# A comparative analysis of risk prevention policy tools and governance structures in Normandy (France) and Victoria (Australia): Assessing policies for high-risk sites

Scarlett Tannous, Myriam Merad, Jan Hayes

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Scarlett Tannous, Myriam Merad, Jan Hayes. A comparative analysis of risk prevention policy tools and governance structures in Normandy (France) and Victoria (Australia): Assessing policies for high-risk sites. International Journal of Disaster Risk Reduction, 2025, 110, pp.104600. 10.1016/j.ijdrr.2024.104600. hal-05197573

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# A comparative analysis of risk prevention policy tools and governance structures in Normandy (France) and Victoria (Australia): Assessing policies for high-risk sites

Scarlett Tannous<sup>a, *</sup>, Myriam Merad<sup>a</sup>, Jan Hayes<sup>b</sup>

## ARTICLE INFO

### Keywords:

- Public policy analysis
- Risk policy and regulation
- Risk governance
- Policy tools
- High-risk organizations
- Major risks

## ABSTRACT

High-risk industrial sites are classified as the most dangerous sites for their risk of inducing damage in case of an accident, even if it is rare. Risk policies are one way to prevent damage while balancing other trade-offs. How can public authorities assess “risk policy systems” of high-risk sites in specific administrative regimes for an effective decision process taking into consideration different jurisdictions? This paper investigates the Normandy and Victorian risk policy system in France and Australia, respectively, based on qualitative approaches. By investigating two cases and fostering conceptual thinking, two assessment criteria are highlighted by different stakeholders to determine an effective risk policy. For instance, beyond the common focus on the efficiency and efficacy of risk policies, findings revealed the importance of “dialogue, participation, and cooperation” between actors and “adaptivity, flexibility, relevance, and coherence” of different tools and legal texts. Limitations and further work include testing and iterating on other assessment criteria to propose an adapted assessment framework for high-risk policies.

## 1. Introduction

As one of the world's largest industrial sectors, the chemical industry includes the processing and production of “industrial chemicals, polymers, pharmaceuticals, pesticides, biocides, food and feed additives, and cosmetics” [1]. Although the production of chemicals helps in improving people's health, quality of life, and well-being, when dreaded events (e.g., fires, explosions, or release of toxic chemicals) occur, the list of negative impacts can include potential fatalities, injuries, material damage, etc.

High-risk industrial sites consist of sites with significant volumes of stored chemicals which are singled out for special legislative attention, such as the industrial Seveso Upper Tier (UT) sites in Europe and Major Hazard Facilities (MHF) sites in Australia [2,3,85]. By definition, a major accident corresponds to a very low occurrence and a high level of potential damage [4]. Risk prevention and crisis management policy are one way to prevent that while considering the economic viability of the industrial sector. Such trade-offs between safety improvement and economic viability constitute a major challenge for public authorities, who have a primary role in citizens' safety and well-being. Their administrative and political decisions have to contribute to the development of effective risk prevention and crisis management policy.

According to legislative definitions, materialized disaster risks or major accidents with immediate public fatalities and/or significant and immediate environmental and material effects are considered to be relatively rare [4]. For an accident to happen, multiple

<footnote><sup>a</sup> LAMSADE, Paris Dauphine University, Pl. du Maréchal de Lattre de Tassigny, 75016, Paris, France</footnote>

<footnote><sup>b</sup> School of Property, Construction, and Project Management, RMIT University, GPO Box 2476, Melbourne, VIC, 3001, Australia</footnote>

