A comparison between the implementations of risk regulations in the Netherlands and France under the framework of the EC SEVESO II directive

Abstract

International audienceThe SEVESO II directive has created a common framework for the European state members for the implementation of risk management strategies that require the introduction of various dimensions ranging from technical to organisational ones. Local regulations in countries have however diverse histories and philosophies. Some regulations include the calculation of probabilities (to define risk contours for Land Use Planning purposes) and some others do not (yet!). When they do not, deterministic scenarios are applied for land use planning, implying the calculation of the most severe potential accident or some negotiated/reference scenarios (like in the 90s in France). This is not without putting some constraints on the companies, on the local control authorities and on the urban planners from the cities. The Netherlands and France have two different traditions, respectively a probabilistic and a deterministic one. The aim of the paper is to compare how these two traditions, under the same SEVESO II directive, proceeded to implement the safety strategies required by the directive. Several dimensions will be compared in order to understand the current positions of the two countries and how this evolved after the two disasters of Enschede (2000) and Toulouse (2001). This will include the general organization, the main practices in terms of land use planning (past and future), the type of risk assessment and the number of SEVESO sites in order to put into context the two country's resources and constraints, and then appraise common points and differences