MechChem Africa

The Major Hazard Installation Regulations are being amended and are set for promulgation in 2018 at the earliest. Motlatsi Mabaso, CEng, MIChemE, Director: MMRisk, a process safety and risk consultancy, spells out the changes.

Motlatsi Mabaso MMRiskA Major Hazard Installation (MHI) facility may be defined as an industrial facility that manufactures and/or stores relatively large quantities of chemical materials, which, if they were to lose containment, would result in effects that could cause harm to personnel and members of the public near the facility. Effects may include major fires, explosions and release of toxic materials that disperse over a distance. Quantity of storage and location of onsite facilities relative to the site fence are the main considerations for MHI facilities, as these have an influence on the effects of loss of containment on members of the public around the facility.

By South African law, governed by the Department of Labour and part of the Occupational Health and Safety Act No. 85 of 1993, every MHI or suspected MHI is required to undertake what is known as an MHI Risk Assessment, which is a Quantified Risk Assessment (QRA) of the facility that considers the potential effects in the case of loss of containment as well as the likelihood of its occurrence.

MHI Risk Assessments are undertaken by Approved Inspection Authorities (AIAs), which are vetted by the South African National Accreditation System (SANAS). The final risk results, which combine effects and likelihood of occurrence, can be compared against internationally recognised thresholds to determine tolerability for the site under review. The MHI Risk Assessments are required to be updated five-yearly.

At present, a number of stakeholders in the South African MHI industry have difficulty in interpreting and applying the current MHI Regulations. These include confusion around the quantities and types of facilities that qualify for exemption (if any); the definition of ‘Impact on the Public’; interpretation of the regulations by the various AIAs; and the meaning of some of the vague phrases within the regulations. Ultimately, the final interpretation and decision-making should be made by the national Department of Labour with assistance from the AIAs as required. Such uncertainty is not good in an important industry whose aim is protecting members of the public from the effects of industrial accidents.

However, a change is coming – the MHI Regulations are in the process of being overhauled with a new set of regulations due to come out in the next 12 months (in the best case). There is also a new South African National Standard (SANS-1461) for the compilation of MHI Assessments being compiled through the South African Bureau of Standards (SABS), as well as a new standard to for Emergency Preparedness for Major Hazard Installations (SANS-1514).

On 27 October 2017, the Department of Labour’s (DoL) Explosives and Major Hazard Installations Directorate hosted a workshop to introduce and sensitise industry (operators of MHI facilities) and other stakeholders to the upcoming regulations. On the same day, a story broke about a massive explosion at a fireworks factory in Indonesia leading to a fire that brought down the entire roof of the factory. The incident left 47 people dead, 46 injured and ten initially unaccounted for. There was no more fitting story than that to use as a ‘safety moment’ at the workshop.

The session began with addresses by officers of the DoL, including Ms Iggy Moiloa, Inspector General and Rachel Aphane, Deputy Director of Major Hazard Installations. Aphane took us through the history of the MHI regulations, comparing the old with the new regulations in both technical and procedural aspects. She described how, in future, terminology will change slightly: an ‘installation’ shall refer to a process unit or piece of equipment on-site, while the entire site itself will now be referred to as an ‘establishment’ and it may comprise several installations. Other notable definitions included were:

• Dutyholder: simply put, this is the organisation that operates an MHE;
• Licence to Operate (LtO): Official approval/ consent to operate, based on satisfaction that the Dutyholder has identified and understood all operational requirements to protect the public and workers.

A new approach: low, medium and high hazard establishments

The main changes in these new regulations are the introduction of Hazard Levels and...

Click to download and read pdf.

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