Tag Archives: HSE

Residents of Canvey Island left to Face the Risks, whilst Castle Point Council, Fail to Develop an Adequate, operable Emergency Plan!

38,459+ Residents living on Canvey Island, seemingly oblivious to the everyday Risks and potential Harm facing them!

Whether the Risk is Tidal from the Estuary, Surface Water flooding or from the Hazardous Industries on the Island, a suitable Emergency Plan involving the Residents is essential.

The old Adage “we are safe from the Sea” is bunkum, as Castle Point Borough Council’s own evidence Highlights!   

 “Given the risk to the population, various measures are required to deal with the concerns to human health and wellbeing. These include:

• The need for an emergency plan to be in place;

• The need for sea defences to be maintained and improved;

• The need to maintain the population living in the flood risk zone at current levels or lower;

• The need for existing homes to be made more flood resilient, and include areas where people can remain safe in the event of a flood;

• The need for new development to incorporate design elements that make them safe in the event of a flood for occupiers;

• The need for building techniques to be used that enable easy restoration in the event of a flood.” (1)

Further CPBC Local Plan Evidence Documentation enforces the issues;

10.4 Tidal and fluvial flooding poses the most significant flood risk to the Castle Point Borough, in particular Canvey Island and Hadleigh Marshes. The topography and location of watercourses on Canvey Island means that the whole island is at risk from tidal and fluvial flooding. Although much of the Island is protected by the presence of defences, the island is still at residual risk of flooding if the defences were to fail or to be overtopped.

10.5 In the event that a breach in the existing flood defences was to occur, or a failure of one of the existing flood barriers (residual risk), significant depths of floodwater would be experienced on Canvey Island and the southern portion of the mainland.  Given the low lying nature of these parts of the Borough, floodwaters would propagate rapidly across Canvey Island thereby reducing the time for warning and evacuation of residents. (2)

During the Local Plan Intervention fiasco, CPBC informed the Secretary of State of particular physical circumstances of the Borough, considered to be legitimate constraints as to why the Authority could not provide for its Housing Development Needs.

“Of the urban areas of the Borough, Canvey Island, with approximately half of the Borough’s population, is defined by the Environment Agency as Flood Risk Zone 3a, being at or below sea level.

Further land is likely to be required on Canvey Island by the Environment Agency for improvement to existing sea defences in the lifetime of a Local Plan, further restricting opportunity for development

The Health & Safety Executive require significant exclusion areas to be maintained by the Local Planning authority around two top-tier COMAH sites on Canvey Island’s Thames Estuary frontage”, (3)

Direct Recommendations detailed within the CPBC Strategic Flood Risk Assessment state:

“The majority of the sites will rely on the provision of adequate emergency planning measures to mitigate the residual risk of tidal flooding in the event of a breach in the tidal flood defences.

It is therefore strongly recommended that the suitability of locating more residential accommodation on Canvey Island and the capacity of the existing egress routes off the island is further discussed with the Emergency Planning Team at Castle Point Borough Council and/or Essex County Council prior to site allocation” (4)

Remarkably, CPBCs Development Control Committee has taken responsibility, (having only aspirational resolutions for the various preventative requirements), for successfully seeing-through Housing developments at Canvey Island since January 2012.

In doing so exposing an increased number of residential and commercial population to Residual and/or Actual Societal Risks.

Emergency Plans supporting increased development on Canvey Island are seemingly only “Generic”, where by dealing with a wide range of possible scenarios such as for example Influenza Pandemics, with no “Specific Plans” that relate to a particular emergency.

Specific Plans are a detailed set of arrangements designed to go beyond the generic arrangements, when the latter are likely to prove insufficient in particular cases such as breaching of flood defences or total LPG tank failure. (5)

It would appear that CPBC have not considered the value of Specific Planning in relation to Canvey Island, if they have, they have not included the involvement of the community in the production of specific planning for viable emergency incidents.

Editor, I will leave the reader with an opportunity to provide a Rationale as to how our local authority, Castle Point Borough Council has managed “Residual Risks” via its Local Planning strategy.

