Hselup
Hselup
TOM MADDISON
Health and Safety Executive (HSE)
1. BACKGROUND
In the UK arrangements have existed since 1972 for local planning authorities (PAs) to
obtain advice from the HSE about the safety implications for developments from risks
associated with chemical major hazards.
The HSE’s approach to advice originates from a strategy described in the recommendations of
the UK Advisory Committee on Major Hazards (ACMH, 1976-84), set up by the Health and
Safety Commission in 1974 in the aftermath of the Flixborough chemical disaster, namely:
• identification - establishing where major hazards exist;
• prevention and control - reducing the risk of a major accident using controls on-site; and,
• mitigation - reducing the impact of a major accident, if one should occur, through
emergency planning and land use planning control.
Following the UK Flixborough disaster in 1974, the Advisory Committee on Major Hazards in
its second report (Para 109, (ACMH, 1976-84)) stated: ‘The overall objective should always
be to reduce the number of people at risk’ and in its third report (Para 80, (ACMH, 1976-84))
said ‘it is wise to avoid a substantial growth in population near an existing installation’.
This is now taken into account throughout the EU in Article 12 of the EC Seveso II Directive
(EC, 1996) which requires that ‘Member States shall ensure that the objectives of preventing
major accidents and limiting the consequences of such accidents are taken into account in
the land use planning...’1
1 Member States shall ensure that the objectives of preventing major accidents and limiting the consequences of
such accidents are taken into account in their land use policies and/or other relevant policies. They shall pursue
those objectives through controls on:
• the siting of new establishments,
• modifications to existing establishments covered by Article 10
• new developments such as transport links, locations frequented by the public and residential areas in the
vicinity of existing establishments, where the siting or developments are such as to increase the risk or
consequences of a major accident.
Member States shall ensure that their land use and/or other relevant policies and the procedures for
implementing those policies take account of the need, in the long term, to maintain appropriate distances
between establishments covered by this Directive and residential areas, buildings and areas of public use, major
transport routes as far as possible, recreational areas and areas of particular natural sensitivity or interest... so as
not to increase the risks to people.
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The Health and Safety Executive (HSE) advises Planning Authorities (PAs) on applications
for development in the vicinity of major hazard sites and major accident hazard pipelines.
HSE also advises PAs on applications for Hazardous Substances Consent to create a new
major hazard site, or for Consent to modify an existing major hazard site. HSE is also
consulted on the routing of new major accident hazard pipelines.
To improve the service to local Planning Authorities and to increase the transparency of the
HSE’s advice, a policy decision was taken to codify the process and experience obtained
over 30 years whilst continuing the HSE’s policy of giving clear advice for or against a
proposed development.
Following this decision, the previous scheme has been replaced with a new scheme known
as PADHI + (Planning Advice for Developments near Hazardous Installations (1)). This has
now been provided to PAs as a computer programme which they can use themselves to
obtain advice. The codified scheme does not represent the true situation of a gradual
change in risk with distance but is a pragmatic way to generate timely advice: it is intended
to give broadly similar decisions to the previous system that are consistent across the UK
and allows a more effective use of the HSE resources. Thus the scheme may be seen as a
development of the previous system rather than a replacement.
It must be stressed that, in this context, HSE’s role is purely advisory. It is for the PA to
weigh all of the different factors in the balance and decide whether or not permission should
be granted. However HSE has the right of appeal to a Government Minister if it believes
sufficient weight has not been given to the safety aspects.
This advisory function is distinct from HSE’s role as a regulator of major hazard sites.
Residual risk
HSE’s advice is based on an assessment of the residual risks to people presented by the
major hazard site. Residual risk is the risk that remains after the site operator has done all
that they need to do to comply with the law (noting that the law does not require the risks to
be zero). The residual risk concept also recognises that a lapse in vigilance at a site that
normally complies with the law can lead to an accident.