<footnote>* Corresponding author.</footnote>

<footnote>E-mail addresses: scarlett.tannous@dauphine.psl.eu (S. Tannous), myriam.merad@lamsade.dauphine.fr (M. Merad), jan.hayes2@rmit.edu.au (J. Hayes).</footnote>
failures of many system defenses must ‘line up’ like holes in Swiss cheese [5]. It is common for investigations into such accidents to find faults with regulatory systems and so regulatory failure is often cited as a cause of major accidents. Yet, regulatory failure does not trigger an accident. It is what Reason [5] calls a latent failure i.e., a condition of the system that then fails to identify and prevent other more active failures that can trigger an accident. As a result, there is an opportunity to find and manage such regulatory issues ex ante (before the occurrence of an accident). To do this requires some kind of benchmark or framework regarding what makes for effective regulation. Despite multiple studies, such a framework has not been developed for risk policy in relation to accidents in the chemical industry. This paper contributes to the development of such a framework based on a critical comparative analysis of the chemical industry safety risk policy systems in Normandy, France and in Victoria, Australia. By examining these regulatory systems in practice and identifying common features and differences, this research aims to identify key parameters that can be used for the assessment of regulatory effectiveness<fnref n="1" />.

Attention to the effectiveness (i.e., whether the policy system works or not) of risk policies related to this sector is intermittent. It is mainly in the wake of major industrial accidents and environmental controversies that policies, regulations, regulators, and everything in between gain prominence, come under scrutiny, and may be subject to blame. This was the case after the AZF explosion in 2001 in France [6–9], the Lubrizol-Normandie Logistique (LNL) fire in 2019 [10–13], and the Longford gas explosion in 1998 in Australia [14, 15]. Many previous accidents<fnref n="2" /> have also contributed to the genesis and development of today’s regulatory systems, including offshore accidents.

In fact, the Seveso Disaster led to regulatory reform in Europe that still bears the name of this major accident. This disaster, with all its environmental, economic, and social impacts, has attracted attention to the production, processing, storage, and transportation of chemical substances. Across Europe, in response to the need for harmonized regulations of risks, the first Seveso Directive<fnref n="3" /> made inadequacies in safety measures, professional management, and public control no longer acceptable. This is by imposing a safety report on the operating company (OC), requiring inspections by competent authorities, and establishing minimum requirements to be applied by the Member States [16,17]. Subsequently, the Seveso II Directive<fnref n="4" />, which, after the occurrence of several accidents correlated to “management factors”, attempted to increase consistency in enforcement through greater prescriptive details indicating the obligations of the competent authority (CA) [18]. It increased recognition and importance of appropriate (i) policies; (ii) management systems; and (iii) inspection, oversight, or monitoring systems, which were later formalized into different legislative and regulatory approaches. Seveso III Directive<fnref n="5" /> in 2012 emphasized the role of emergency plans, the involvement of the public in consultation and decision-making, and the considerations of the Globally Harmonized System (GHS) for the classification of ‘dangerous substances’ [83]. For Seveso UT sites, OCs must submit a “safety report” that is intended to enforce planning for those major accident scenarios. Regulators review these reports to ensure they meet acceptable standards and to plan corresponding inspections [17].

Many questions come to mind when dealing with the topic of public policy assessment such as the following: should the public authorities wait for an accident to occur to question the ability of public policies on risks to prevent major accidents including their potential damage, i.e., their effectiveness? What about continuous learning as well as adaptive and integrated assessment? What are the aspects and conditions that can determine and guarantee an “effective” risk policy at high-risk industries? Ultimately, a risk policy must reduce risks and prevent major accidents (e.g., efficacy), but what other aspects condition such performativity? In addition to these operational questions, a specific Research Question (RQ) is investigated: *how is an effective risk policy system<fnref n="6" /> around high-risk sites perceived by the main stakeholders at the Regional level for France and the State level for Australia and what aspects drive this perceived effectiveness?* This paper will contribute to answering these operational and research questions based on a bottom-up approach where the data is collected from the actors who deal with, mobilize, and apply the policies and regulations in practice and hence experience their effectiveness in preventing major risks.

