Wednesday’s Local Plan Task and Finish Group meeting covered the Constraints on Housing within Castle Point, see our previous Blog post covering the meeting HERE.
Views were expressed on the protection of Green Belt, the status of our Green Belt, Flood Risk from both surface and Estuary and at this very late stage of the Local Plan proceedings the Hazardous Industries on Canvey Island.
This debate appeared to expose the complacent, if not deceptive way the issue of Safety has been presented through the Core Strategy and the Local Plan!
Here for clarity is an explanation that not only clears up the matter for residents, but also questions Castle Point Council’s approach;
There is a requirement of all operators of Top Tier COMAH Hazardous Site Installations such as the Calor Gas LPG Storage Site on Canvey Island, to provide a comprehensive Safety Report.
Reports are submitted to the Competent Authority for assessment against the Safety Report Assessment Manual. Once passed through examination the report is made available to Local Authorities, in this case Castle Point Borough Council .
An important aspect of this risk based approach to mitigation is to recognise that it is based upon the likelihood of an incident and that should one occur the potential consequences will, in the worst case, extend beyond the land use planning zones in the down wind direction.
Thus local authorities off site emergency plans need to be drawn up accordingly.
Hazardous Installation Safety Reports are designed and expected to provide additional information than that identified by Consultation Distances and Public Information Zones.
The Control of Major Accident Hazards Regulations 2015
“251 The local authority cannot prepare an external emergency plan for an establishment without obtaining necessary information from the operator. This information will not normally be the entire safety report.
The operator should provide that information which is relevant to preparing the external plan, including major accident scenarios and consequences.
The operator must provide this information by the date on which the internal plan has to be prepared to comply with regulation 12(2) and should also ensure that any information supplied to the local authority is updated as necessary in the light of any changes.
252 Some establishments may be designated by the competent authority as being part of a ‘domino group’ – establishments where the likelihood or consequences of a major accident may be increased because of the location and proximity of other establishments and the dangerous substances present there.
These establishments need special consideration in terms of emergency planning and the testing of the off-site response. The operators in the group must co-operate with each other in supplying any relevant information to the local authority.”
Those parts of the Calor Gas safety report that deal with “The Population at Risk” and the Impact on Population, demonstrate the extent and severity of a credible major accident scenarios which has been modelled to reveal that there is an extensive population likely to be affected.
It would seem that this aspect has not been considered when planning applications are being deliberated upon by the Castle Point Borough Council Planning Authority, even though they act as the Boroughs Hazardous Substance Authority.
The subject of safety reports has been covered within this site and
having noted a recent local newspaper article that deals with the expectations of the availability of Hazardous Sites Safety Reports I would like to take an opportunity to dispel any suggestion that the Calor Gas Company on Canvey Island have in any way failed to provide the required information to the HSE/ Environment Agency i.e. the Competent Authority that satisfies the necessary criteria and content of its current Safety Report.
The most recent COMAH regulations require that a review of Safety Reports be undertaken to take account of, amongst other points, the following issues.
“At least every five years – regulation 10(1)
191 It is important that the review not only details the changes that have occurred, but also assesses the significance of the changes in terms of the identification, prevention, control and mitigation of major accidents. Examples include: changes in the land use of areas surrounding the establishment, including changes in population; or changes in the conservation designations of the surrounding area.
Particular attention should be given to the cumulative effects of any minor changes that have taken place over the period.
192 One of the purposes of the review is to see whether the standards, both
technical and procedural, remain appropriate in the light of new knowledge and technological developments. For example, it may not always be sufficient for the operator to maintain the plant and systems in an ‘as built’ condition. If the review reveals that further measures are necessary, these additional measures should be taken.”
Given this requirement It would seem imperative that a Planning Authority keep this in mind when dealing with a planning application as it may have a financial implication on the ability of an installation to maintain its safety systems to the required expectations.
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