Major Accident Prevention Policy: MAPP statement
BAI fuel oil terminal - Millbay docks
The BAI fuel terminal at Millbay was constructed in 2001 to provide strategic fuel oil storage, (and thereby a secure bunker supply), for the Brittany Ferry cross-channel fleet operating out of Plymouth.
Three main tanks of 1,227m3 physical capacity, (designated tanks 1, 2 & 3), and a smaller 30m3 tank, (tank 4), are contained within a reinforced concrete and masonry bund. Rainwater is drained off in a controlled manner through a three stage interceptor.
The bund capacity has been professionally measured at a total capacity of 1,086m3, therefore each of the three main tanks are restricted to a maximum working capacity of 987m3.
BAI are owners of the terminal; which is situated within the Millbay dock TRANSEC security zone, (it being an international ferry port); the land itself being owned by Associated British Ports. Since June 2011 the site has been managed for BAI under contract by John H Whitaker (Tankers) Ltd.
Upon assuming responsibility of the day to day management of the site, a comprehensive schedule of maintenance and remedial works was undertaken at the request of BAI technical management. Each of the three main tanks has been professionally inspected and refurbished to best industry standards and tank no. 4 replaced entirely with a new unit.
The site is manned by two full time staff plus a third individual contractor providing holiday relief. Day to day technical and operational support is afforded by Whitaker's staff teams based at Southampton and Hull, with scheduled supervisory and surveillance visits from BAI Technical management at Roscoff, France, along with support from Brittany Ferries' safety manager at Plymouth.
Safety of persons and the environment are core values of BAI, Brittany Ferries and John H Whitaker (Tankers) Ltd. All stakeholders subscribe to a robust safety culture and endeavour to follow best industry practices at all times.
Fundamental to the above, and the operation of the BAI Fuel Terminal in particular, is a commitment to prevent major accidents occurring, ever. This is to be achieved by the application of a thorough and comprehensive safety management system, including:
A safety policy - statement of aims and objectives
Hazard identification and risk assessment
Clearly defined roles and responsibilities for the management of major hazards
Comprehensive terminal procedures and instructions
Training for the above as identified to ensure competence
Careful and methodical recording of all design and modification to the installation
Emergency response procedures, (and exercising thereof)
Measurement of compliance
A system of review and audit
The following headings of this MAPP document address each of the above in turn.
Southern Divisional Director
John H Whitaker Group
Ver. 6 – March 2015
a) Safety Policy - aims and objectives
We aim to operate a safe and successful business based on strong ethical principles: specifically that safety comes first: of both people and the environment.
Put simply; no person, or aspect of the wider environment should ever come to harm through the conduct of our business. Safety is the foundation of a successful operation and no commercial pressure must ever be allowed to jeopardise this.
All of our company activities should be conducted in a manner to minimise HSE risks to a level which is As Low As Reasonably Practicable, (ALARP).
We will continually monitor and measure our HSE performance and strive for continual improvement through commitment to best practice.
All employees shall refrain from actions that are considered a risk to HSE and are empowered with authority to stop others from doing so. All contractors working on our behalf are required to comply with this policy.
b) Hazard identification and risk assessment
The site is managed within the framework of a comprehensive Safety Management System (SMS).
Hazard identification and risk assessment is achieved by the HSE “five steps” approach:
1. Identify the hazard
2. Assess who / or what aspect of the environment, might be harmed
3. Evaluate the risks
4. Record any significant findings – and implement them
5. Regularly review each risk assessment
These assessments are reviewed by senior management and the ALARP approach is taken at all times.
Examples of potential Major Accident Hazards (MAH) / Major Accidents to the Environment (MATTE) considered, include (but are not limited to);-
Working at height
Lifting operations with HIAB-type crane
Operation of company vehicles
Safety of personnel in extreme weather
c) Clearly defined roles and responsibilities for the management of major hazards: (MAH’s / MATTE’s)
The Whitaker group SMS defines management roles and responsibilities for health and safety matters. (Refer below to Company SMS section 8: Work Instruction A – page 7: Group safety management organogram).
The BAI terminal has two full-time staff with additional management support from the Southampton and Hull Whitaker offices, also from BAI Technical Management at Roscoff, France.
Importantly, the site comes under the jurisdiction of, and interfaces with, the statutory harbour authority and the Millbay major incident emergency response plans which define roles and responsibilities. It is therefore anticipated that these resources would be called upon in the event of a MAH / MATTE. Copies of the Millbay emergency plan (MILLPLAN) & oil spill response plan are enclosed and reference copies also kept on site.
d) Terminal procedures and instructions
A comprehensive set of terminal procedures has been developed and incorporated into the company SMS. A copy is kept on site.
The terminal procedures include detail of steps to take in event of a MAH / MATTE. The principle risks being identified as:
Fire / explosion
Oil pollution incident
Security threat (chiefly through theft but also potentially from act of terror)
See HRA’s for detailed considerations of above.
e) Training of site staff
The Whitaker group SMS contains a section dedicated to training of personnel; providing for identification of training needs, ongoing assessment and records pertaining to such.
The duties of the two full-time and one relief member of the terminal staff are itemised in comprehensive job descriptions; these, along with training records are maintained on site.
f) Methodical recording of all design and modification to the installation
The technical design aspect and any modification of the terminal and its equipment is managed by the Group Southern Technical Supt. based at Southampton. He is trained and certificated in storage tank assessment to EEMUA 159 standard.
All works are conducted to the appropriate industry standards and detailed records are maintained by the Supt. at the Southampton office. Details can be made ready for inspection at the Millbay terminal on request.
Note that any changes to the installation’s design must be subject to a MoC (Management of Change) assessment and the MAPP/SMS/WI-013 Terminal Operating Procedure should be reviewed before any modifications are implemented.
g) Emergency response procedures, (and exercising thereof)
Emergency response procedure is included within the site terminal procedures; these linking to the MILLPLAN and Millbay oil spill emergency plan as appropriate.
Exercises with the local authorities are proactively engaged and records of such retained.
A meeting with the port statutory authority shall be conducted on a minimum of an annual basis to discuss testing of emergency response procedures and full participation will be given to any emergency drills/exercises. At least one emergency drill per year is to be conducted.
h) Measurement of compliance
The site comes under the Whitaker Group KPI monitoring system: any non-conformances to the SMS / terminal procedures must be recorded and logged as a KPI (Key Performance Indicator). Copies of these logs and reports to be retained on site.
Any accidents or near misses are also to be fully logged as recordable KPI’s; each to be investigated as appropriate. All reports to be monitored by company senior management (see SMS organogram) and reviewed regularly at Group safety and quality meetings.
i) Review and audit
A review must be conducted of any accident or significant near miss incident, and a record made of any lessons learned.
Senior management of the Whitaker Group meet at regular intervals to discuss and review the group’s SMS compliance, including the terminal’s safety and environmental performance. Regular site visits to the terminal are undertaken and records of review to be available.
This document, and indeed the SMS and all procedures, are very much a “dynamic” process and subject to ongoing development and review as needs are identified.
Southern Divisional Director
John H Whitaker Group
Plymouth Terminal MAPP ver6 February 2015