Changes to the production plant
In order to manage process safety, the operator must have a systematic and effective change management procedure to identify, assess and commission changes to the production plant.
Tukes’ change management requirements are presented as part of Tukes’ process safety system under Change management. Tukes’ change management requirements apply in particular to operations that involve handling and storing hazardous chemicals (including plant, equipment and personnel). The functionality of change management and the changes implemented accordingly are covered at periodic inspections of the production plant.
Some changes are so significant in type or scope that a change notice or change permit application must be submitted to Tukes. The need for a change notice is assessed in relation to the risk of accidents and the scope of the operation. The assessment may also consider the operator’s competence and how advanced the process safety system is.
The processing of change permits and notices is explained on the Tukes website Processing of permits and changes.
What kind of changes may require the operator to submit a notice or permit application to Tukes?
The following sections provide guidance criteria for changes that require a change permit or change notice. Guidance is also provided for changes that do not need to be reported to Tukes. They are processed as necessary as part of periodic inspections.
Change permit
Riskiperusteiset kriteerit
- The change has or may have an impact on the environmental land use planning of the production plant
- The areas impacted by production plant accidents increase
- The plant’s consultation zone must be expanded or the impacts within it become more severe
- New areas around the production plant come under the consultation zone
- The change affects the risk of knock-on effects (an accident spreading from one production plant to another)
Criteria based on the list of chemicals
- The maximum quantity of a hazardous chemical is increased and as a result
- The scope of the activities increases (from minor to large-scale) or
- There is the obligation to prepare an operating principle document or safety assessment
Change notice
Risk-based criteria
- The change could significantly affect the risk of accidents in the production plant area due to the hazards of a chemical or its location
- The change requires or may require significant technical or structural changes to the handling or storage of hazardous chemicals and/or improvements to accident prevention or to limit the consequences.
- Examples of changes that may require a change notice:
- New storage tank, tank area or storage building of significant size
- Expansion of chemical storage to a new storage section
- Implementation of a fire-extinguishing system
- Expansion of the system for managing waste water from fire extinguishing
Criteria based on the list of chemicals
- The maximum quantity of a hazardous chemical is increased and, as a result, an LPG plant requires a permit
- The maximum quantity of a hazardous chemical is reduced or its handling is discontinued and, as a result, the scope of the activity becomes smaller
- From large-scale to small or
- From a plant requiring a safety assessment to a plant requiring an operating principle document or a permit
- From a plant requiring an operating principle document to a plant requiring a permit
Inspection (no reporting required)
- The change carries only minor risk
- The change has no impact on the areas affected by accidents at the plant
- The change does not call for technical/structural alterations or the alterations are not significant
- New small chemical tank (e.g. 10 m3 fuel oil tank)
- Changing the contents of an existing tank to a chemical of the same hazard class
- Increase in the maximum quantity of a chemical in the same storage area or part thereof
- The change does not require new technical solutions to prevent accidents or limit their consequences
Change permit
Risk-based criteria
- The change has or may have an impact on the environmental land use planning of the production plant
- The areas impacted by production plant accidents increase
- The plant’s consultation zone must be expanded or the impacts within it become more severe
- The new chemical involves new risks of major accidents for the plant, and the accidents may have consequences outside the site (e.g., the plant previously only used flammable chemicals, and the new chemical is immediately toxic)
Criteria based on the list of chemicals
- As a result of new chemical(s)
- The scope of the activities increases (from minor to large-scale) or
- There is the obligation to prepare an operating principle document or safety assessment
Change notice
Risk-based criteria
- The chemical poses new hazards to the production plant or the chemical is more hazardous than chemicals of the same type that have previously been handled (more flammable, toxic, reactive, more hazardous state, etc.)
- The change significantly increases or may increase the risk of accidents on the production plant site, taking into account the location of the chemical and activities in question
- The new chemical requires or may require significant technical or structural changes and/or improvements to accident prevention or to limit the consequences.
Criteria based on the list of chemicals
- As a result of new chemical(s), the LPG plant requires a permit
- A new chemical replaces an existing one and, as a result, the scope of the activities becomes smaller
- From large-scale to small or
- From a plant requiring a safety assessment to a plant requiring an operating principle document or a permit
- From a plant requiring an operating principle document to a plant requiring a permit
Inspection (no notice required)
- The change carries only minor risk
- The change has no impact on the areas affected by accidents at the plant
- The new chemical has similar hazardous properties to existing chemicals
- The change does not call for technical/structural alterations or the alterations are not significant
Change permit
- As a result of a change in the hazard classification of a chemical
- The scope of the activities increases (from minor to large-scale) or
- There is the obligation to prepare an operating principle document or safety assessment
Change notice
- Downward change in scope due to a change in a chemical's hazard classification
Inspection (no notice required)
- Changes to the hazard classification do not cause changes to the handling or storage of the chemical
- Changes to the hazard classification that do not affect the scope of operation are processed as part of periodic inspections (processing of the chemical list)
Change permit
Risk-based criteria
- The change has or may have an impact on the environmental land use planning of the production plant
- The areas impacted by production plant accidents increase
- The plant’s consultation zone must be expanded or the impacts within it become more severe
- The change involves new types of major accident risks for the production plant, and accidents may have consequences beyond the plant site
Criteria based on the list of chemicals
- As a result of changes to the process or storage conditions, the scope of operation becomes larger (from minor to large-scale) or the operator s obligated to prepare an operating principle document or safety assessment.