Document References

  1. The CPBC Sustainability Appraisal and Strategic Environmental Assessment Scoping Report, New Local Plan January 2012
  2. Castle Point Borough Council New Local Plan 2018 Technical Evidence: Summary Document June 2018
  3. CPBC Response letter to Sajid Javid 31st Jan 2018, regarding why Government Intervention in the Local Plan process was unnecessary.
  4. Revised Castle Point 2018 Strategic Flood Risk Assessment
  5. Chapter 5 Cabinet Office Revised Emergency Preparedness. Definitions of “Generic” and “Specific” Emergency Planning.

China Crisis = Answer to Canvey Island issues? Or – Castle Point’s Broken Local Plan Process “the continued development of Canvey Island is necessary”???

“The continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement.”

So say, Castle Point borough council planning officers in their programmed approach to avoiding objections to each and every proposal for development on Canvey Island.

This programmed response, supporting perpetual development, is in respect of evading opposition and objection to the “Special Case” position the officers are ordered to adopt in consideration of Canvey’s Flood Risk Exception test.

Whilst Constraints on development in other areas of the borough are sited and strictly adhered to, as a matter of policy, similar approach to Canvey Island proposals appear less rigorously imposed.

Given that Canvey development should be constrained by the fact that the Island is a tidal Flood Risk Zone 3a area, is now deemed a Critical Drainage Area following the surface water flooding during 2014 and previously, as well as being the location of 2 Top Tier Comah hazardous industrial sites.

That there is only one access / egress point, that the Island’s dedicated Rapid Response (paramedic) Vehicle is being withdrawn and that, like other areas the Police and the Fire and Rescue service presence has diminished.

These factors, one would think given Canvey Island’s geographical position, may cause outsiders to wonder why castle point borough council planning department should be so manipulative, when they recite such Unsound Drivel as “the continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement”!

Higher up the local government ladder the planning department superiors have indentified in contrast, that on tidal Flood Risk alone, they consider that the population of Canvey Island should be limited to the level prior to 2011, OR LESS!

However cpbc Cabinet, Councillors, Officers and Planners ALL choose to ignore this apparently sensible and cautious approach to Housing Numbers, one can only assume, so as to limit the levels of apparently necessary, but unpopular, Housing Need elsewhere in the Borough!

Now whilst our local “public servants” propose and impose yet more development, both Housing and Industrial, onto Canvey Island under the pretext that, “the continued development of Canvey Island is necessary to sustain the local community and prevent the social and economic blight of the settlement” they would do well to appreciate what is going on far from here.

Local decision makers, in their desperation to support the Borough’s income stream and limit the perceived Housing Need on the mainland, are willing to overlook potential Hazards and Constraints that should, by Rights, limit the ever-increasing Canvey Island Population Growth, through the means of our broken Local Plan process!

This Blindfolded and Wreckless approach to Development Planning on Canvey Island, has directly led to the flooding of many properties during 2013 / 2014, and is continued unabated, despite the clear warning towards adoption of a more cautious approach following the Calor escape of 163 tonnes of liquified gas forming a  vapour cloud over the Island!

Whilst the efforts of the Essex Fire and Rescue Service to convince cpbc members that their vastly reduced level of cover for Canvey Island would be adequate in the event of a major accident at either of the 2 Hazardous sites, their claim should not serve as supporting evidence for continually increasing the Population of Canvey.

Castle Point, we believe, would be totally justified in adopting a Limited Population Approach to its Housing Supply through its Local Plan Process, especially where Canvey Island is concerned.

This approach would be fully justified and would protect local builders and developers alike.

An ever-increasing population has little or no justification in any of the reasons recited by cpbc in its flimsy evidence to direct the levels of development growth towards Canvey Island, indicated in their various versions of failed Local Plans .

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It is Amazing then to discover that a Far Eastern Country should have adopted a Plan that puts concerns for its Population and Environment first, by recognising the Need to Limit Population Levels.

Whilst we do not compare the population levels of Shanghai and Canvey Island, it does indicate that limiting population, rather than the contrived reasoning behind the proposal for the ever-increasing population numbers policy, as applied by Castle Point Council Strategic and Local Planners!

 “China’s financial hub of Shanghai will limit its population to 25 million people by 2035 as part of a quest to manage “big city disease”, authorities have said.

