Abstract
The Seveso III Directive, adopted by the European authorities in 2012, has updated the European regulation on industrial risks and on the prevention of industrial accidents. Among the prescriptions, there is the periodical review of the safety report for upper-tier establishments at least every five years (Article 10-5). In France, this prescription has been transposed in national regulation by the obligation, for operators of these establishments, to write a “review notice” five years after the last safety report has been submitted and accepted by the Competent Authority. This notice must study 11 points to determine if the facilities are still in adequation with their environment and if new technologies or new safety measures may be implemented to improve risk management. Following this notice and depending on its conclusion two options are available. In case of strong changes / modifications (of the facilities, environment, regulation), a revision / new version of the safety report has to be submitted to the Competent Authority. The second option, in case of no major modification and if the conclusions of the existing safety report are still valid, is to update this existing safety report. Contrarily to this last option, the revision of the safety report implies that the French authorities will process it and new prescriptions may be added to the establishment. This paper describes the requirements and contents (the 11 points) of a French review notice of the safety report for an upper-tier Seveso establishment, and its advantages / drawbacks compared to the automatic revision of the safety report every five years.
