Εξαιρετικό άρθρο από την Financial Mirror
05 August, 2011 | Posted By: Alan Waring
The Risk Watch Column
By Dr Alan Waring
In the previous two Risk Watch articles in the Financial Mirror (‘A Gamble that Cost Lives’ and ‘Mari-Vassilikos Disaster: More Troubling Questions’), I outlined a number of key principles applicable to major hazard sites as well as the requirements of the EU Major Hazards Directive (the ‘Seveso II Directive’) and asked whether the official inquiries into the disaster are up to the task. In this article, I probe further and consider specifically the Electricity Authority of Cyprus (EAC), the operators of the Vassiliko power station site.
Confusion and Clarification
At present, for any kind of understanding of the disaster the public has to rely on statements from a range of politicians and officials as quoted and paraphrased by journalists and editors. We wait, perhaps naively, for the two official inquiries to report so as to get a more accurate and complete picture but, according to a straw poll I conducted in various kafenios and tavernas, a ‘whitewash’ is widely predicted, accompanied by ‘etzi ine stin Kypro’ and a shrug of the shoulders.
There are some grounds for such cynicism when one hears via the media where the focus of the various investigations seems to be, not to mention the credentials of the Polyviou inquiry in particular. For example, the Cyprus Mail reports that the government’s joint Health and Environment Committees have discussed at length the European Commission Seveso II Directive 96/82/EC in terms of whether or not it ‘should have been implemented on the day of the blast’. The article then tells us that the Directive ‘aims to improve coordination between different authorities, reduce bureaucracy and improve information provided to the public and relevant authorities’. This is not the Directive’s main aim.
Unfortunately, this focus on ‘who did what on the day’ and ‘who failed to coordinate with whom’ gives only a partial and very misleading impression, as it omits the main thrust of the Major Hazards Directive which is firstly to prevent major accidents occurring and secondly limit their impact. As outlined in the previous Risk Watch, the Directive, Article 7, requires designated site operators to have a Major Accident Prevention Policy ‘designed to guarantee a high level of protection for man and the environment’, an associated Safety Management System, a detailed Safety Report (Article 9) on the effectiveness of the MAPP and SMS, systematic major hazards risk assessment and so on.
All the reported focus of the joint Committees has been on whether the Fire Services responded correctly. Already, Fire Services personnel have been suspended, implying they are culpable. The article also reports that a Fire Services official told the joint Committees that the Fire Services did not need to implement the Directive because the risk of chemical leakage was limited and could be handled within hours. Whether true or false, this dubious assertion has no bearing on the EAC’s own obligation as the Vassiliko site operator to implement the Directive. It is a red herring, as the EAC had the primary duty to comply in relation to its own site.
So, focusing on implementation of the Directive just on the day of the blast fails to address all the prior compliance by EAC that was required to ensure (the Directive demands a ‘guarantee’) that this disaster would never occur. Whatever the responsibility of the Defence Ministry in respect of the munitions explosion at adjacent Mari, EAC still had a separate compliance obligation for its own site. We are told that the Vassiliko site still holds some 135,000 tonnes of diesel and fuel oil. These are far in excess of the threshold inventories for such substances in Annex 1 of the Directive and therefore strongly suggest that when the plant was being designed and built in stages over the period 2001-2009 the Directive should have been complied with in full by the Electricity Authority of Cyprus, including the land planning and site location requirements, proximity to habitation and to other sites (especially other major hazards etc) needed to prevent a domino effect (Article 8). Let’s remember that it was mostly by luck that the EAC fuel storage tanks did not blow up when the blast from Mari hit the site.
Produce the Evidence
Rather like ‘the dog that didn’t bark’ in Sherlock Holmes, the silence from EAC on their compliance with the Directive has been deafening. One would have expected them to be telling all and sundry about how good their MAPP was, and how well their SMS and emergency plans (offsite and onsite) had functioned. Could the silence be explained if EAC in fact had none of these vital elements?
Vital questions for EAC to answer therefore include:
• Who at the EAC approved the siting and go-ahead for the Vassiliko plant?
• Was the Seveso Directive fully complied with by EAC, and if not why not?
• Who at EAC was responsible for compliance during the various stages of its life cycle, (design, construction, handover, operation, modifications/extensions etc)?
• What steps did EAC take to address the major hazards interactions and potential domino effect vis-à-vis the Mari Naval Base?
• When did EAC suitably inform the public, and especially residents and businesses in surrounding villages, of its protective provisions at Vassiliko?
