Hazardous incident officers: avoid hazardous situations before they occur

Comprehensive and regularly monitored safety measures are a top priority in the process plants of, for example, chemical-pharmaceutical and metalworking companies or energy companies. Human error, undetected material fatigue or undesirable chemical reactions - there are many reasons why an incident could occur in a plant.

If operators have not carried out an appropriate assessment in advance, a simple operating error may be enough to release a large quantity of hazardous substances, endangering the health of employees and residents or risking human lives through fire and explosions, for example.

It is therefore important to take preventative safety measures to avoid emergencies as effectively as possible.

In the Federal Immission Control Act (BImSchG) and the 12th BImSchV (Hazardous Incident Ordinance, StörfallV), among other things, the legislator defines the framework conditions that operators of facilities in which hazardous substances are present must take to prevent incidents and limit damage.

Operators of upper-tier installations subject to licensing are required by law to appoint one or more hazardous incident officers if the quantities of hazardous substances in an operating area reach or exceed the quantity thresholds specified in the 12th BImSchV.

Section 58 a (1) of the BImSchG stipulates that operators of upper-tier establishments must appoint one or more hazardous incident officers in order to minimize risks when handling hazardous substances and, in the event of serious accidents, to keep the potential hazards for employees, the neighbourhood and the general public as low as possible. If necessary, the appointment of hazardous incident officers can be ordered by the authorities.

Other important guidelines for the safe operation of process plants are

• Major Accidents Ordinance (StörfallV),
• Ordinance on installations subject to licensing (4th BImSchV),
• Ordinance on immission control and hazardous incident officers (5th BImSchV).

Regulations on risk assessment for the process plant and explosion protection are also relevant for the hazardous incident officer:

• Ordinance on Industrial Safety and Health (BetrSichV),
• Ordinance on Hazardous Substances (GefStoffV).

What are the tasks of hazardous incident officers?

In general, hazardous incident officers work towards improving plant safety. According to BImSchG § 58 b, this includes the following activities:

• Monitoring compliance with the regulations of the BImSchG, the 12th BImSchV and other requirements,
• Regular inspection of operational facilities,
• Reporting on any deficiencies identified and drawing up proposals for rectification,
• Informing the operator about malfunctions that endanger the general public or the neighborhood,
• Annual reporting to the operator.

In return, the plant operator is obliged under BImSchG § 58 c to obtain an opinion from the hazardous incident officer in good time before making investment decisions, planning operating facilities or introducing work processes and working materials.

The so-called right of presentation also ensures that the hazardous incident officers can report deficiencies, concerns or suggestions directly to the management at any time and without delay.

As a rule, the hazardous incident officer works closely with immission control officers and safety specialists. If proper fulfillment of the tasks is ensured, one and the same person can also assume the function of the hazardous incident officers and the immission control officer.

Which companies need a hazardous incident officer?

Section 1 (2) of the 5th BImSchV summarizes when a hazardous incident officer must be appointed: Companies must appoint hazardous incident officers if hazardous substances are present in an operating area whose quantities reach or exceed the thresholds defined in the 12th BImSchV, Annex 1.

In individual cases, the authority may also order the appointment of a hazardous incident officer if the quantity thresholds for the hazardous substances present are not reached.

The work of a hazardous incident officer is often not a full-time job, particularly in small and medium-sized companies. In this case, a single person often has to take care of several areas, from immission control and water protection to occupational safety, and is therefore unable to fully perform any one task. This is where it pays to call in expert external support. With experienced external hazardous incident officers, you save costs and can concentrate on your core business in peace.

Hazardous incident officers need special expertise and time for their task

The tasks of the hazardous incident officer cannot be performed alongside a main activity and require full attention. Not all employees are equally qualified for the role of hazardous incident officer. § Section 7 of the 5th BImSchV specifies the technical requirements that hazardous incident officers must fulfill:

• Completed university degree in engineering, chemistry or physics,
• Participation in officially recognized training courses in which the specialist knowledge of a hazardous incident officer required in Annex II of the 5th BImSchV is taught,
• Two years' knowledge of comparable plant types from practical experience.

In accordance with Article 10 of the 5th BImSchV, hazardous incident officers must also have the necessary reliability and personal qualities to carry out their duties.

In order to provide comprehensive safety-related support for the plants, it is also necessary to keep the hazard assessments for the process plants (HAZOP) and other safety-related documentation up to date on a regular basis. In order to be able to take on this task for the operator, the hazardous incident officer must also be given the necessary time.

Why you should entrust the tasks of hazardous incident officers to Infraserv Höchst's experienced experts

• Meet all regulatory requirements for plant operation: Specifications for the state of safety technology and regulations that must be observed are updated regularly. It is often difficult for plant operators and company employees to keep up with all the latest developments. Infraserv Höchst specialists always know the latest versions of all relevant regulations.
• Free up your own human resources: The job of an hazardous incident officer requires extensive expertise and regular training. The larger your facility, the more complex and extensive the hazardous incident officer's tasks will be. You will save time and money and gain legal certainty in day-to-day operations if you appoint an external expert for the safety-related supervision of systems and processes.
• Benefit from the cross-company plant experience of an industrial park operator: As the operator of Industriepark Höchst, Infraserv Höchst and its experts provide hazardous incident regulation support to various industrial operations inside and outside Industriepark Höchst. Thanks to our extensive experience with all kinds of process plants, our specialists can think outside the box and help you develop new and safer processes.
• Outsource time-consuming additional tasks, reduce administrative expenses and book all-round support from experts to meet your needs: Infraserv Höchst's services go far beyond providing an hazardous incident officer and advice on plant and process safety. Our experts will also be happy to provide you with advice and assistance in the areas of licensing, pollution control and waste management and in occupational safety.

How Infraserv Höchst can help you implement the StörfallV and BetrSichV in your facility

• Initial check of your existing documentation to ensure compliance with legal requirements (e.g., completeness check of safety report and concept or explosion protection document, evaluation of hazardous substances, plausibility check of HAZOP or classification of PCT safety functions),
• Checking the safety of process plants and the associated documentation (e.g. by inspecting plants, assessing specific issues relating to the processes or the connection to supply and disposal networks),
• Ongoing advice to process plant operators from Infraserv's plant safety engineers, appointment of an hazardous incident officer,
• Safety assessment of process plants by HAZOP/ PAAG, e.g. in the context of new buildings or plant modifications or recurrently when updating the safety reports,
• Participation in the development of proposals for plant optimization under the aspect of accident prevention,
• Support in communicating with authorities in the event of incidents or accidents or during inspections by authority representatives.

Infraserv Höchst services that you can use to implement the provisions of the Major Accidents Ordinance

• Assumption of the function of hazardous incident officer,
• HAZOP/PAAG assessment: Systematic and structured process hazard analysis (PHA) for early identification of potential risks and definition of requirements for PCT safety functions and plant safety equipment (SIF/EzA),
• Explosion protection: development of explosion protection concepts and explosion protection documents,
• Preparation of safety reports and safety concepts in accordance with StörfallV,
• Carrying out dispersion calculations in accordance with StörfallV or for explosion protection,
• Independent auditing of your safety management system in accordance with StörfallV.

Learn more about the services provided by Infraserv’s hazardous incident officers! Download Infraserv’s expert tips and guide on incidents now!