The State Council said on its website late on Monday the goal to control the size of the city was part of Shanghai’s masterplan for 2017-2035, which the government body had approved.
“By 2035, the resident population in Shanghai will be controlled at around 25 million and the total amount of land made available for construction will not exceed 3,200 square kilometres,” it said.
State media has defined “big city disease” as arising when a megacity becomes plagued with environmental pollution, traffic congestion and a shortage of public services, including education and medical care.

But some experts doubt the feasibility of the plans, with one researcher at a Chinese government thinktank describing the scheme as “unpractical and against the social development trend”.
Migrant workers and the city’s poor would suffer the most, predicted Liang Zhongtang last year in an interview with state media, when Shanghai’s target was being drafted.

The government set a similar limit for Beijing in September, declaring the city’s population should not exceed 23 million by 2020. Beijing had a population of 21.5 million in 2014. Officials also want to reduce the population of six core districts by 15% compared with 2014 levels.
To help achieve this goal authorities said in April some government agencies, state-owned companies and other “non-core” functions of the Chinese capital would be moved to a newly created city about 100 kilometres south of Beijing.
An exact date for when those offices will have to move has not been set, but Beijing officials have already begun reshaping the city’s population.

Tens of thousands of migrant workers were evicted from their homes beginning in November, after authorities launches a 40-day crackdown on unsafe buildings in the wake of a fire.
Many of China’s biggest cities also face surging house prices, stirring fears of a property bubble. Beijing and Shanghai have enacted strict rules on who can purchase property and the two cities are the most vulnerable if prices begin to tumble.
Shanghai had a permanent population of 24.15 million at the end of 2015, the official Xinhua news agency said last year.
The city has also said it would intensify efforts to protect the environment and historic sites as part of its masterplan.” *

As a further reminder, we make no apologies for reminding readers of the devastating effects on households Hazardous Accidents have the potential to cause, as seen in this Video recording.

Grateful thanks go to Ian Silverstein for use of his video.

*Report filed for the Guardian by; Benjamin Haas in Hong Kong and agencies
Tue 26 Dec ‘17
Reuters contributed to this report

And for those who have read this far, here is a link to some music – China Crisis’ recording of “Wishful Thinking”.

We thought the title appropriate!

Dates, Canvey Islanders won’t even Notice! Thorney Bay’s, on its way!

Canvey Islanders, it is said, haven’t the nous to have a cynical thought cross their little minds.

Firstly, following the Election announcement on the very last day prior to the period of Purdah commencing, the Jotmans Farm Appeal Inquiry was Rejected by the then Secretary of State, thereby saving important mainland Green Belt from development.

Secondly, tomorrow, 6.6.2017, just 2 Days prior to the General Election, castle point council development committee will decide the Recommended Approval “first phase” of the Thorney Bay vast green field development, on Canvey Island.

Thorney Bay Beach Camp, Canvey Island, Essex

copyright Jason Hawkes

This so called first phase at Thorney Bay amounts to 113 new dwellings.

The development committee Agenda paperwork indicates officers advise :

It is not considered necessary for Members to visit the site prior to determination of the application.

This despite :

To the north of the site is the Local Wildlife Site (LoWS) Thorneyfleet Creek, which comprises a water body with Common Reed and rough grassland; beyond this is residential development. To the east is Public Open Space, in the form of a grassed area and children’s play space. To the south and west is the wider expanse of the Campsite. A water treatment works lies to the west of the wider site and beyond this is the Calor gas terminal. To the south is the Canvey Island Sea Defence, beyond which is the River Thames.

Of the Health and Safety Executive’s comment;

..more than 10% of the housing development area lies within the (Calor Gas Hazardous) middle zone….and HSE Advised Against Granting Planning Permission.

The HSE then go onto excuse the proposed development layout, stipulating that castle point council must not in future use the self regulating facility, instead be referring any future development directly to the HSE!

The Case Officer comment, which will no doubt be pointed out to the planning committee members in the Agenda Paper states; 

Health and Safety Executive  No objection.