Some answers to these multidisciplinary questions can be found in public administration, management and decision sciences as well as risk, safety, and regulatory research areas. Under the public policy dimension, studies emphasize gaps related to (i) the role of effective risk governance and (ii) the central role of inspection, oversight, or monitoring, which are often overlooked despite their importance [18–22]. To answer some of these issues, some comparative studies addressed onshore industrial risk or safety regulations across countries and continents [23–34]. These studies included some type of document review or content analysis of regulatory and policy aspects. Except for Sandri et al. [33] and Ylönen et al. [34], no other comparative study in the list of references that we have considered included interviews with actors such as regulators or inspectors.

Discussions regarding the regulation of major accident risk often compare and contrast prescriptive regulations (as broadly used in the US) with a goal-setting form of regulation (commonly used in Europe and Australia) [26,31–34]. This research provides a different point of comparison by contrasting the French Napoleonic law with the common law system in place in Australia (as in the UK). This

<footnote n="1">¹ Some consider that policy effectiveness can be determined by the efficiency, efficacy, and adequacy of the policy. Others add to them public participation, legitimacy, etc. This paper takes the policy effectiveness to a multi-criteria scope where two criteria emerged as important when conceptualizing the “effectiveness” concept</footnote>

<footnote n="2">² For instance, these accidents include the Flixborough Disaster in 1974, the Bhopal Gas Tragedy in 1984, the Seveso Disaster in 1976, and the Texas City Refinery Explosion in 2005.</footnote>

<footnote n="3">³ Official Journal of the European Communities [88].</footnote>

<footnote n="4">⁴ Official Journal of the European Communities [89].</footnote>

<footnote n="5">⁵ Official Journal of the European Union [83].</footnote>

<footnote n="6">⁶ In this study, a risk policy system combines (i) an organizational and governance system that organizes the roles and responsibilities of the public and private spheres with regard to risk, (ii) a regulatory or normative system that defines the institutional framework of the risk policy, and (iii) a system of practical tools that enable stakeholders to put the risk policy into practice.</footnote>
case selection provides a more detailed comparison of two regimes broadly grounded in the same kind of goal-setting approach. This highlights the originality of this paper, which aims to address the “effectiveness” of risk policies related to high-risk industries by considering a more bottom-up comparative approach that is closer to the actors implementing, developing, and interacting with the risk policy system. It iterates between Normandy (France) and Victoria (Australia) at a Regional and State level for the first time, which can be enriching since their different legal system, regulatory approach, jurisdictions, and contextual aspects can have different implications on the policy effectiveness.

Based on qualitative approaches and two iterative case studies where 43 interviewees shared their perceptions and experiences with high-risk organizations and regulatory agencies, this paper aims to enhance the understanding of risk policies by comparing the risk policy systems in place in the two cases and revealing some determining aspects of their effectiveness (e.g., beyond economic efficiency and efficacy in achieving objectives) in practice. This fosters multi-criteria conceptual thinking and problem framing for risk policy assessment [35,36] to go beyond the efficiency and efficacy dimensions recurrently used in assessment strategies as reviewed in Tannous et al. [37]. Therefore, this study suggests, as illustrated in Fig. 1, embracing the complexity of a risk policy system that combines (i) an organizational and governance system that organizes the roles and responsibilities of the public and private spheres with regard to risk, (ii) a regulatory or normative system that defines the institutional framework of the risk policy, and (iii) a system of practical tools that enable stakeholders to put the risk policy into practice. This system is then investigated within two qualitative case studies in the Normandy Region and the State of Victoria. Comparing a Region in France to a State in Australia helps in maintaining the assessment around the regulatory/control authority taking into account their centralized versus federal context. More specifically, the Normandy Region and the State of Victoria were chosen for this study due to their relevance to the industrial risk policy effectiveness concerns. They have attractive and enriching role because (i) both are areas with significant numbers of high-risk facilities, (ii) both are marked by significant accidents that affected the public perception of industrial risks and the regulatory arena, and (iii) both have a control or inspection authority known for its engagement on industrial risks aspects for high-risk facilities. Therefore, as major accidents do not occur frequently, risk policies have blurred contextual boundaries, and their effectiveness depend on numerous variables [38,39], a relatively limited knowledge is found ex-ante (i.e., before the occurrence of the accident). This calls for accumulating such exploratory iterative qualitative case studies. Each case has its specificities, which, when combined, provide different possibilities [40] to propose some key components of effective risk policies.

