Variety is the Spice of Life

21 March 2018

My wife and daughter are huge fans of cookery programmes. I am what is termed a “hostage viewer”, and have come to know more than I ever thought possible about tuiles, bone marrow, and sous vide cooking. Everything except how to actually use the techniques shown, of course. In the UK incarnation of a popular show one of the judges eagerly devours the best creations, especially desserts. In the Danish version of the same show which I caught recently while travelling the judges stared solemnly at the entries for a good twenty minutes, and intoned their verdicts in hushed tones; I never saw them eat anything. The angst was palpable. The same format; completely different realisations.

The idea of different interpretations of the same concept is familiar to anyone working with industries covered by EU Directives, of course. One only has to consider the differing implementations of the EU Seveso Directive, which cover industrial sites where the amounts of hazardous materials present exceed defined thresholds. Created in response to a serious pollution incident in Seveso, Italy, in 1976, the Directive has been updated to cover learnings from later accidents across the world. Across Europe the Seveso Directive, now in its third iteration, has helped set standards for controlling risk for in-scope sites, although declines in the accident rate have slowed in recent years. One Directive, and one goal; the reduction of hazards for both people and the environment.  

Yet this is not a European Regulation; the Directive has been implemented in different ways across the EU, written into law by national legislators. The interpretation of Seveso III in the Netherlands is different from that in Germany, which is different again from Italy. Some regulatory regimes require more third party validation than others. Some are prescriptive in specifying actions to be carried out; some set goals which must be met, but are more flexible about how to reach them. This divergence of interpretation has increased, as inspections of sites against the Directive have, in many cases, come to include issues on the leading edge of concern. Threats from direct attack, both in physical space, and through online means, from hostile actors must also be considered, although there is not yet a “standard” assessment route across regulatory regimes.

This presents a problem for organisations which operate across jurisdictions. How can they standardise their operating methodology as far as possible across their operations, while maintaining industry good practice, when requirements vary across the different implementations followed in the EU, let alone considering sites further afield?

This is a problem that is certainly of key importance to EEMUA members, and our guidance is often produced in response to exactly this issue. Cyber security concerns have prompted the work of our Cyber Security Forum, which has produced a useful information sheet on common basic issues, and will be releasing an elearning course on basic principles later in the year. These are applicable to any site, and represent a base level of good practice, applicable in any jurisdiction. Our storage tank expertise, exemplified by the guidance in EEMUA 159, and its associated competency courses, are recognised worldwide as good practice, and can be regarded as a bridge between ISO, EN and API standards. We work to identify the common threads of engineering good practice applicable across regulatory boundaries, and enable standardisation of operation as far as possible.

Variety is the spice of life, but the bane of an operations and maintenance policy. 

As to which cookery format I preferred? Well, I love a good dessert, but the food in Copenhagen was wonderful.