recent advice forwarded to Castle Point Planning Authority from the HSE.
The development committee members are expected to rely on the submission of the HSE. Castle Point Council did not feel it necessary to engage with a consultant to cross check information.
There appears to be unanswered questions for Canvey Island residents to concern themselves with.
Disclaimer:Content observations of the author and correct as far as can be interpreted by lay person no responsibility is accepted as to the contents factual correctness and advice should be sought before reprinting