The structure of this paper starts with reviewing the main characteristics of the risk policy system in Normandy (France) and Victoria (Australia) in Section 2. The qualitative methods adopted, including semi-structured interviews and document review are explained in Section 3. The main findings are explained and compared for the Normand Region and the State of Victoria by structuring and mapping the main actors and tools as perceived by key stakeholders in Section 4. Consequently, this paper confirms the multi-actors and multi-criteria nature of a risk policy system and highlights two of the main criteria of an effective risk policy to finally conclude and highlight some future work in Section 5.

## 2. Risk policies in the (petro)chemical sector

In a relatively centralized governance system like France, policies for high-risk sites are typically determined and enforced uniformly by the central government (e.g., ministries and their regional control authorities) through national regulations, centralized oversight, and top-down enforcement. In a federal governance system like Australia, regulation of high-risk sites is a State responsibility. States, like Victoria, have their own regulations tailored to their needs, leading to differences in practices, legislation, and monitoring approaches towards operating companies among others. Laws setting general requirements are enacted by the State Parliament and subsidiary regulations are developed by the government after going through a consultative process with various stakeholders. This contextualization is necessary to understand how the control or monitoring authority works and interacts at a regional level within the French system, characterized by centralized governance where the same ministry gives orders to different regional control authorities. This is in contrast to the decentralized approach in Australia, where states like Victoria have their own regulations and regulatory authority that manages all local regulatory activities.

### 2.1. Brief overview of risk policies framework: policy objectives, main actors, and latest reforms in France

In France, the Environmental Code is the main digest of legal texts that regroup obligations linked to the management and prevention of industrial risks. Since the early attempts to address industrial risks with the Napoleonic Code (1810), the prevention of major industrial risks has always relied on several pillars served by various practical policy tools<fnref n="7" /> [41–43]. The law<fnref n="8" /> has gradually evolved after each learning situation (e.g., major accidents, political crises, controversy, etc.) [6,8,42,44–47].

The industrial risk prevention approach in France relies on four main principles: (i) risk reduction at the source through ensuring a defense in-depth approach based on multiple independent prevention and protection barriers or layers. Risk prevention is the operating companies’ primary responsibility. The State, through the facilities’ inspection body, known as DREAL (Regional Directorate for Environment, Planning, and Housing) plays an important role in the preventive approach as well; (ii) the urbanization control by land-use planning that aim at reducing the population density (or at least avoiding an increase) and the existence of vulnerable stakes such as buildings and infrastructures, around the industrial sites with major offsite industrial risks (when this is possible) (Seveso Upper

<footnote n="7">⁷ Policy tools or instruments including legislative and regulatory tools/instruments can serve interwoven purposes within a public policy. For example, they play a symbolic role representing the authority of legitimate power, an axiological function by delineating the values and interests chosen to be protected by the State, and a pragmatic role aiming to nudge social behaviors and shaping oversight systems [87].</footnote>

<footnote n="8">⁸ The law relies on seven main pillars including the knowledge of hazards and risks, monitoring, crisis anticipation, and urban planning considerations [4].</footnote>
<figure><img src="image_3.png" /><figcaption>Fig. 1. Components of the risk policy system.</figcaption></figure>

Tier). Efforts of the State, the local authorities, and operating companies (OCs) contribute to this control; (iii) emergency response planning where both internal and external emergency plans play an important role; and (iv) the information for the public about the possible accidents with offsite impacts and the way to react in case of their occurrence [4].

