INDUSTRIAL RISK MANAGEMENT

1Do I have to update the hazard assessment of my industrial site subject to authorisation (non-Seveso) when a modification is made?

A new authorisation application may be filed for any industrial site with a Seveso Upper Tier, Seveso Lower Tier classification or subject to simple authorisation, registration or declaration when a modification is made or an extension planned. This will depend on the nature of the modification or extension.

In the first instance, an official notification known as a Porter A Connaissance (PAC) must be addressed to the Prefect to inform the authorities of the new installation and its characteristic features.

If the Regional Environment, Planning and Housing Agency (DREAL) then estimates that the modification being made on the site subject to authorisation represents a potential danger to the environment or is a substantial modification*, you will indeed be required to file a new application for what is now called an Autorisation Environnementale Unique (single environmental authorisation).

On the other hand, if it is established on notification that the new activity does not create any further danger or represent a substantial change, the procedure will not call for a public enquiry. An additional permit will simply be issued.

SOURCE
Regulatory basis of the answer > French Environment Code – Article L512-15
“Any modification made by the operator to the facility, to its mode of operation or to its surroundings that is liable to lead to a notable change in the elements of the authorisation or registration application or the declaration must be brought to the attention of the Prefect before said alteration is implemented.”

REMINDER
Substantial modification* Modification to the activity generating an increase in the products stocked and exceeding the thresholds and criteria established by the new decree of 8 July 2010. Even if the danger remains unchanged, a new authorisation application must be filed.

FIRE SAFETY

1I have a project of implementation of a sprinkler system in my factory of 12 000 square meters. Is it better to pass directly with an installer or by an engineering consulting firm ?

Changes to the purchasing process in fire safety are currently a burning issue. Taking the lead from the oil sector five years ago, industrial groups stopped working directly with installation firms for projects involving investment in excess of €250,000.

Decision makers prefer to go through an engineering consultancy who will provide support from the design phase through to assistance with acceptance operations and who will help them to select the right installer (in conjunction with Purchasing) rather than opting for a turnkey project directly from an installation company with the risk that they may not be completely impartial.

2Can a brokerage firm call on the services of CYRUS INDUSTRIE?
We have remarked that insurance professionals are often asked by their clients to assist them with their fire safety projects and cannot always respond to every need. In such cases, Cyrus Industrie welcomes one-off consultancy assignments to advise on fire safety and provide dimensional design and hydraulic calculations, or for technical assistance missions for the installation of a new sprinkler system.
3I work for a Departmental Fire & Rescue Service (SDIS) or as a Regional Environment, Planning and Housing Agency (DREAL) engineer. A local industrial site has asked me for a fire safety audit to find out my requirements. I don’t have the time (or the skills) to help them with their request for fire safety advice. Which of the various fire safety agencies can I turn to?

We have noticed that fire services/DREAL engineers are often asked by their industrial contacts for support (or a diagnostic) on fire safety projects and cannot manage to satisfy everyone.

We recommend that you give them the name of independent fire safety experts firms so that the client receives clear advice from a fire safety specialist with no vested interest in the installation stage.

4For my sprinkler system installation project or to audit my water source, would it be preferable to go through an independent company or through an engineering firm like Cyrus Industrie?

To help you choose your fire safety assessors, the DREAL will give far more credit to the fact that you have opted for fire safety engineering consultants involved in a MASE (Company Safety Improvement Manual) approach. MASE is a management system aimed at the permanent, continuous improvement of companies’ Health, Safety & Environment performance levels. It is also a system of certification which is awarded by a regional steering committee following an audit conducted by a selected outside body.

A good starting point when choosing the firm that will assist you with your plans to install a sprinkler system is to look at engineering consultants’ OFQIBI qualifications. The purpose of this qualification is to recognise the competence and professionalism of companies providing engineering services: consulting engineers, design offices and engineering companies. It reflects a structure’s ability to provide a specific service to its customers’ satisfaction.

Finally, for your fire safety study, we recommend that you work with a member of GEESPI, an association of engineering firms specialising in fire safety that is itself affiliated to the FFMI (French Federation of Fire Professions).

With such an array of accreditation, the selected fire safety specialists will hold more weight in your dealings with the authorities and/or insurance companies.

5How to know if I need to implant a sprinkler system in my industrial site?
6How long is it necessary to implant sprinkler system in a building ?
7How to draft my sprinkler CCTP ?
8How to obtain the N1 ?
9How well to choose my system of fire protection ?
10How to master my budget during a project of implementation of a sprinkler system ?
11How to approach my sprinkler project at the request of my insurer FM Global ?
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