Enforcement of Seveso II : an analysis of compliance drivers and barriers in five industrial sectors : key points and conclusions

This report describes the outcome of a workshop (the Mutual Joint Visit for Seveso Inspections) hosted by the Ministry of Social Affairs and Employment of the Netherlands in November 2006 on "enforcement in Seveso II enterprises" in particular, a subject that has never been dealt with at EU level before. The "Table of Eleven" was used as model in order to facilitate and encourage discussion. The Table of Eleven is a model based on behavioural sciences consisting of eleven dimensions, or factors, which are decisive for the level of compliance with legislation. The use of the Table of Eleven requires the definition of and focus on "target groups" and "rules''. Five specific target groups were selected: Mineral oil refineries, the pharmaceutical industry, fertilizer production, chemical batch processing, and LPG storage. Five specific rules were selected: 1) "The requirement of submitting a notification" (ref. Article 6 sub 1); 2) "Major accident scenarios" (ref. Article 9 and Annex II sub IVa); 3) "Assessment of the extent and severity of consequences" (ref. Article 9 and Annex II sub IVb); 4) "The identification of training needs" (ref. Article 7, 9 and Annex III sub c.i); and 5) "Procedures for management of change" (ref. Article 7, 9 and Annex III sub c.iv). The workshops discussions produced several interesting and useful conclusions concerning the enforceability of the Seveso Directive in general, and differences in compliance drivers in different sectors and across the Member States. On the basis of these conclusions, several recommendations were generated for European, national and inspectorate level regarding the improvement of enforcement strategies, tools and the results of the analyses performed in this workshop overall and by industry sector and by rule.