Initially, the control of major industrial risks is essentially entrusted to the Ministry of Ecological Transition (MTE). Traditionally speaking, the industrial risk management system in France was considered as a command-and-control top-down hierarchy. This is represented in Fig. 2 where the Government and Ministries appear are at the top of the risk governance system while they are supported by some<fnref n="9" /> agencies, bureaus, and institutes. The latter have various roles including piloting the investigations the causes of industrial accidents, mobilizing and centralizing the existing skills in the field of industrial safety from both the public and private spheres, publicly formulating recommendations and ensuring their follow-up to improve the industrial safety (more on this in Ref. [36, 48,49]). The inspection body, DREAL, stands at the intersection point between public authorities and their national regulations and the objects subject to risks, such as the facilities, sites, territories, etc. One of the other main actors is the General Directorate for Risk Prevention (DGPR)<fnref n="10" /> of the Ministry of Ecological Transition, which plays an important role in framing, elaborating, coordinating, and implementing public policies related to major risks and waste management. Its Ministry considers five main principles regarding the quality of public policy evaluation: impartiality, transparency, pluralism, exhaustivity, and trackability [50].

Sites are classified depending on the type and quantity of hazardous materials and the most hazardous are called “classified installations for the environment” (ICPE). Industrial sites are classified according to the type of facilities and degree of hazardous substances under distinct licensing regimes. The licensing system encompasses environmental authorizations (AE), declaration (D), and registration (R). Each licensing regime determines the level of safety constraints and measures that should be put in place and the legal requirements throughout the process lifecycle, starting with the initial declaration/file submission to the Prefect till the authorization and monitoring by DREAL. Higher-risk installations<fnref n="11" /> are divided between Seveso Upper-Tier (UT) and Seveso Lower-Tier (LT) [3].

In France, in 2023, 1344 sites fall under the Seveso III Directive including both Seveso UT and LT [51]. More particularly, in 2023, 56 Seveso Upper Tier sites operate in the Normandy Region [52]. This region is one of the densest region in terms of number of Seveso UT in France (especially its Seine-Maritime department). For instance, 3 325 500 individuals reside in the Normandy region [53,54]; this corresponds to a population density of 111.3 residents per kilometer square in 2020.37.8 % of these individuals reside in the Seine-Maritime department, making it one of the most populated departments of this region [55], especially in the areas around the Rouen metropolis surrounding the Seine River loops [56].

## 2.2. Brief overview of risk policies objectives, main actors, and latest reforms in Victoria

The Occupational Health and Safety (OHS) Act 2004 and Regulation 2017 are the main pieces of legislation to regulate the most hazardous chemical sites known as major hazard facilities (MHFs). Under this OHS goal-based legislation, owners have a duty of care to those who can be impacted by their activities, including workers and contractors on site and members of the public in surrounding areas who may be impacted by an incident at the site [85]. In real terms, this means that MHF operators must demonstrate that hazards have been identified and associated risks have been managed appropriately,<fnref n="12" /> including that everyone on site understands their roles

<footnote n="9">⁹ Agencies, bureaus, and institutes have various roles including piloting the investigations the causes of industrial accidents, mobilizing and centralizing the existing skills in the field of industrial safety from both the public and private spheres, publicly formulating recommendations and ensuring their follow-up to improve the industrial safety.</footnote>

<footnote n="10">¹⁰ In particular, the technological risks service (SRI) coordinates with different ministries and institutes the aspects related to the technological risks.</footnote>

<footnote n="11">¹¹ The UT European classification is paralleled by a French classification called environmental authorization (AE).</footnote>

<footnote n="12">¹² This includes ensuring that everyone on site understands their roles in major hazard accident prevention, that the likelihood of hazards and the degree of harm from an eventuated risk are known, reduced, and eliminated to the best available and suitable ways, and that the cost of reducing or eliminating them is reasonable.</footnote>
<figure><img src="image_4.png" /></figure>

