The internal operation plan

The post-accident context in Rouen led to changes in regulations to learn the lessons of this event in order to improve the safety of high-risk industrial sites and maintain a high level of prevention. These texts significantly reinforce the obligations concerning the POI (internal operation plan) of SEVESO sites, as well as the requirements concerning the prevention of fire risks and the limitation of their consequences, in the storage of flammable and combustible liquids and in warehouses.

In addition to the SEVESO High Threshold facilities, new establishments are now required to draw up an IOP, namely SEVESO Low Threshold facilities, as of January 1, 2023 (amended order of 26/05/2014).

What is a POI? 

Definition of the POI

The Internal Operation Plan, known as the POI, is an operational operational tool for prevention, control and decision support for crisis management. This emergency plan aims to organize the response to accidental situations at industrial sites subject to the obligation.

The POI meets a regulatory obligation for SEVESO establishments in order to prevent, organize an effective fight and limit the consequences of an incident (fire, explosion, spill, etc.) in order to ensure the protection of the population and the environment.

This document should aim at efficiency objective. Therefore, it must be concise, operational and known by all actors.

Also read: What is a POI (Plan d'Opération Interne) and what does it include?

Who are the actors of the POI? 

The actors of the POI within the establishment concerned

The heads of SEVESO establishments facility managers are responsible for drawing up and implementing an IOP. The drafting of a POI is facilitated by the Gesip technical guides which provide detailed outlines of the essential chapters.

All persons involved in the involved in the implementation of the IOP, must be be trainedWhether they are a professional firefighter or an employee. Some installations subject to an IOP are autonomous installations, i.e. they have the capacity to manage the disaster without the intervention of the public emergency services.

The external actors of the POI

The public emergency services as well as the government services (Inspection of classified facilities, DREAL, Prefecture, police services) are involved in the implementation of the internal operation plan. They are aware of it because of the obligation for industrialists to communicate the IOP to them.

In addition, if the effects of the accident go beyond or are likely to go beyond the limits of the industrial site the POI becomes a PPI (Particular Intervention Plan) at the request of the plant manager. The prefect is then responsible for managing the disaster.

The residentsThe local residents, companies or infrastructures are also included in the IOP. They can be affected by the effects of a disaster, to a greater or lesser extent.

The different types of organization of a POI

Gesip provides manufacturers with three technical guides depending on the size of the site, the available fire fighting resources, the kinetics and the extent of the incident:

• small sites (dedicated) ;
• large sites (typically a refinery with a large number of activities that require adapted reflex cards);
• gas sites (specific provisions).

The objective of the Gesip guides is to provide companies with an operational tool to help for the elaboration of intervention tactics as well as their implementation. They deal with all the fields related to crisis management and provide the operator with reflex cards, allowing them to combine reactivity and efficiency.

These guides ensure that operators have an IOP that complies with with regulatory requirements.

What does the POI contain? What is its classic structure? 

The internal operation plan must define the organizational organizational measures, methods of intervention, and the necessary resourcesThe internal operation plan must define the organizational measures, the response methods and the necessary resources, both internal and external, to be implemented within the establishment, in the event of an accident, in order to control it, protect personnel and property and avoid the effects on the population and the environment.

A Hazard Assessment (SA) must be carried out upstream of the POI and will serve as the basis for its development. An industrial site is, by its very nature, subject to numerous risks, the origin of which may be linked to the operation, the environment, etc. The accident scenarios to be considered may therefore be numerous.

The exhaustive analysis of the risks, carried out in the Study of Hazards, is essential and serves as a basis for the definition of the means and protective measures described in the POI. 

Also read: How to train for the implementation of the IOP?

Presentation of the establishment 

The first part of the internal operation plan must include a description of the activity and the location, including the identification of assembly points and the description of the means as well as the characteristics of the equipment.

Alert 

The procedures for raising the alarm and calling the emergency services must be included in the POI: 

• Decision support for the triggering of the POI and the setting up of the crisis unit;
• Alert schemes in order to warn all the actors (firemen, prefect, administration, DREAL, police, local organizations, etc.) and typical warning messages (internal and external);
• Emergency organization with presentation of the organization, the means of fighting as well as the function sheets of the internal interveners during the launching of the POI.

