Emergency Plans Steve Jones Pembrokeshire County Council COMAH - - PowerPoint PPT Presentation

COMAH External Emergency Plans

Steve Jones Pembrokeshire County Council

COMAH Regulations 1999

• Duty for Local Authorities to

prepare emergency plan for accidents which result in consequences beyond the site boundary

• Regulations updated in 2015 –

Offsite is now External

• Although sites were consulted,

plans tended to be ‘imposed’.

• Very little tie-in between site

emergency plan and offsite plan.

COMAH Exercises

• Duty to carry out live

exercise every three years

• Usually FRS turning up

to spray lots of water / foam around

• Valuable for the FRS

and on site fire staff

• Rarely testing specific elements of plans
• No coordination between onsite and offsite responses
• For some sites very difficult to come up with credible

scenarios to have realistic off-site impacts

Chevron Pembroke Refinery 2nd June 2011

• Four fatalities but not a

COMAH incident

• Impacts for the site and

the community were no less than for a ‘full’ COMAH event

• The COMAH plan was

used for the response

• Investigation still ongoing
• Coordination was lacking in

the response

• Debrief identified lack of

training available for tactical staff as an issue

JESIP

• Since 2012 Emergency

Services have been rolling out JESIP

• 2016 extended to all

responding agencies

• The model by which

responses are judged

• COMAH plans now based

upon JESIP Principles

• COMAH exercises used as an
• pportunity to put into practice

JESIP theory

JESIP / COMAH Exercises

• Problem identified that
• nly FRS & HART go

inside Security fence

• An argument over which

vehicle bonnet was OCG

• Solution to pre-identify rooms /

facilities as multi-agency OCG

• These have been agreed and

placed in COMAH Plans

• Also since tested in COMAH

exercises (worked well)

South Hook LNG Planning

• The site were busy refreshing their onsite plans and

training staff for specific roles

• They suggested that the on and off-site plans should

align

• Asked us to use the same Representative Scenarios

from their HSE Safety Report.

• Even asked that we

use their computer graphics to ensure both sets of plans seamlessly align.

South Hook LNG Exercise Puffin 2015

• The first live test of the merged plans / responses
• Multi-agency OCG (Bronze) sited next room to Onsite

Incident Management Team

• Information flows were good, particularly ensuring

casualty figures, names & destinations were correct

• A certain lack of understanding of roles between site

staff and responders was evident

Multi-agency OCG SHLNG Incident Management Team

Post Exercise

• It’s no good having an exercise

without identifying good practice and areas for improvement

• Following a COMAH exercise

a debrief report is prepared into the multi-agency response

• This is shared with the other

Industrial Partners via the LRF Industrial Hazards Group

• Recommendations are tracked
• n the LRF Performance

Management System to ensure they are not forgotten

The Way Forward

• In 2017 the LRF TCG Training was adapted to allow for

partners from industrial facilities to participate

• The sites have put aside commercial confidentiality to

allow observers in each other’s exercises

• Efforts are underway to align on-site response

mechanisms and roles between the sites

• A programme of annual multi-agency COMAH 360o visits:

A site visit for tactical commanders to experience the topography and site processes A briefing from SHLNG regarding their emergency response and expectations of Responding agencies Counter briefings from Emergency Responders about their roles and expectancies from the site Particularly relevant is the briefing of what to expect in the event of deaths on site

Progress so far

• What used to be a very much ‘Us’ and ‘Them’ approach

to planning, training and exercising is no longer the case

• Now it is just ‘Us’
• A recognition that a problem for one can affect us all
• Hopefully the next time there is a major incident the multi

agency response will be better coordinated. Downside As the level of training and expertise of site staff increases, they start to recognise some of the shortcomings of other responding agencies who tend to have a higher rate of staff turnover

Thank you Any Questions?