Killadysert Explosive Factory - Our letter in the clare champion


The Editor,

The Clare Champion,

11 December, 2000

Killadysert Explosive Factory

Dear Sir;

Your recent report noted that County Councilors were concerned about the lack of information relating to the safety of the proposed explosives factory at Killadysert. In fact, we had been requested by residents to assist them in seeking information about this proposal which they have been unable to obtain.

We purchased the Environmental Impact Statement for £30.00. Unfortunately, Appendix 1 is missing from the document.

Appendix 1 relates to the Health and Safety section [see 3.5 Health and Safety], which containing no data refers to 4.2 ["Technical supporting material"] which also contains no data and refers to Appendix 1, which is not included in the copy supplied.

At a number of points during the EIS the authors refer to the confidentiality of their operation, even citing a "need to know" principle.

The requirements for public consultation and the availability of information relating to explosives are clearly laid out in EU Directive 96/082, "The Seveso Directive", which is not referred to by the applicant in the EIS. The term "need to know" is not used in the Directive.

The following matters, however, are required to be made available to the public and have not yet been provided, unless they are in Appendix 1 which is missing from the copy supplied by your authority.

Article 11 of this Directive requires the production of internal and external "Emergency Plans" with the object of "communicating the necessary information to the public." No such Emergency Plan is included in this EIS.

Article 9 requires that a "Safety Report" be drawn up. No such Safety Report is included in this EIS.

Article 13 (1) "Information of safety measures" requires "Member States shall ensure that information on safety measures and on the requisite behavior in the event of an accident is supplied, without their having to request it, to person liable to be effected by a major accident originating in an establishment covered by Article 9".

Article 13 (4) states that Member States shall ensure that the Safety Report is available to the public.

Annex V details "Items of Information to be Communicated to the Public as provided for in Article 13 (1)". This lists 11 separate items, none of which have been provided within this EIS.

We have written to the local authority asking them to ensure that the developer conforms to Directive 96/082 by providing for public scrutiny the Emergency Plans and the Safety Report required by this Directive.

Further, in the course of our investigations into the proposal, we requested under the Freedom of Information Act full documentation from the Forest Service of the recent felling at the subject site. On the basis of this request, we are writing to the local authority with copies of documents which demonstrate that site development took place at this location without planning permission.

We are requesting that the Council ask the applicant to withdraw the current application and first seek retention for the site development works detailed in the Freedom of Information material supplied by the Forest Service.

Friends of the Irish Environment
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