Protecting and intervening

The POI relies on the vigilance and expertise of the industrialist when drawing up the scenario sheets. The hazard study or studies are the reference documents in the phase of identifying accident scenarios.

The selection of reference scenarios is based on the probability of occurrence of these events, as well as on their potential severity or the particular nature of certain accidents (toxic or pollution scenarios, for example).  

The scenarios are then summarized in operational sheets with a description of the means of control used and actions to be implemented associated with target sheets.

Tool Sheets

Many of the POI tools are available to the command post, known as the operator's PC or PCEx, in order to to resolve the crisis situation as best as possible. Some tools are developed well in advance, others are built as the disaster management process progresses.

• The SITAC (Situation TACtique) allows to follow graphically and with the help of field feedback the current situation to allow the PCEx to determine the actions to be implemented. It is a central tool for exchanges with the public emergency services.
• The SAOIELC is the non-visual counterpart of the SITAC. This document helps to structure the thinking around the management of the event. It is broken down as follows: 
  • Situation: Description of the initial situation 
  • Anticipation: Possible evolution of the disaster
  • Objective: Goals to be achieved 
  • Idea of maneuver: Techniques considered to achieve the objective 
  • Execution: Distribution of tasks, sectorization
  • Logistics: Logistical means required: lighting, emulsifier, etc.
  • Command: Transmission, position of the COS (Emergency Operations Commander), COS deputy, individual and collective safety measures
• The Power Escalation Curve (CMP) is elaborated beforehand to describe graphically and precisely the means necessary to control a fire in less than three hours.
• The Asset Management Curve (CGM) is an organizational tool built in real time to monitor available resources such as the quantity of emulsifiers remaining, for example.
• Other documents: Sample press release, Attendance sheets, Tank draining speed, etc. 

When should the POI be revised? 

The revision of the POI is required every 3 years. More regular revisions may be necessary for the administrative review of the different actors or to take into account regulatory changes.

For example, the POI should include:

• as of January 1, 2022, the means and methods provided for environmental remediation and cleanup.
• as of January 1, 2023, provisions for conducting the first environmental first environmental sampling (relevant substances, sampling equipment, authorized personnel or organizations) concerning toxic substances and the types of decomposition products likely to be released in the event of a major fire.

A better knowledge of thestate of stored materials is also part of the feedback, in order to better anticipate and control the consequences of industrial accidents. This status must now be included in the IOP.

POI exercises and training - How can teams make this document their own?

For the installations SEVESO Seuil Hautthe regulations require at least an annual exercise conducted jointly with the public emergency services and in the presence of the administration (DREAL).

The POI exercises become mandatory every 3 years in the other sites where an IOP is prescribed.

To ensure the effectiveness of the internal operation plan, regular regular POI exercises must be carried out with simulations of the different scenarios for the teams. The repetitiveness of the exercises is a key element of the control of the POI.

The exercises must be aimed at putting the POI into practice both in the field and for the PCEx. They give rise to an analysis and a report that highlights both the positive points and the dysfunctions in order to suggest proposals for improvement. 

In order to ensure the effective implementation of the POI, operators regularly attend training sessions, some of which are provided by Gesip. 

Also read: The POI and its tools

How does Gesip support operators who are newly subject to a POI (SEVESO Seuil Bas and new entrants to the modified ministerial order of October 3, 2010)? 

Gesip offers its expertise in the following fields

• Creation / Development / Review of your POI 
• Support for the development and updating, validation
• Organization / Observation of a POI exercise (annual and night exercise) 
• Assistance to ICPE Inspections 
• Training of your teams in emergency response.

With its audit and consulting missionsGesip offers in-depth and comprehensive support to operators subject to POI.

In this respect, Gesip makes its knowledge available to industrialists through its technical guidestechnical guides, technical and practical documents with high added value, detailed above.

Gesip also organizes training in the application of the POI on industrial installations as well as training on real fires in its two technical platforms, unique in Europe. The added value of Gesip's training courses lies in this essentially practical approach based on the sharing of experience and knowledge.

The latest news about the training actions of the Gesip community is a Webinar proposed on June 9th on the following subject: What regulatory changes for the storage of flammable liquids in fixed tanks?