Regulatory compliance is the first step in the process of controlling and preventing industrial risks. Regulatory compliance is an important factor in improving industrial safety.
However, between regulatory inflation, the complexity of the texts, and the double level of regulation (French and European), regulatory compliance constitutes a real labyrinth for industrialists, in particular with regard to ICPE (Installations Classified for Environmental Protection).
Indeed, industries are regulated, and more particularly ICPEs, according to their activity and their level of danger (type and quantity of products):
- Not classified
- Statement
- Declaration with control
- Registration
- Authorization
- Authorization with easement (SEVESO low threshold/ SEVESO high threshold)
The complexity also results from the need to respect a very precise schedule of deadlines for the implementation of regulatory texts. This application is regularly controlled by the French administration (DREAL) which can, in case of deviation from the regulations, specify corrective measures according to the level of deviation (minor or major non-conformity, formal notice, shutdown) potentially associated with a fine.
This is where Gesip's expertise can be useful to industrialists by offering them support in the regulatory compliance of their installations.
Regulatory Compliance Audit Organization
With 70 years of experience, Gesip is a community of experts working to improve the safety of people and facilities in industry through consulting, auditing and training activities aimed at improving the control of industrial risks.
In this respect, Gesip assists companies in their efforts to bring their facilities into regulatory compliance:
- Regulatory compliance audit and blank audit,
- Advice on new regulations,
- Regulatory watch,
- Preparation for the DREAL inspection,
- Post-inspection follow-up...
Gesip's expertise and neutrality have contributed to building its legitimacy as a reference organization in the field of industrial safety. Strongly involved in numerous working groups alongside industrialists, Gesip regularly contributes to the development of regulatory changes, such as those following the Rouen 2019 accident, and its new requirements concerning the POI (Internal Operation Plan). This process of consultation with the involvement of industrialists allows us to produce texts that are closer to the field.
The regulatory texts are becoming increasingly dense and long without being sufficient in themselves for their application. Thus, Gesip and its associated working groups develop guides that are recognized by the administration. Manufacturers who comply with the guides are presumed to be in conformity with the regulations, while those who do not comply must justify the measures taken to comply with the order.
Also read: Industrial chemical risk training
Regulatory compliance, Gesip's support and expertise
Post-Rouen regulatory compliance, drafting and revision of POI, PSI and emergency plan
Regulatory compliance includes, among other things, compliance with the requirements of regulatory documents, which are operational decision-making tools that can be used internally and by external emergency services in the event of a disaster: POI (Internal Operation Plan), PSI (Safety and Intervention Plan) or emergency plan.
The need to have a POI generally corresponds to changes in the facility's regulatory status or to a tightening of the regulations, such as the one that occurred in 2019 following the Rouen accident. Thus, from now on, all SEVESO low and high threshold facilities must have an operational POI.
The revision of these documents must be done according to the frequencies imposed by the texts, or after requests formulated by the administration following failures, gaps or regulatory deviations noted during a review or an exercise.
Gesip assists newly submitted operators in the development of their POI (SEVESO Seuil Bas and new entrants of the modified ministerial decree of October 3, 2010) and offers its assistance to industrialists for the revision of their POI by relying on one of the four POI guides that have become industry references according to the type of installation concerned:
- Guide 96/01 - The development of the POI of a large industrial site ,
- Guide 96/02 - Developing a Small Site POI,
- Guide 2016/01 - Developing an LPG Storage Facility IOP
- Guide 2007/01 - Methodology for the realization of a PSI on a transport pipeline.
Gesip guides industrialists to appropriate and respect the new regulatory requirements. The POI is, in fact, an example of the difficulties encountered by industrialists for Post-Rouen compliance.
In order to ensure the effectiveness of the internal operation plan, the regulations require at least an annual exercise conducted jointly with the public emergency services and in the presence of the DREAL, for SEVESO High Threshold facilities, and POI exercises are now mandatory every three years at other sites where an POI is prescribed.
Gesip offers its expertise to industrialists for the organization and follow-up of these POI exercises with the development of scenarios and a presence on site.
Gesip can also assist them during ICPE inspections.
Also read: Safety of chemical industrial sites: risks and regulations
Realization of SGS (Security Management System) audit
By AM of May 26, 2014, regulations require operators of AS establishments (Authorization with Public Utility Servitudes under ICPE regulations) to implement a Safety Management System (SMS) proportionate to the major accident risks likely to be generated by the substances present in their facilities.
Due to the comprehensive and complex nature of a SMS, audits must be specific, and can be performed by Gesip's SMS experts.
The industry's SMS must, by regulation, include seven chapters:
- Organization, training
- Identification and assessment of risks related to major accidents
- Process control, operation control
- Design and change management
- Emergency management
- Performance monitoring
- Audits and management reviews
Gesip verifies the SMS chapter by chapter to ensure their existence, application and effectiveness. Gesip provides the industrialist with a gap analysis with the regulatory requirements and proposes its recommendations for improvement.
Gesip can also act as an independent expert at the request of the Industrialist and the Administration within the framework of a prescription resulting from a complementary prefectoral decree (independent expertise or third party expertise).
Training on new regulations
Believing that risk control and management depend on the pooling of knowledge and the sharing of experience, Gesip offers a range of training courses dedicated to industrial and logistics sites.
As an example, the Gesip training course for the management of a disaster on hazardous product transportation pipelines (GS CANA) teaches the organization and implementation of a Safety and Response Plan (SRP). It complies with article L6313-1 as an action to acquire, maintain or improve knowledge.
Gesip also provides numerous training courses related to the POI or the hazard study.
Attentive to the needs of changing regulations, Gesip organizes occasional Matinales, short, targeted training sessions that encourage exchanges between participants (for example, Gesip Matinale dedicated to the Multi Fluid Order (AMF) and its various regulatory obligations).
For more information, please contact gesip-technique@gesip.com