As far as potential flooding is concerned, especially as the site is directly reliant on the Canvey Sea wall Defences;

Environment Agency  No objection: following the receipt of a revised FRA, subject to conditions and the satisfaction of the LPA that the proposal will be safe for its lifetime

It should also be noted, should the are become flooded yet again that responsibility has been relieved of the Leal Local Flood Authority (Essex CC.);

It is the applicant’s responsibility to check that they are complying with common law if the drainage scheme proposes to discharge into an off-site ditch/pipe. The applicant should seek consent where appropriate from other downstream riparian landowners. 
The Ministerial Statement made on 18th December 2014 (ref. HCWS161) states that the final decision regarding the viability and reasonableness of maintenance requirements lies with the LPA. It is not within the scope of the LLFA to comment on the overall viability of a scheme.

But of course the Rumours emanating from CPBC is that Thorney Bay will become a Park Home site, So None of these Rules Will Apply!

1,600 static caravans could quite easily become 1,000+ Park Homes, and there is the next Local Plan’s 5 Year Housing Supply.

Let existing Canvey Island residents and future property owners be warned!

We make no apology for over-simplifying these issues but for anybody interested the webcast and recording should be available via;  https://castlepoint.gov.uk/webcasting

The meeting Agenda papers are available via; https://www.castlepoint.gov.uk/agendas-minutes-library


“Dear John” Letter from the HSE to Castle Point Council spells a loss of Trust over Thorney Bay!

“WOULD NOT ADVISE AGAINST” Is a phrase that is akin to music to Castle Point Planners ears!

So often does it extinguish any questioning by planning committee members of the extra conditional advice from the HSE, or the Environment Agency, or the Lead Local Flood Authority, when the committee consider Canvey planning applications!

At the Risk of being accused of Scare-mongering, and unlike some that “run with the fox AND hunt with the hounds”,  we prefer to refer to our approach to development as being Cautious, when we refer to Canvey’s constraint issues.

The proposal for the first phase of the Thorney Bay Housing development, cpbc planning application No: 14/0620/FUL, to sit alongside existing caravans is progressing, albeit in an apparently unusual sequence. Given the obvious issue of the neighbouring Calor, Top Tier Comah site, one would have thought that Castle point planners would have made early use of the Health and Safety Executive’s online planning advice app.

It appears however that despite cpbc receiving the planning proposal on the 6th November 2014, no such enquiry was made to the HSE, until the 12th January 2017!

Whilst an initial use of the HSE planning app was made for the original “proposal in principle,” cpbc planning application No: CPT/707/11/OUT, of 600 dwellings plus residential care homes, lodged with cpbc as long ago as 2011, this resulted in an acceptance that 10%, or 60, of the total number of dwellings could be developed within what is labelled the hazardous “middle zone”.

The more “recent” application, for 113 dwellings, sought to use a proportion of the 60 dwellings allowed, sited in the “middle zone,” BUT at a much higher proportion, in relation to the latest planning application, of over 26% !

Rather surprisingly this did not appear to occur to OUR local authority that they might just possibly feel they should refer this percentage level to the HSE!

The developer may indicate the future development phases will have a much lower level of percentage dwellings in the hazardous “middle zone”.

They MAY also find in future these development phases prove unviable without similar high percentage rates, 26%, within the “middle zone,” and having set a precedent within the first phase who could argue?

This seeks higher density development across the whole site, something that would suit developer and the cpbc Local Plan authors equally!

It is somewhat reassuring that the Health and Safety Executive appear to have lost faith in castle point council and with their policy approach towards increasing new residents risk to the exposure to the Hazardous Site.

The HSE have dictated to cpbc that they no longer can take advantage of the HSE’s online Planning Advice App, they have decreed that in future, NOT ONLY ALL future Thorney Bay planning applications which propose development in the “middle zone” must be referred directly to the HSE, but that the 30 dwellings proposed within the current application, is the TOTAL number they will permit!

It appears that Castle Point Council have, at least where the HSE is concerned, used the “Canvey is a Special Case” card once too often!

For those with a more sceptical attitude, we suggest the same may also have led to the problems at Buncefield which led to the events recorded in this resident’s video recording below.

