Report on Major Hazards and Notifications
Reports submitted on Major Hazards and Notifications must be stand-alone documents that are sufficient to meet the contents and level of detail required by the law, without the need to refer to other external documentation.
The guidance material below defines the required content and level of detail expected in relation to each of the submitted documents, such that they comply with the requirements of applicable Law.
The ALARP principle states that all risk reduction measures must reduce risk to levels that are “As Low As Reasonably Practicable”.
This guidance document provides detailed information on HEREMA’s requirements for an ALARP assessment to demonstrate that the Major Hazards risk is ALARP.
The Operator/Owner must establish a verification scheme carried out by an Independent Verification Body (IVB) under L.4409/2016 (Article 17) that provides an independent review of the above activities, through a process of audit, examination and witnessing of assurance routines. Independent verification means an assessment and confirmation of the validity of particular written statements by an entity or an organisational part of the operator or the owner that is not under the control of or influenced by, the entity or the organisational part using those statements.
This Verification Guidance document sets out the requirements for a notification and Report on Major Hazards submissions, requirements for acceptance of an Independent Verification Body by HEREMA, the processes that are required within any verification scheme, and the requirements for different types of schemes.
Thorough Review of a Report on Major Hazards
A Report on Major Hazards must be subject to a thorough review at least every five years. Under Articles 12 and 13 of the law, HEREMA can also direct an Operator/Owner to undertake a thorough review at its discretion (e.g. following an incident, or series of minor incidents).
This guidance document on the conduct of thorough reviews draws on the requirements of Annex III of L.4409/2016, as well as those in Annex IV and Article 19, requiring cooperation between HEREMA and owners/operators in developing (and hence using) best practices for major accident management.
Internal Emergency Response Plan Requirements
According to Article 11 Paragraph 1(g) of L.4409/2016, the Report on Major Hazards must include a description of the operator’s or owner’s internal emergency response plan (IERP). This guidance document details the basic requirements of an IERP. The description of the internal emergency response plan should provide evidence that it satisfies these requirements. However, the contents of each installation-specific IERP will need to be formulated according to circumstances and will be assessed accordingly.