Question:  What do the following industries all have in common? Producers and distributors of bulk chemicals, the energy industries (both renewable and nonrenewable), pharmaceuticals production, production of cleaning products and solvents, manufacture of plastics, production and storage of fertilizers and pesticides, metal processing and metal parts manufacturing, and waste water treatment and supply of drinking water.  Answer: They are all essential industries for the functioning of society during the pandemic lockdown, many of them are contributing products to combat the virus, and they are also largely hazardous industries, routinely handling dangerous substances in medium to large volumes. Sites handling hazardous substances in sufficiently large volumes are subject to the obligations of the EU Seveso Directive (2012/18/EU).

The current Covid-19 pandemic has been a challenge for high hazard sites to maintain high levels of resilience on site while reducing exposure of personnel to the risk of contracting the virus.  It has equally been a challenge to achieve meaningful government oversight, verifying that sites are appropriately managing potentially high risk situations and planning how to manage potential changes to come.

Since the start of the pandemic, the JRC has conducted a number of activities to promote understanding and awareness of how the pandemic has affected hazardous sites, including an alert on preventing chemical incidents due to temporary site closures,  a survey of EU and OECD competent authorities, a webinar for EU Seveso site inspectors, and monitoring of chemical incidents occurring in the EU potentially impacted by the presence of the Covid-19 pandemic.  Findings from these initiatives all indicate that avoidance of personal contact and changes in site activity had far-reaching impacts on risk management and resilience of hazardous sites in the face of abnormal conditions.

In particular, to avoid personal contact, hazardous sites were obliged to deploy new methods and strategies, in a very short time frame, sometimes requiring successively more changes because of economic pressures, illness, and restrictions on transport to the site and intrasite mobility.  On many sites, the ongoing fluctuation of pandemic restrictions throughout the entire pandemic - imposed for several weeks, then lifted, and then imposed again - perpetuated this state of ongoing and continuous adaptation.  Companies had to conduct risk assessments and introduce new procedures to address the impacts of smaller, more distanced staff operations, remote staffing, and staff shortages due to illness and lack of childcare.  In addition, maintenance, shift changes, communications between staff, emergency planning, and IT security, are among numerous activities that needed to be adjusted to continue to be effective and keep the plant safe during the pandemic.

Limiting contractors on site meant that many companies had to reprioritize maintenance activities (e.g., replacing worn-out parts, anti-corrosion treatment) a critical element of safety, usually conducted by third parties.  The failure to adhere to strict maintenance schedules creates a higher risk that a pipe, tank or vessel will rupture or leak, causing a fire, explosion or toxic release. In many cases, it may take many months, or even one or two years, for a site to close out its maintenance backlog.

Changes in consumer demand created additional pressures on hazardous sites in managing their chemical accident risks. As reported to the EU, excess demand contributed to both a major accident on a liquid oxygen production site and a near miss at a disinfectant manufacturer. In both cases, the instrumentation was either inadequate or insufficiently calibrated to detect the presence of a hazardous substance in excess of production or storage capacity. Conversely, EU inspectors also reported concerns with hazardous sites related to a reduction in activity due to
pandemic measures.  As a result, many sites were operating at a loss for a variety of reasons, e.g., due to temporary shutdown of their industries, or scarce availability of process inputs, or because of decreased demand for their products or those of their clients.  In these circumstances there is always a risk that personnel and financial resources will eventually be insufficient to guarantee safety of operations in the foreseeable future.

While site closures were largely phased out after summer 2020, social distancing measures have been slower to disappear and there is still uncertainty in regard to whether the situation will be completely normalized in the winter of 2021.  Moreover, while it appears that some restrictions may have loosened to allow maintenance activities to be re-scheduled, it has been predicted that many sites will not be up-to-date in meeting their maintenance targets until some time next year.  In addition, industry in general appears to still face supply bottlenecks for certain inputs and component parts, due to a variety of reason that have been widely reported elsewhere, but also including ongoing effects of Covid-19 pandemic measures in various parts of the EU and the world.  To have a more precise perspective on resilience and recovery of hazardous industries at this stage of the pandemic, the JRC is considering conducting a follow-up survey of EU and OECD authorities in the spring of 2022.