Hindsight can be a wonderful thing, but in the meantime Caution may be the better option and it will be interesting to learn how the cpbc Local Plan Inspector views this approach, should the Plan reach the Examination stage and of course to observe the cpbc development committee’s consideration of the proposal.

 Grateful thanks go to Ian Silverstein for use of his video.

The Castle Point Borough Council planning Devil is in the Detail!

The devil is in the detail, is an idiom that Castle Point Council appear to rely on where development approvals on Canvey Island are concerned!

Far too often development proposal comments by consultees are taken at face value in the support of approval recommendations of the “professional” officers.

Rarely do development Committee members challenge the points of recommendation, simply because of a lack of alternative information.

Within proposal consideration for Calor and Oikos will often be the Health and Safety Executive comment; “Do not Advise Against”.

Within a recent appeal inquiry in Oxford a Do not advise against comment was made by the HSE in regard to a development near a Hazardous site.

However the local authority, UNLIKE Castle Point felt they should seek independent advice, rather than rely on untrained officers taking the HSE at their exact word. The advisor to the Oxford council considered that;

Do not advise against is not the same as saying planning permission must be granted. 

Overall the HSE methodology is designed to identify sites where the HSE feels obliged to advise against planning permission.

However, their only other advice category of do not advise against is not equivalent to supporting the application being granted.

As already established it is quite legitimate for a local planning authority to take a different view on the merits of granting planning permission, so long as the HSE’s advice has been taken into account.

That the HSE disputed some of the advisors comments, was not disputed, what is relevant is that the local authority had attempted to seek objective advice that may not be available amongst local authority officers.

The development in question, is in a less significant Flood Risk Area than that of Canvey Island.

The local authority in Oxford have a shortfall in housing land and under estimated their Objectively Assessed housing need, as is likely to be found in the case of Castle Point’s local plan 2016.

Despite this and the fact that the site in question was for a great deal fewer dwellings than in the case of Thorney Bay, the Oxford local authority turned down the application.

Castle Point of course have approved in principle outline permission for 600 dwellings, a residential institution plus the retention of static caravans and included these numbers within their daft New Local Plan and Local Plan 2016!

This despite the developer having relied on quoting the CPBC’s previous consideration: “The most recent Strategic Housing Land Availability Assessment (SHLAA) (2011)  indicates a potential range for dwelling units for the site between 378 and 595”

All based upon them achieving a “do not advise against” response from the HSE.

The Environment Agency acknowledge an agreement with Castle Point council in which Canvey is to be treated as a Special Case where Flood Risk and housing development needs for the whole Borough is concerned!

Canvey representatives really do need to start reading the SMALL PRINT where planning proposals are concerned!

  Footnote: Neither of the local Parish nor Town councils concerned in the Oxford case have given any indication that they intend to produce a Neighbourhood plan.  No evidence was submitted of any preliminary works in this regard. 

What a whiff of gas in the Canvey air has uncovered.

The Echo today reports on concerns of Canvey residents following the leakage from Calor Gas last week.

Many issues of concern appear to have been brought to the surface; the lack of information, the lack of a warning system similar to that offered by the Environment Agency should flooding be forecast, the removal of the Canvey warning sirens, the lack of Full Time Fire and Rescue Crews on the Island, and the impossibility of an efficient emergency evacuation of residents.

Castle Point Council insist the emergency plan must remain confidential as it contains sensitive information. It must remain secret as if it were to bee made public information contained within may threaten the security and safety of the site, its staff and local residents.

Despite this Castle Point Council are content to make information and the position of tanks and their purpose for use, available for all on their Planning Portal, in the case of OIKOS!

Testing of the emergency procedures are scheduled to take place in October to satisfy regulations. However these are only a “desk top” exercise.


Essex County Council appear to feel that the correct approach were potential major accidents are concerned is to keep Canvey residents uninformed. The approach appears to be, to hope the worst, never happens!

This is not a grown up, responsible and sound way to treat the residents and future residents of Canvey Island!

For the County Council to suggest that “the offsite effects of a major accident (at either, or both, Calor Gas and OIKOS) would be very limited,” is irresponsible to say the least!

We thought lessons had been learned from the Buncefield, Hertfordshire incident in 2005, little sign that Castle Point and Essex County Council accept what just might, might happen to Canvey.