An estimation of the outcome, including consideration of the types of accident events which
could take place at a major hazard, the scale of these accidents and how far away their
impacts could be felt. This is termed an estimation of the scale of the consequences.
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An estimation of how likely it is that these events will take place, and therefore how likely it is
that certain consequences could be experienced around the major hazard. This is termed an
estimation of the frequency (since the likelihood is usually expressed as a frequency) and
may be either qualitative or quantitative in nature.
HSE’s assessment of the risk may be either protection based or risk based, depending on
the specific features of the major hazard site under consideration (and particularly on the
nature of the dangerous substances present).
The protection based approach relies upon a consequence based assessment, where only
the potential effects of selected accidents are quantified. The likelihood of particular accident
events happening is considered in a qualitative way. This approach is used for the majority
of major hazard sites storing or handling flammable substances especially liquefied
petroleum gas (LPG).
The risk based approach involves quantification of both accident consequences and
frequencies, enabling numerical estimates of risk to be calculated. This method is known as
quantified risk assessment (QRA). For major hazards where the dangerous substances
present are toxic (e.g. chlorine or ammonia), and for some hazards arising from flammable
materials (e.g. flash fires resulting from accidental releases of liquefied natural gas), HSE’s
advice is based on risk, using QRA.
The estimates of risk produced by a risk assessment, like any prediction, are subject to
uncertainty and it is important that this is recognised when establishing the criteria used for
giving advice.
3. HARM CRITERION
It has often been assumed that risk criteria for major hazards should relate to the likelihood
of death. This seems straightforward and easy to compare with risks from other hazards in
life. However there are two important problems with a criterion based on the risk of death in
the present context:
(a) society is concerned about risks of serious injury or other damage as well as death;
(b) there are technical difficulties in calculating the risks of death from a hazard to which
individual members of a population may have widely differing vulnerabilities using an
injury criterion other than death.
It is possible to avoid some of these problems by using an injury criterion other than death.
For example, it is possible to define a dose of toxic gas, or heat, or explosion overpressure
which gives all the following effects:
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• Some people are seriously injured, requiring prolonged treatment;
• any highly susceptible people might be killed.
HSE describes this as a 'dangerous' dose because it has the potential to cause death but it
will not necessarily do so. Then the risk assessed is that an individual at a particular place
will be exposed to such a dangerous dose or worse. For more information on this see ref (9).
HSE’s Reducing Risks, Protecting People(2) document indicates that an individual risk of
death of less then 1 in a million per year would be regarded as broadly acceptable, for the
purposes of judging if the risks from an existing major hazard site to an existing population
are acceptable. For the purpose of giving land use planning advice HSE uses the figure of 1
in a million per year for the lower bound, but in relation to the risk of receiving a 'dangerous'
dose or worse, for a typical pattern of user behaviour in a development.
For developments where there would clearly be a high proportion of highly susceptible
people, a more stringent criterion is judged to be appropriate. HSE considers that a level of
1/3 in a million per year of a dangerous dose or worse would be trivial even for such cases
as homes for the elderly, caring institutions, long-stay hospitals etc. This provides a lower
bound, below which advice on land use planning on the basis of individual risk is not
warranted.
In terms of an upper limit, the Reducing Risks, Protecting People document indicates that,
where members of the public have a risk imposed upon them, then an individual risk of
death in excess of 100 in a million per year would be considered unacceptable. This
criterion would apply when considering the risk presented by an existing major hazard site to
the existing surrounding population, and whether HSE should take enforcement action
against the operator of the site to ensure that the risk is reduced. However, in the context of
a proposal to introduce additional population into the vicinity of an existing major hazard site,
HSE considers that a more stringent criterion is appropriate. Hence HSE uses an upper limit
of 10 in a million per year of a dangerous dose or worse, depending on development size
and type.