- For example, this is possible in the case of flammable liquids (P5a-P5c) where the condition is taken into account when calculating the ratio
Change notice
Risk-based criteria
- The way a hazardous chemical is handled or manufactured changes significantly, and the change affects the risk of accidents
- The change significantly increases or may increase the risk of accidents on the production plant site, taking into account the location of the chemical and activities in question
- The process conditions (e.g. pressure or temperature) change in a way that significantly affects process safety
- The change requires or may require significant technical or structural changes and/or improvements to accident prevention or to limit the consequences.
Criteria based on the list of chemicals
- As a result of changes in process or storage conditions, the scope of operation becomes smallern
- For example, this is possible in the case of flammable liquids (P5a-P5c) where the condition is taken into account when calculating the ratio
Inspection (no notice required)
- Process changes are within the safe operating limits
- The change carries only minor risk
- The change has no impact on the areas affected by accidents at the plant
Change permit
- The change has or may have an impact on the environmental land use planning of the production plant
- The areas impacted by production plant accidents increase
- The plant’s consultation zone must be expanded or the impacts within it become more severe
- The production plant’s area expands
- Expansion equivalent to the establishment of a production facility
Change notice
- The change affects the production plant’s layout and safety clearances
- The change has a significant impact on leakage management systems (e.g., bund walls, arrangements for managing waste water from fire extinguishing)
- The change has or could have an impact on the management of rescue activities or protection of people in the area
Inspection (no notice required)
- The change carries only minor risk
- Individual or minor changes in process equipment
- The main purpose of the building does not change
Change permit
- The change has or may have an impact on the environmental land use planning of the production plant
- The areas impacted by production plant accidents increase
- The plant’s consultation zone must be expanded or the impacts within it become more severe
- The change involves new types of major accident risks for the production plant, and accidents may have consequences beyond the plant site
Change notice
- The change includes new types of activities for handling and storing hazardous chemicals for the plant
- A significant change in the manufacturing process or processing method and may affect the risks
- New technology has or may have an impact on risks or risk management
- Technological changes in process control or monitoring
Inspection (no notice required)
- The change carries only minor risk
- Individual or minor changes in process equipment
Change notice
- The business operator changes (the business ID changes): Forms (Operator change notification)
- The person responsible for the production plant (e.g., the plant manager or CEO) changes: Email the new person’s details to the Tukes registry ([email protected])
- The ownership of the operator changes, and the change has a significant impact on the process safety system or the content of the safety assessment
- Requires the safety assessment to be reviewed
- Submit an updated safety assessment (Industrial use of chemicals and gases - forms)
Inspection (no notice required)
- Change in the person responsible for supervising the use of chemicals or preparing the operating principles
- The business operator changes its name (the business ID remains unchanged)
- Other relevant organisational and personnel changes
Notice
- The production plant will be closed down: Industrial use of chemicals and gases – forms (Notice of closure or suspension)
- Part of the production plant is closed down and it affects the scope of operation: Industrial use of chemicals and gases – forms (Notice of closure or suspension)
- The production plant’s operations are suspended for more than one year: Industrial use of chemicals and gases – forms (Notice of closure or suspension)
- Suspended operations are resumed: Change notice
Inspection (no notice required)
- Other suspensions and decommissioning of process units and equipment
Change of owner
If you buy a business, make sure that all necessary documentation is transferred in connection with the sale. The necessary documents include:
- original official permits
- records of previous inspections and information on valid requirements
- documents required by the authorities, such as rescue plans, the operating principle document or safety assessment
- PI diagrams, electrical and automation drawings, structural designs
- risk assessments
- servicing and maintenance plans and details about the history of machinery and equipment
- tank and pipeline documentation
- operating instructions and training material
Update the documents and notify the authorities of a change of ownership
Report a change of owner, name or contact information to Tukes. It is not necessary to notify Tukes of any changes to the chemical or LPG control officers, but a list of the control officers must be kept at the production plant.
Notification forms (in Finnish)