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Safety and environmental standards for fuel storage sites
Buncefield Standards Task Group (BSTG) Final report
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Health and Safety
Executive
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Contents
Foreword
Introduction
Part 1: Action required to prevent a further incident – what must go right!
Systematic assessment of safety integrity level requirements
Control and safety systems for petroleum storage tanks
Incorporating the findings of SIL assessments into COMAH safety reports
Protecting against loss of primary containment using high-integrity systems
Management systems for maintenance of equipment and systems to ensure
their continuing integrity in operation
Tank overfill prevention: Defining tank capacity
Fire-safe shut-off valves Remotely operated shut-off valves (ROSOVs)
Testing overfill protection systems
Safe management of fuel transfer
Engineering against loss of secondary and tertiary containment
High reliability organisations
Roles, responsibilities and competence
Staffing and shift work arrangements
Shift handover
Organisational change and management of contractors
Performance evaluation and process safety measurement
Emergency arrangements
Principles On-site emergency plan
Firefighting planning and preparation
Part 2: Detailed guidance on standards for the transfer and storage of fuel
Systematic assessment of safety integrity level requirements
Control and safety systems for petroleum storage tanks
Incorporating the findings of SIL assessments into COMAH safety reports
Protecting against loss of primary containment using high-integrity systems
Management systems for maintenance of equipment and systems to ensure
their continuing integrity in operation
High-integrity, automatic operating overfill prevention systems
Tank overfill prevention: Defining tank capacity
Fire-safe shut-off valves
Remotely operated shut-off valves (ROSOVs)
Testing overfill protection systems
Safe management of fuel transfer
Engineering against loss of secondary and tertiary containment
Bund integrity (leak-tightness)
Fire-resistant bund joints
Bund capacity
Firewater management and control measures
Tertiary containment
High reliability organisations
Roles, responsibilities and competence
Staffing and shift work arrangements Shift handover
Organisational change and management of contractors
Performance evaluation and measuring process safety performance
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Emergency response arrangements
Principles
On-site emergency plan
Firefighting planning and preparation
Part 3: Work in progress on process standards
Protecting against loss of primary containment using high-integrity systems
Maintenance of records
Engineering against loss of secondary and tertiary containment
Bund floors (impermeability)
Fire-resistant bund joints
Bund capacity
High reliability organisations
Management of plant and process changes
Delivering high performance through culture and leadership
Long-term industry leadership
Leadership and process safety culture Process safety management
Hazard identification, layers of protection and assessment of their effectiveness
Emergency response arrangements
Part 4: Comparison of BSTG recommendations with the MIIB report on the
design and operation of fuel storage sites
Appendices
1: Example LOPA assessment for an overfill scenario
2: Defining tank capacity
3: Job factors for management of fuel transfer
4: Key requirements for operational planning 5: Process safety performance indicators
Glossary
References
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Foreword
How industry responds to incidents such as Buncefield and how the regulators
respond on behalf of the public is a measure of our society. A decisive and
dynamic response with all parties co-operating is the product of a democratic and
advanced society.
If there is a serious incident then everybody, including the public, the company
directly involved and any company in the same or similar sectors, suffers
consequences to a greater or lesser extent. It follows that all companies have a
vested interest in ensuring that these incidents do not occur. Stakeholders have a
right to expect compliance with a minimum set of standards and expectations from
everybody in a particular sector and compliance with a higher set of standards for
specific situations involving higher than normal risks.
Shortly after the Buncefield incident, the Buncefield Standards Task Group (BSTG)
was formed consisting of representatives from the Control of Major Accident
Hazards (COMAH) Competent Authority and industry, with the aim of translating
the lessons from Buncefield into effective and practical guidance that industry
would implement as rapidly as possible. This also facilitated a joined-up approach
to managing risk across the sector by providing an authoritative benchmark for
standards and practices. The intent was to ensure more consistent responses to
broadly similar risks. Existing guidance was reviewed and confirmed as industry
standards, with extra detail and examples added where necessary, while in other
cases new standards were created to close gaps. This report contains all of the
recommendations of BSTG including those previously released. A separate report
will detail the progress made in complying with the initial recommendations.
In parallel with the BSTG work, the Buncefield Major Incident Investigation Board
(MIIB) conducted an investigation into what happened at Buncefield. Information
from the MIIB’s reports and from safety alerts issued by the Competent Authority
was factored into BSTG work as appropriate. In addition, BSTG also considered all
the factors that need to go right to prevent such an incident, which helped define
further areas for action. In March 2007, the MIIB issued a report Recommendations
on the design and operation of fuel storage sites.1 It sets out 25 recommendations
to improve safety and environmental performance. Many of these had already been
fully addressed by the BSTG’s work, although others have only been partially
addressed or have yet to be addressed. This lack of an identical match is due to
the decision made at an early stage to balance the need for putting improvements
in place rapidly with the need to await the MIIB’s full recommendations. We believe
that BSTG made the right decision, with significant improvements already having
been achieved.
One of the guiding principles of BSTG has been that we would be judged on the
delivery of improvements, not simply on an intention to deliver. We have achieved
much already; however, we are not complacent and realise that much work
remains to be completed. Outstanding matters will be taken forward by the
Petrochemical Process Standards Leadership Group (PPSLG), which replaces
BSTG, whose working life ends with the publication of this report. PPSLG will also
oversee the monitoring of and reporting on compliance with all of their
recommendations, as well as those of BSTG.
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I believe that the way in which industry and regulator have come together to co-
create and deliver action to prevent a Buncefield-type incident is a model for the
future. PPSLG will continue the approach of industry and regulator being ‘aligned
but not joined’, whereby we are committed to delivering timely and appropriateagreed action through mutual challenge and understanding of our particular
perspectives. Delivery is an essential part of building trust upon which this
approach depends. Critically, success requires us to ‘say what we will do’ and ‘do
what we say’.
Please read this report and turn its recommendations into action. Doing so may
well prevent you and others from suffering the adverse consequences, whether to
people or the environment, of an incident.
Ken Rivers Chair
Buncefield Standards Task Group
24 July 2007
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Introduction
1 The purpose of this report is to specify the minimum expected standards of control which should be in place at all establishments storing large vo