For the purposes of delivering land use planning advice, HSE defines a Consultation
Distance, within which are usually three zones (Inner, Middle and Outer) around the major
hazard. When using a risk-based approach, the zone boundaries correspond to levels of
individual risk of dangerous dose or worse, as follows:
Inner Zone (IZ): 10 chances per million per year (cpm) or greater individual risk of
dangerous dose or worse;
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Middle Zone (MZ): Between 10 cpm and 1 cpm individual risk of dangerous dose or worse;
Outer Zone (OZ): Between 1 cpm and 0.3 cpm individual risk of dangerous dose or worse.
Individual risk results are commonly presented as a set of contours drawn on a map, where
the contours join together points at which the individual risk is the same.
0.3 cpm
1 cpm
X
Major
Hazard
IZ
MZ
10 cpm
OZ
The numerical risk criteria can only be applied where a QRA is undertaken. For protection
based assessment of fire and explosion hazards HSE has developed a set of criteria which
relate to the nature of the hazard presented under various different accident scenarios.
These criteria define zones within which the following levels of harm are experienced.
Inner Zone (IZ): exposure to the effects of a major accident would lead to a significant
proportion of the population being fatally injured.
Middle Zone (MZ): exposure to the effects of a major accident would lead to a very low
proportion (a few %) of a normal population being fatally injured.
Outer Zone (OZ): exposure to the effects of a major accident would lead to a very low
proportion (a few %) of a vulnerable population being fatally injured.
Vulnerable populations would include the elderly and the sick (e.g. hospital patients).
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7. PROPOSALS FOR DEVELOPMENT IN THE VICINITY OF EXISTING MAJOR HAZARD
SITES
Once the details of the development are known and its location within the zones then the
PADHI+ software can be used by the PA to generate advice (1). The figure below shows the
overall process for provision of HSE’s advice to PAs on applications for development in the
vicinity of existing major hazard sites.
The PADHI+ software (provided to PAs by HSE) receives inputs describing the development
and which land use planning zone the development is in, and then generates the appropriate
HSE advice. The advice given depends upon the size and nature of the development and
the zone in which it is located (IZ, MZ or OZ). The advice generated by PADHI+ is either
that HSE ‘advises against’ or ‘does not advise against’ the proposed development on the
grounds of safety.
The size and nature of the development is taken into account by assigning the proposed
development to a Sensitivity Level. Essentially there are four Sensitivity Levels:
Sensitivity Level 2: Based on the general public – at home and involved in normal activities;
Sensitivity Level 3: Based on sensitive or vulnerable members of the public (e.g. children,
those with mobility difficulties, those with certain health conditions or those unable to
recognise physical danger);
Sensitivity Level 4: Large examples of Level 3 and large outdoor examples of Level 2.
Within each Sensitivity Level are a number of Development Types, which are used as a
direct indicator of the sensitivity of the population at the proposed development. Exceptions
are made for some very large or very small developments by assigning them a higher or
lower Sensitivity Level than normal for their Development Type. As a general principle the
Sensitivity Level is decreased by one for small examples of a type of development, and
increased for large and very large examples of a type of development or where particular
features of the development increase the risk to the population.
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Fig 2 – Overall land use planning process
Outer Zone
The HSE notifies the PA of the
consultation distance associated with the
major hazard, within which proposals for Middle Zone
development would trigger the consultation
arrangements Inner Zone
Major
Hazard
Consultation
The PA considers the HSE’s advice, Distance
together with all of the other factors
for and against the proposed
development, then decides whether or
not to grant permission.
Within PADHI+, a decision table is used to generate the advice, in conjunction with a set of
rules. The decision table is displayed in. Table.1
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Land Use Planning Advice Decision Table
Sensitivity Level Development in Development in Development in
Inner Zone Middle Zone Outer Zone
1 DAA DAA DAA
2 AA DAA DAA
3 AA AA DAA
4 AA AA AA
Notes:
AA: Advise Against
DAA: Don’t Advise Against
It should be noted that, as a result of the accident at Buncefield in December 2005, HSE has
introduced particular arrangements for large scale petroleum storage depots which differ
from those described above.