The proverbial way mushrooms are grown: “Keep them in the dark and feed them with s**t”

Similar to the threat from Tidal Flooding and Surface Water flooding we are fed assurances that it will never happen to Canvey Island. A quick watch of a Buncefield resident’s video of the effects on his property and the aftermath of that incident should leave you hoping that Castle Point Council, Essex County Council and the first responders are well prepared.

It should also leave you wishing to know how best to respond should similar happen on Canvey Island.

Grateful thanks go to Ian Silverstein for use of his video.

Maurice Richmond wrote in the Echo:

WORRIED families on Canvey claim they have been left in the dark over what to do in the event of a major emergency.

It comes as dozens of residents reported a strong smell of gas in Long Road and Fairlop Avenue areas of the island last Thursday afternoon, prompting them to call both Calor Gas and National Grid in search of answers.

Calor Gas, in Thames Road, confirmed that the smell was caused by a small gas leak with an additive designed to give gas a detectable odour and was in fact harmless.

However despite this, campaigners are worried that a “lack of public information” is putting their safety at risk in the event of a major incident at either one of the island’s top-tier hazardous sites – Calor Gas and OIKOS terminals in Haven Road,

Aresident, of Janette Avenue, lives near to the OIKOS terminal and says he has very limited information on how an evacuation.

He said: “The only thing that we have been told to do is to switch off electricity and gas and to close our windows and wait for information on a wind up radio.

“That doesn’t say how we can evacuate the island in an emergency and even then only some of my neighbours actually know about this. Years ago there was a document telling us what to do, which was called “Advice to Householders.” It documented Canvey Island’s Emergency Procedure.

“I want to know what has happened to it, and what we should be doing if there is a major incident.

Under Health and Safety Executive guidance for Control of Major Accident Hazard Regulations 2015 it states that local authorities “must consult the public” when preparing the external emergency plan.”

The regulations add that “a local authority in whose administrative area an upper tier establishment is situated must prepare an external emergency plan specifying the measures to be taken outside the establishment.”

A 61 year old resident, of Haven Road is angry about the lack of information that is available from authorities Suffolk, Plymouth and Medway, but not for Canvey.

Canvey Island and Hazardous Industry policy nearly received the Brush off!

The Local Plan Task and finish group met to discuss policies surrounding the hazardous industries on Canvey Island.
It was interesting to note that of the two policies concerning Port related activities and that of Waterborne freight, both policies were altered so as to reflect the representations of the port of London Authority, Oikos and calor gas!
The third policy, relating to Developments near Hazardous Uses, was not objected to by PLA or Calor, with just OIKOS registering support for the policy. Castle Point Council therefore suggested that the policy required no amendments.
Proof enough for residents to examine the policy.
A map was shown to councillors illustrating the zones around the two hazardous sites. Each zone controlled whether housing or other development was allowed. The inner zone = no development, the middle zone = limited development, the outer zone = development allowed generally speaking. In other words these are the minimum permitted Government (HSE) limited distance for development.
In the light of the Buncefield enquiry there is a recommendation that these zones are extended further from the hazardous sites.
CPBC new Local Plan seeks to approve policy, ahead of any new HSE recommendation based on the existing zonal limits.
I will use an analogy.
An employer makes an employee, of many years dedicated service, redundant. The employer limits the redundancy package to the Government minimum settlement. That would infer that the employer is unconcerned whether he is considered an employer of good reputation.
Likewise a local authority seeks to develop new housing as near to a hazardous industrial site as the government minimum distances allow, possibly risking the well-being of future residents having bought these new houses should an incident occur. That would infer that the Local Authority is unconcerned whether it is considered a council of good reputation!
The outcome of the meeting was that the particular policy decision was deferred and that the CIIP member should return with recommended wording changes to the policy.
Other members refused to accept or read the short documentation that was offered by cllr Watson.
For those interested, and not among the 4 residents that made the journey to the council chamber for the meeting, here is that document;
Recommendation and Support Rationale

7.4 Actions for the Task and Finish Group Policy NE12

Insufficient weight has been given to the residual risk and risk ramifications emanating from the Top Tier COMAH sites and how this could impact on the societal risk to the community of Canvey Island.

