Operator’s duty to prepare a safety report
The safety report is the primary document submitted by the operator of a place classified as a major hazard facility (MHF) to demonstrate to the department’s Chief Officer that systems at the facility are appropriate to manage risks by either eliminating or reducing as low as reasonably practicable the risk of a major incident.
There are three parts to the safety report:
- part A: Notifiable information
- part B: Risk assessment
- part C: Safety management system.
The safety report should be a succinct document that provides transparent validation and linkages between assessments, consultation and verification. Its aim is to assure the department’s Chief Officer that systems, methods and processes at the facility will prevent a major incident, and public and worker safety will not be compromised.
A safety report is a legally binding document for the purpose of section 3 of the Dangerous Goods Safety Act 2004.
A safety report is only required if a site has been classified as an MHF by the Chief Officer.
For further information on classification as an MHF, refer to When is a dangerous goods site also a major hazard facility (MHF)?
Dangerous Goods Safety (Major Hazard Facilities) Regulations 2007
- Regulation 25
- Regulation 18 (for further information on "notifiable information")
- Regulation 23 (for further information on "risk assessment")
- Schedule 1 - Threshold quantities for Schedule 1 substances (Tables 1 and 2)
- Schedule 2 - Notifiable information.
Dangerous Goods Safety Act 2004
- Sections 3 and 10 (for further information on "risk assessment").
The information provided below is for guidance purposes only.
Part A: Notifiable information
The notifiable information should provide a basis for the assessment of the level of risk of a major incident occurring at the place, and its potential consequences, to determine whether the place will be declared an MHF. The duration of the assessment process will depend in part upon the quality of the information provided in the notification.
- For a corporation – the full name of the corporation and trading name, Australian Company Number, registered address and place of business, nature of the corporation’s business.
- For an individual – the person’s full name, residential and business addresses, any business name used by the person, nature of the person’s business.
- The location – this information locates the facility, its address and contact details.
- The zoning for the place - Information about the zoning of the area on which the site is located can be obtained from the local government body responsible for the area.
- Land use in the area surrounding the place - Information about the type of surrounding land use should extend to land within the consequence distance of the site and include:
- identification of the type of land use such as residential, commercial, recreational, heavy industrial, light industrial
- identification of sensitive land use developments such as caretaker’s residence, schools, child care facilities, aged care facilities, hospitals, public open spaces, sports complexes and other sensitive land uses where people may congregate
- information about population density including an estimate of the numbers of people likely to be present in sensitive land use areas during normal business hours
- information about infrastructure such as railways, ports, roads, electrical substations
- information about areas such as wetlands, water courses, which may suffer environmental harm in the event of a major incident
- details of any pipeline carrying Schedule 1 materials, which enters or leaves the site.
- Scale maps for the area should be attached showing sufficient details of the natural and built environment to enable the regulator to assess the possible impact of a major incident on the people, property and environment in the area surrounding the facility. Maps should have the following clearly marked:
- sensitive land uses
- commercial premises
- industrial premises (including other major hazard facilities)
- residential premises
- major infrastructure (e.g. railways, ports, major electrical substations)
- major roads or highways
- environmental features such as waterways.
The purpose of this information is to provide an adequate description of the dangerous goods present, and the activities and processes associated with those dangerous goods, to enable the regulator to make an assessment of the risk of a major incident occurring at the place.
The following information must be provided.
- A list of all dangerous goods that will be on the site, with:
- the name of each kind of dangerous good
- a copy of the safety data sheets (SDSs)
- the quantity at the place.
- A description of the nature of the business or other activities on the site, and the use or production of dangerous goods in conducting the business or activities. Details of processing and storage activities, any pipelines used for Schedule 1 materials and loading /unloading operations should be included. A process flow diagram should be attached where appropriate
- The number of employees at the facility to include information about:
- The usual hours of operation of the facility
- The maximum number of people, including contractors normally on site
- An indication of where people are normally located on the site.
- The hours of operation for transport related activities associated with the facility, such as loading/unloading of road, rail or ship transport
- Scaled plans of the facility must be attached showing:
- The layout of the place
- The boundary of the facility
- The location of all areas of storage and handling of dangerous goods. Process units, storages, tanks, pipelines that contain dangerous goods, other transport movements should be clearly marked. The distance from the boundary should be indicated for each.
Regulation 18 allows the department’s Chief Officer to direct, in writing, an operator to provide additional information following receipt of the notification. The direction will specify the additional information required and the date by which the additional information must be received.
Part B: Risk assessment
The safety report needs to contain an overview of the risk assessment process and outcomes, and state where the supporting material is available.
Duty to prepare a risk assessment
Regulation 23 requires the operator of a major hazard facility to prepare a risk assessment for the facility.
The risk assessment should:
- identify all hazards relating to dangerous goods at the facility
- for each hazard:
- assess the probability of that hazard causing a major incident
- determine the harm to people, property and the environment that could result from the major incident
- identify the control measures that will eliminate, or reduce the risk as far as reasonably practicable.
The risk assessment must also explain the methods used to make each of the judgments required above, and the reasons for those judgments. To demonstrate that the risks have been eliminated, or reduced to as low as reasonably practicable (ALARP) levels, the operator should consider different options for the reduction of risk and provide justification that the chosen option will achieve the lowest practicable risk level. The operator should also provide justification that further reduction in risk is not practicable. In essence, the operator must define and justify what is ALARP appropriate to the nature and complexity of their facility.
Events with both on-site and off-site impacts need to be considered in the risk assessment. The risk assessment must be prepared in consultation with workers. Appropriate personnel should be identified and consulted at each stage of the facility lifecycle.
Part C: Safety management system
The operator of a major hazard facility should develop, implement and maintain a comprehensive safety management system.
The safety management system is the cornerstone document for the operator of a major hazard facility to demonstrate that all necessary measures have been taken to prevent major incidents, and limit potential consequences for people and the environment. It should address the specific issues of the facility.
The safety report needs to contain an overview of the safety management system, and state where the supporting material is available.
Duty to prepare a safety management system
Regulation 24 requires the operator of a major hazard facility to prepare a safety management system for the facility.
The safety management system:
- records the policies and procedures for implementing and managing the control measures identified in the risk assessment, including the procedures referred to in Schedule 4 of the regulations
- is prepared in consultation with employees (and the Resources Safety case manager) and records the details of the consultation
- is in a form acceptable to the Chief Officer.
Submission and approval of a safety report
Operators of a site classified as an MHF should consider the time required to complete the safety report approval process when submitting the initial MHF notification. This process typically takes 12-18 months. Consultation with Resources Safety at an early stage of the project will facilitate the process.