Generally speaking this system has worked reasonably well in the UK and for most of the
time Planning Authorities have complied with our advice. However the UK is a very crowded
island and some problems have started to emerge with giving advice mainly based on
individual risk.
The main problem is that planning applications are dealt with on an individual basis and
cannot take into account the piecemeal or incremental growth of the total population near to
a major hazard site. Eventually, a situation is reached whereby the risks from the MH
establishment are no longer reduced as far as is reasonably practicable. (ALARP) and the
HSE may then require the operator to implement measures to reduce the risks. This problem
arises because the HSE’s current system considers each new development proposal on its
own merits, with no consideration of the change in overall societal risk from the MH site.
(See an illustration of this in Figs 3, 4 and 5)
Another difficulty arises from proposals for new large scale development in the vicinity of MH
sites that are beyond the CD but still sufficiently close to be affected by some of the events
at the site. Although the individual risk associated with the location is low, the societal risk
generated is significant. Furthermore, since the proposed location is beyond the CD, the LA
is under no obligation to consult HSE and grants permission for the development.
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Fig 3 Low level of Societal Risk
0.3 cpm
Increasing 1 cpm
Level of
Societal X
Major
Risk Hazard
Criterion IZ
line
MZ
10 cpm
OZ
0.3 cpm
Increasing
Level of 1 cpm
Societal Risk
Major
X
Hazard
Criterion IZ
line
MZ
10 cpm
OZ
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Fig5 Incremental Development
Societal Risk criterion is exceeded
0.3 cpm
Increasing
Level of 1 cpm
Societal
Risk Major
X
Criterion Hazard
IZ
line
MZ
10 cpm
OZ
The risks from major hazards are of direct concern to the individual people who might be
injured, but they are also of concern to society at large since there is the potential for large-
scale disasters. It is generally recognised that these two aspects both require consideration
in risk criteria for major hazards.
Individual risk is the likelihood that a particular person might be harmed. For the purpose of
this document, the person may be, say, a typical inhabitant of a house at a particular
location, or a typical user of a leisure facility at a particular location.
Whilst individual risk is a useful measure, it does not reflect one important feature of major
accidents – their potential to affect large numbers of people at once. The societal risk
addresses this aspect. Societal risk is usually expressed as the annual chance of harming a
certain number of people. In simple terms, societal risk reflects the disaster potential of the
major hazard site.
National Societal Risk: The risk to the nation as a whole from a particular type of activity
(e.g. nuclear power, or the transport of dangerous goods).
Local Societal Risk: The risk to a localised population from a particular type of activity (e.g.
the risk to the population of a town near a heavily industrialised area where a number of
major hazards are present).
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Case Societal Risk: The risk at a particular location or from a particular activity (e.g. the risk
to persons who would be present at a proposed shopping centre in the vicinity of an existing
major hazard, or the risks to an existing population from a proposed major hazard).
The principal means of dealing with case societal risk (the societal risk of individual
developments) is through the PADHI+ system, where Sensitivity Levels are used to
represent increasing scale of the development and vulnerability of the associated population,
but this does not deal with local societal risk which is the risk of harming a large number of
the total population around a site.
For the majority of major hazard sites in the UK, HSE’s advice is based principally on an
assessment of individual risk, with case societal risk being addressed semi-quantitatively by
classifying proposed developments into different Sensitivity Levels. However, there is a
small proportion of major hazard sites where it is the view of Government Ministers that the
local societal risk has reached a level where it is worthy of explicit consideration alongside
individual risk and case societal risk.
In view of this a new approach is being developed which will take into account local societal
risk. (3)
Within societal risk attention zones, the principal means of advising PAs on local societal risk
is through consultation on the development plan or local development framework (LDF).
This advice supplements that given by HSE with respect to individual applications for
development.
