Version no:

5

OG status:

Fully Open

Author section:

CI4

Issue date:

01 February 2012

Review date:

01 February 2013

Target audience:

HID CI

Purpose

This amended SPC updates SPC/Permissioning/08 and supplements the section of HID CI, SI Inspection Manual on the Lead Unit System for Multi-Establishment Companies, pending revision of that manual as part of the CRM program. The principles set out here will be carried forwards into the revised manual. 

Background

 The Chemical Industries Division Management Meeting (CIMM) agree that the full Level 1 Lead Unit System remains appropriate but, because of its resource implications, must be limited to a small number of companies. These are listed in Annex A.
There are other companies where there are advantages, both for HID and the company, of a coordinated approach to regulation. These companies are listed in Annex B. CIMM is mindful to allow inspector's flexibility of approach to these companies. The degree of coordination adopted may range from networking or copying letters and reports to other Inspectors (Level 2 Lead Unit System, as defined in the HID Inspection Manual), to an approach close to Level 1 Lead Unit System in a few appropriate cases.

Organisations considered for inclusion in Annex A or B met the following criteria:

• had at least one site subject to COMAH (lower or top tier); and
• had at least 5 sites, with sites in more than one CI unit; and
• had a recognised central management structure with common approaches between sites

However, there are many other multi-site establishments and Inspectors are encouraged to liaise with colleagues to enhance our impact at all such establishments.

Role and responsibilities of inspectors responsible for level 1 lead unit system companies (Annex A)

The Inspector responsible for coordinating the approach to a Level 1 Lead Unit System company subject to COMAH Top Tier requirements should exercise oversight of safety report assessment work. In particular the coordinating Inspector should ensure that where an 'exemplar' approach has been taken, or a report from one establishment has been assessed, elements common to that report are not reassessed at other establishments. It is important both for the company and the competent authority that duplication is avoided. Any conflict should be referred to the unit Band 1 for resolution.

Coordinating Inspectors for Level 1 Lead Unit System companies should develop the intervention strategy based on intelligence provided by colleagues and should include all establishments and sites, whether or not subject to COMAH. The strategy should include three-year inspection plans for Top Tier establishments which should ensure that unnecessary duplication of inspection is avoided. However the inspection plan should not limit other Inspectors ability to pursue site-specific issues if that is deemed appropriate, or if there are matters of evident concern. However it is envisaged that the coordinated inspection activity will account for the majority of work carried out with a Level 1 Lead Unit System company in any year.

To enable the Lead Unit System to work, the Lead Unit System coordinating Inspector should prepare a suitable communications strategy, in discussion with their Band 1, to enable Inspectors, technical specialists and other members of the competent authority (EA and SEPA), to contribute to the intervention strategy. The method of communication will vary between Lead Unit System companies and may involve face-to-face meetings or merely exchange of correspondence. Inspectors who have a coordinating role are responsible for reporting back as appropriate to all colleagues who are involved with relevant companies.

The coordinating Inspector should discuss the inspection strategy, in general, with the Level 1 Lead Unit System company including an approximate estimate for cost recoverable time.  Matters of disagreement should be referred to the unit Band 1s.

Band 2's have responsibility for ensuring that resources are available and support is provided to the Band 3 to enable lead unit work to be undertaken. Specifically they are responsible for meetings with senior managers within Level 1 Lead Unit System companies or arranging, in appropriate cases, for Band 1 or Band 0 involvement. Band 2 should monitor Lead Unit activity within their command and report back to Band 1 that the work is being carried out.

Unit Band 1's are responsible for delivery of the Lead Unit System programme. They should ensure adequate resources are provided to support the inspection strategy. Unit Band 1's should ensure that review meetings with Level 1 Lead Unit System companies are carried out and would usually attend these review meetings. The Band 1 should identify particular Lead Unit System companies where it is appropriate for Band 0 or Head of Directorate to be involved in the review meetings with the most senior managers/main Board Members. This should be clearly identified on the review plan.

Band 1s should report to other CID Band 1s (through the CIMM) so that the progression of the full Lead Unit System initiatives can be monitored.

Role and responsibilities of inspectors responsible for other lead unit system companies (Annex B)

The less highly developed arrangements applicable to the companies in Annex B should be defined by the lead team after liaison with representatives of the other participant regulatory teams, taking into account the nature of the organisation. The arrangements may be no more than effective UK wide networking between regulators (Level 2 Lead Unit System) or may be more complex. In appropriate cases they may approach the complexity of Level 1 engagement.

Whether this work is lead at B2 or B3 should be determined by the Lead team B2's who should support this work and should report developments to Units B1 to enable wider sharing of appropriate information with other CID Band 1s (thorough CIMM).

Inspector training

To facilitate this work Inspectors may need to be competent in the following areas:

• enhanced communication skills for approaches to Lead Unit System senior management (main board level equivalents);
• recognising company structures and how organisations function and operate globally;
• what makes organisations tick;
• understanding financial processes and their impact on large organisations and to appreciate how this knowledge can be used to influence health and safety considerations.

These topics are covered by in house training courses. (See L&D Intranet site for details)

Annex A: Companies subject to the full lead unit approach

Annex B: Companies subject to other types of lead unit approach

Other informal liaison arrangements exist for:

Alcan, Aerosol Products / Robert McBride, Sabic and Terra.