• Has the EAC provided to the police and the Polyviou official inquiries copies of the site MAPP, Safety Management System, detailed Safety Report, major hazards risk evaluation, and its internal and external emergency plans, and if not why not?
• If Vassiliko is to be rebuilt on the same site, how will EAC ensure compliance with the Seveso Directive?
In addition to Vassiliko, EAC operates a number of other power stations and the stored fuel inventories at each are likely to bring them within the scope of the Seveso Directive. Can the EAC produce conclusive evidence to assure the public that it has fully complied with the Directive at each of these sites?
Moreover, on top of human and environmental safety as demanded by the EU Directive, as a strategic utility provider EAC has a further (governance) obligation to protect its operations, its shareholders, its customers and the economy from unnecessary loss and damage. Therefore, to meet ISO 31000 requirements and the forthcoming EU Directive on Corporate Governance, EAC should have had a comprehensive and robust risk management system for all its sites, addressing prevention as well as emergencies and crises and covering all manner of threats and major accident scenarios.
Conclusion
During my career, I have participated in various investigations and studies for and/or in response to official inquiries into man-made disasters, including the Morton Inquiry into the Safety of Natural Gas, the Fennell Inquiry into the Kings Cross London Underground Fire, the Sea Empress Oil Tanker Disaster Inquiry and the Piper Alpha Disaster Inquiry. All of these inquiries shared some golden attributes, such as independence from political or other interference; a strong, impartial and experienced chairman; relevant multi-disciplinary technical expertise on the inquiry committee and support team; and a determination to get to the whole truth. This enabled those inquiries to deliver comprehensive reports and recommendations that avoided the ‘shooting at the mice and missing the elephants’ problem from which unfortunately the Mari-Vassiliko inquiries appear to suffer. Red herrings and scapegoats will do a great injustice, not only to the victims and their families but also to the Cypriot people as a whole. The Polyviou inquiry, for example, should have been held in public to ensure transparency.
I wait to see whether any of the questions I have raised will be asked by the inquiry, what answers and supporting evidence were received and what the inquiry’s analysis, conclusions and recommendations are. Ever the optimist, I await a positive outcome.
Dr Alan Waring is an international risk management consultant with extensive experience in Europe, Asia and the Middle East with industrial, commercial and governmental clients. Contact info@dralanwaring-riskconsultants.com .
©2011 Alan Waring
By Dr Alan Waring
In the previous two Risk Watch articles in the Financial Mirror (‘A Gamble that Cost Lives’ and ‘Mari-Vassilikos Disaster: More Troubling Questions’), I outlined a number of key principles applicable to major hazard sites as well as the requirements of the EU Major Hazards Directive (the ‘Seveso II Directive’) and asked whether the official inquiries into the disaster are up to the task. In this article, I probe further and consider specifically the Electricity Authority of Cyprus (EAC), the operators of the Vassiliko power station site.
Confusion and Clarification
At present, for any kind of understanding of the disaster the public has to rely on statements from a range of politicians and officials as quoted and paraphrased by journalists and editors. We wait, perhaps naively, for the two official inquiries to report so as to get a more accurate and complete picture but, according to a straw poll I conducted in various kafenios and tavernas, a ‘whitewash’ is widely predicted, accompanied by ‘etzi ine stin Kypro’ and a shrug of the shoulders.
There are some grounds for such cynicism when one hears via the media where the focus of the various investigations seems to be, not to mention the credentials of the Polyviou inquiry in particular. For example, the Cyprus Mail reports that the government’s joint Health and Environment Committees have discussed at length the European Commission Seveso II Directive 96/82/EC in terms of whether or not it ‘should have been implemented on the day of the blast’. The article then tells us that the Directive ‘aims to improve coordination between different authorities, reduce bureaucracy and improve information provided to the public and relevant authorities’. This is not the Directive’s main aim.
Unfortunately, this focus on ‘who did what on the day’ and ‘who failed to coordinate with whom’ gives only a partial and very misleading impression, as it omits the main thrust of the Major Hazards Directive which is firstly to prevent major accidents occurring and secondly limit their impact. As outlined in the previous Risk Watch, the Directive, Article 7, requires designated site operators to have a Major Accident Prevention Policy ‘designed to guarantee a high level of protection for man and the environment’, an associated Safety Management System, a detailed Safety Report (Article 9) on the effectiveness of the MAPP and SMS, systematic major hazards risk assessment and so on.