The process of consultation on the major hazard risk implications of a development plan or
framework involves not just the PA and HSE, but also other stakeholders such as
emergency planners, the emergency services and the operator of the major hazard site.
The objective of this wider involvement is to enable a fuller exploration of all the public safety
issues arising from the long-term plans for development in the vicinity of the major hazard
site.
The proposal is that when consulted by a PA on a draft development plan or framework that
is associated with a societal risk ‘attention zone’, HSE assesses the level of local societal
risk currently arising from the major hazard site(s) affecting the plan area; Assesses the case
societal risk associated with the site allocations or development proposals described in the
plan / framework; and, assesses the overall change in local societal risk resulting from
implementation of the plan / framework.
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11. SOCIETAL RISK CRITERIA OR GUIDELINES
An Individual Risk criteria framework is well established in the UK (2) and is widely followed
by industry and regulators. Societal Risk considerations are implicit to some degree in
existing land use planning advice, but although Societal Risk is used in risk assessment
there are, as yet, no widely agreed societal risk criteria. An indicative point is presented in
(2) (50 deaths at 200 chances per million (cpm) per year). This was proposed by HSE as a
basic criterion for the limit of tolerability, particularly for accidents where there is some choice
whether to accept the hazard or not, e.g. the risk of such an event happening from a major
chemical site or complex continuing to operate next to a housing estate.
There is a developing industry framework for Societal Risk criteria summarised in (8) and a
possible approach could be based on the guidelines shown in Figure 6. It can be seen that
these guidelines do not explicitly include scale aversion. This scheme is based on
established reference criteria or anchor points, and proposes four guideline bands to use to
initially assess the results of societal risk calculations.
R2P2 Point
1.0E-03
ACMH Point
Serious Concern
or Intolerable
1.0E-04
Frequency of N or more fatalities (/year)
Significant
Moderate
1.0E-05
Broadly
Acceptable
1.0E-06
1.0E-07
1.0E-08 12
1 10 100 1000 10000
Number of fatalities (N)
Figure 7 illustrates an FN curve for a sample hazardous installation plotted over the
guidelines from Figure 6. Land use planning advice may initially be guided by the position of
the FN curve in relation to the comparison lines. If the FN curve was substantially above the
upper comparison line this would indicate significant societal risk and a high expectation
value or EV (A measure of the potential number of people killed per year from an installation
EV), and attract firm negative advice. (EV – Expectation Value is the sum of all the fN pairs
for a defined situation. Also referred to as PLL – potential loss of life.)
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An FN curve also shows the more dominant contributors to the EV, in terms of whether they
are high or low frequency or high/low N, or a combination of the two. This could form the
basis to review development plan proposals to reduce potential risks.
Figure 8 shows the individual risk contours for an installation, at 10, 1, 0.3 chances per
million (cpm) of dangerous dose. These contours form the basis for existing land use
planning advice, defining the inner, middle and outer zones. The outer contour defines the
existing consultation distance for hazardous installations.
Figure 8 also shows a blue line that is plotted at a distance of twice the consultation
distance. This is expected to be the outer boundary for most societal risk planning advice.
The basis for this is that outside this distance individual risks are low and the EV from most
developments is likely to be a very small proportion of the existing EV. Extremely large
developments, located outside the blue line, where very large numbers of people may
accumulate cannot be completely ignored, and may have to be included in a screening
process.
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Map based representations of risk assessment results could be more informative and useful
to planners giving an indication of areas more suitable for development. For example map
based representations of risk could help illustrate to planners preferred locations for new
developments.
Figure 9 EV density (hot spots) map (night time residential population), colour scale numbers in
fatalities per year per hectare.
HSE is looking at how these measures, and others, could be used to provide advice to local
planning authorities. Conversely HSE is also consulted on proposals to construct and locate
new major hazard sites.