Extract from
Buncefield Major Incident Investigation Board.
Recommendation on Land Use Planning and Control of Societal Risk around Major Hazardous Sites.

Role of planning authorities

52 The planning authorities take decisions on planning applications having taken into account the interests of the local community (both business and residential), the interests of the developer and relevant safety and environmental considerations. This includes advice from HSE regarding developments within the consultation distance of a major hazard site. Of recent years this advice has been available in the vast majority of cases through a software tool developed by HSE. This is known as PADHI (Planning Advice for Developments near Hazardous Installations).

53 HSE advice, though, only takes account of the potential to cause human harm because its remit is limited to occupational health and safety. No account is taken of damage to property and disruption to personal lives and economic activity, but we believe it should and that the Buncefield event amply demonstrates why. If a wider view of ‘harm’ is taken, then the planning authority will need to seek advice from other organisations in addition to HSE.

54 The above briefly illustrates the complexity of the decisions planning authorities can be faced with. There is guidance to planning authorities in the various administrations on how to balance the various considerations in reaching their decisions, but not sufficient guidance on how to balance safety clarity and transparency considerations in relation to other issues around major hazard sites – there needs to be greater clarity and transparency over how decisions are reached. Decisions that will increase the population around major hazard sites should be clearly explained to all those affected. More resources may be required to assist planning authorities to interpret specialist advice and to fully understand the wider impacts of their decisions.

That further work be undertaken that ensures that “no stone is left unturned” in considering the implication of Land Use Planning and the corresponding Societal Risk emanating from a major incident at the COMAH sites on Canvey Island. The New Local Plan must give full consideration and deliberation to ensure that the concerns expressed by our community are further fully examined.

The following are some examples of the documentation available to the Authority from which to base a conclusion that sufficient work has been undertaken.

1.“Buncefield Major Incident Investigation Board.”
Recommendation on Land Use Planning and Control of Societal Risk around Major Hazardous Sites.

The extract on page 1 is an example as to why this document needs to be examined and its recommendations fully considered.

2.“The Community Risk Register.”

The relevant community risk register has previously provided risk assessments which include the likelihood and potential impact emanating from the types of hazardous substances found at the COMAH installations on Canvey Island. Information being expressed for the storage of LPG has in the past identified a considerable number of potential casualties beyond the site boundaries following a credible accident. Incidents resulting from malicious events have not been considered.

3.“Information contained in specific COMAH site Safety Reports”.

Whilst there may be some sensitive factors for disclosure contained within these reports, it is in the public interest that they are fully informed about the potential environmental and health and safety issues of major accidents at fuel storage terminals. This will allow the public to make informed decisions about where they choose to live and work.

It must be clearly understood that it would be inappropriate that some factors, specifically relating to the number of Population at Risk, to be disclosed within this forum. It must also be understood that those aspects contained within Safety Reports that would have an adverse impact on public safety and national security should be considered elsewhere.

4.“Seveso Directive.”

Essentially these European Directives have the specific objective of controlling certain new developments to maintain adequate separation, including residential area, buildings and areas of public use around major hazards when the development is such as to increase the risk or consequences of a major accident.
In essence, decision-makers should ensure that new development does not significantly worsen the situation should a major accident occur


The New Local Plan has not provided evidence that justifies the proposed increase in the population around major hazard sites. There is no clarity or transparency as to how decisions have been reached. The result of a Do-Not-Advise against resulting from the use of the Planning Advice for Development near Hazardous Installations process, is very limited when assessing the totality of Societal Risk. There is no evidence that the New Local Plan has taken Societal Risk into account when considering Land Use Planning issues. The adoption of the previously stated recommendation, will serve to give a stronger indication that a full examination into the subject of societal risk has in fact been undertaken. The subject matter referred to here is not exhaustive, indeed Canvey Island has historically been the example as to where Societal Risk has given cause for concern.

I therefore direct members to the recommendation included within Page 2 of this document.

Again, so as to bring the gravity of this subject and the concerns for Canvey residents, I make no excuse for again including the link to the Buncefield incident and its impact on a resident