All the reported focus of the joint Committees has been on whether the Fire Services responded correctly. Already, Fire Services personnel have been suspended, implying they are culpable. The article also reports that a Fire Services official told the joint Committees that the Fire Services did not need to implement the Directive because the risk of chemical leakage was limited and could be handled within hours. Whether true or false, this dubious assertion has no bearing on the EAC’s own obligation as the Vassiliko site operator to implement the Directive. It is a red herring, as the EAC had the primary duty to comply in relation to its own site.
So, focusing on implementation of the Directive just on the day of the blast fails to address all the prior compliance by EAC that was required to ensure (the Directive demands a ‘guarantee’) that this disaster would never occur. Whatever the responsibility of the Defence Ministry in respect of the munitions explosion at adjacent Mari, EAC still had a separate compliance obligation for its own site. We are told that the Vassiliko site still holds some 135,000 tonnes of diesel and fuel oil. These are far in excess of the threshold inventories for such substances in Annex 1 of the Directive and therefore strongly suggest that when the plant was being designed and built in stages over the period 2001-2009 the Directive should have been complied with in full by the Electricity Authority of Cyprus, including the land planning and site location requirements, proximity to habitation and to other sites (especially other major hazards etc) needed to prevent a domino effect (Article 8). Let’s remember that it was mostly by luck that the EAC fuel storage tanks did not blow up when the blast from Mari hit the site.
Produce the Evidence
Rather like ‘the dog that didn’t bark’ in Sherlock Holmes, the silence from EAC on their compliance with the Directive has been deafening. One would have expected them to be telling all and sundry about how good their MAPP was, and how well their SMS and emergency plans (offsite and onsite) had functioned. Could the silence be explained if EAC in fact had none of these vital elements?
Vital questions for EAC to answer therefore include:
• Who at the EAC approved the siting and go-ahead for the Vassiliko plant?
• Was the Seveso Directive fully complied with by EAC, and if not why not?
• Who at EAC was responsible for compliance during the various stages of its life cycle, (design, construction, handover, operation, modifications/extensions etc)?
• What steps did EAC take to address the major hazards interactions and potential domino effect vis-à-vis the Mari Naval Base?
• When did EAC suitably inform the public, and especially residents and businesses in surrounding villages, of its protective provisions at Vassiliko?
• Has the EAC provided to the police and the Polyviou official inquiries copies of the site MAPP, Safety Management System, detailed Safety Report, major hazards risk evaluation, and its internal and external emergency plans, and if not why not?
• If Vassiliko is to be rebuilt on the same site, how will EAC ensure compliance with the Seveso Directive?
In addition to Vassiliko, EAC operates a number of other power stations and the stored fuel inventories at each are likely to bring them within the scope of the Seveso Directive. Can the EAC produce conclusive evidence to assure the public that it has fully complied with the Directive at each of these sites?
Moreover, on top of human and environmental safety as demanded by the EU Directive, as a strategic utility provider EAC has a further (governance) obligation to protect its operations, its shareholders, its customers and the economy from unnecessary loss and damage. Therefore, to meet ISO 31000 requirements and the forthcoming EU Directive on Corporate Governance, EAC should have had a comprehensive and robust risk management system for all its sites, addressing prevention as well as emergencies and crises and covering all manner of threats and major accident scenarios.
Conclusion
During my career, I have participated in various investigations and studies for and/or in response to official inquiries into man-made disasters, including the Morton Inquiry into the Safety of Natural Gas, the Fennell Inquiry into the Kings Cross London Underground Fire, the Sea Empress Oil Tanker Disaster Inquiry and the Piper Alpha Disaster Inquiry. All of these inquiries shared some golden attributes, such as independence from political or other interference; a strong, impartial and experienced chairman; relevant multi-disciplinary technical expertise on the inquiry committee and support team; and a determination to get to the whole truth. This enabled those inquiries to deliver comprehensive reports and recommendations that avoided the ‘shooting at the mice and missing the elephants’ problem from which unfortunately the Mari-Vassiliko inquiries appear to suffer. Red herrings and scapegoats will do a great injustice, not only to the victims and their families but also to the Cypriot people as a whole. The Polyviou inquiry, for example, should have been held in public to ensure transparency.
I wait to see whether any of the questions I have raised will be asked by the inquiry, what answers and supporting evidence were received and what the inquiry’s analysis, conclusions and recommendations are. Ever the optimist, I await a positive outcome.
Dr Alan Waring is an international risk management consultant with extensive experience in Europe, Asia and the Middle East with industrial, commercial and governmental clients. Contact info@dralanwaring-riskconsultants.com .
©2011 Alan Waring
Σχόλια