A company proposing to construct a new major hazard site would need to apply for
Hazardous Substances Consent from the Hazardous Substances Authority. Where the
operator of an existing major hazard site wanted to modify their site (for example, to increase
the maximum quantities of dangerous substances present allowed), then they would need to
apply for a variation to their Hazardous Substances Consent. In either case, HSE would be
consulted by the Hazardous Substances Authority.
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HSE’s assessment of proposals for new major hazard sites (or changes at existing major
hazard sites) involves consideration of both the individual risk and the societal risk to the
people living in the surrounding area.
The overall approach involves a number of steps, as illustrated in Fig 10 below. The
detailed methodology for a given situation differs according to whether the assessment of
the proposed major hazard site is risk based or protection based.
Figure 10 - Deciding what Advice to Give for a Proposed Major Hazard Site
Yes No
Yes No
Advise Don’t
Against Advise
Against
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12.2 Incompatible Land Uses
In order to assess the significance of the individual risks from a new major hazard, estimates
of the location of the inner, middle and outer zone boundaries are made, using a risk based
or protection based approach as appropriate. This is Step 1 in Fig 8. Then, in Step 2, the
pattern of existing land use within each of the three zones is then studied. The following
land uses would be considered to be incompatible with the presence of a major hazard site:
If the zones encompass any existing land use that would be considered incompatible (Step
3), then the response from HSE will be to advise against the major hazard site as proposed.
Where there are no incompatible land uses, the assessment proceeds to Step 4 (see below).
In addition, HSE will advise against granting of Consent for a new major hazard site, or for
alterations to an existing major hazard site which would increase the risks from that site, if
any member of the public is subjected to a level of individual risk from all major hazards in
the vicinity in excess of 100 chances per million per annum.
Where no incompatibilities are detected, then HSE performs initial assessment of the
societal risks (Step 4 in 8). The methodology used for this initial assessment depends on
the nature of the proposed major hazard site, and particularly on whether the approach used
is protection based or risk based.
The local societal risk is broadly acceptable, leading to a ‘don’t advise against’ response
by HSE; or,
The local societal risk is clearly so high that an ‘advise against’ response should be
given; or,
The result is not clear-cut and detailed analysis, possibly in conjunction with
consideration of additional risk reduction measures at the proposed site, is necessary.
In the case of the last of these outcomes, the assessment proceeds to Step 6 in 8.
For proposals to introduce new installations, activities or facilities at an existing major hazard
site, or modifications to installations the process is similar.
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REFERENCES
1. PADHI Planning Advice for Developments near Hazardous Installations – HSE’s Land
Use Planning Methodology www.hse.gov.uk/landuseplanning/padhi.pdf
2. Reducing Risks Protecting People. HSE’s decision making process. ISBN 0 7176 2151
0 HSE Books, First published 2001.
3. CD 212 Proposals for revised policies to address societal risk around onshore non-
nuclear major hazard installations. HSE Books. www.hse.gov.uk/consult/index.htm
4. Evidence or otherwise of Scale Aversion: Public Reactions to major disasters.
Reference 0091699-TN03 Rev. 4. June 2009. ERM report for HSE.
5. WS Atkins Technical Note 1. Development of potential frameworks for the assessment of
societal risk. Atkins 5077030 TN1 Issue 02 November 2008, for HSE.
6. What is wrong with FN-Criterion lines for judging tolerability of risk? A W Evans and N Q
Verlander. Risk Analysis, 17(2), 157-168. (1997).
7. I. L. Hirst, Risk Assessment – a note on F-N curves, expected numbers of fatalities and
weighted indicators of risk, J. Hazard. Mater. 57 (1998) 169-175.
8. HSE Research Report RR703 – Societal Risk: Initial briefing to the Societal Risk
Technical Advisory Group. www.hse.gov.uk/research/rrhtm/rr703.htm
9. Risk criteria for land-use planning in the vicinity of major industrial hazards HSE Books
ISBN 9780118854917
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