**ADEME:** French Environment and Energy Management Agency.

**ANSES:** National Agency for Health and Food Safety.

**BEA-RI:** Bureau of Investigation and Analysis on Industrial Risks.

**CEREMA:** Centre for Studies and Expertise on Risks, the Environment, Mobility and Urban Planning.

**CGEDD:** General Council for the Environment and Sustainable Development.

**DGPR:** General Directorate for Risk Prevention.

**DREAL:** Regional Directorates of the Environment, Planning and Housing.

**IGEDD:** General Inspectorate of the Environment and Sustainable Development.

**INERIS:** National Institute of Industrial Environment and Risks.

**INRS:** National Institute for Research and Security.

**IRSN:** Institute of Radioprotection and Nuclear Safety.

**MTE:** Ministry of Ecological Transition

<caption>Fig. 2. Industrial risk governance structure in France in simple terms (source: adapted from Ref. [41]).</caption>

in major hazard accident prevention. This “appropriate management” is related to the fundamental requirement for owners of MHFs to demonstrate that risks at their sites are reduced so far as is reasonably practicable (SFAIRP). Documentary evidence that this is the case must be provided in the form of a safety case and a written safety management system (SMS). Compliance is enforced, in the first instance, by annual inspections in addition to feedback on written submissions. Successful demonstration that risk is controlled is required in order to obtain a license to operate an MHF. Effective major risk policy and compliance with regulations require the capacity of management to undertake risk assessment activities. It also relies on a set of relationships between MHFs, including management, advisors, consultants, workforce, health and safety representatives, etc.; regulators (especially the Major Hazards Unit formed to administer the related regulations); and several other actors such as fire brigades, councils, and other regulators. These relationships evolve throughout the years to cope with regulatory reforms and adjust to site conditions.

The history of legislation of large industrial facilities in Victoria effectively starts with the Royal Commission into the fire and explosion<fnref n="13" /> at the Longford Gas Processing Facility in Gippsland (eastern Victoria) [15]. This 1998 accident killed two workers, but it is remembered primarily because the gas supply to the domestic network was unavailable for two weeks. At that time, many Victorian homes depended on natural gas for heating, cooking, and hot water and gas was also a significant industrial energy source. The high

<footnote n="13">¹³ More on this accident in Longford Royal Commission et al. (1999).</footnote>
<figure><img src="image_5.png" /></figure>

CSIRO: Commonwealth Scientific and Industrial Research Organization.

DEECA: Department of Energy, Environment and Climate Action.

<caption>Fig. 3. Industrial risk governance structure in Victoria in simple terms.</caption>

level of household and industrial disruption created a significant political incentive to take action to prevent such an incident from happening again. The new regulatory regime introduced as a result (2000 version), moved to a goal-setting form of regulation incorporating a licensing requirement and established a new regulatory agency (Major Hazards Unit of WorkSafe Victoria). Several rounds of revisions to the legislation have occurred since that time, but the overall form of risk policy is unchanged, and this has been adopted across other Australian States and in New Zealand. Before that, regulations were based on the 1996 Australian National Standard for Control of Major Hazard Faculties (MHF) which was itself based on the Seveso II Framework [57]. Prior to the Longford accident, no attempt to regulate MHFs differently than any dangerous goods site was made in Victoria, knowing that the history of occupational health and safety regulations can be traced back to before 1985 [58].

WorkSafe Victoria (WSV), and more particularly the Major Hazard Unit, is the regulatory entity of MHFs at the State level (Fig. 3). The regulators’ duties go beyond issuing notices as categorized in Fig. 4 (level 2 of the enforcement pyramid) to englobe practices ranging from license revocation (level 1) to face powerful industries to persuasion (level 3) to also help people resolve MHF issues and comply with local laws. Their oversight strategy is consistent with the European Seveso Directives imposing annual inspections for each MHF. Their roles include verifying that (i) OC is controlling occupational health and safety (OHS) and major incident risks so far as is reasonably practicable (SFAIRP); (ii) SMS and safety systems are operating to achieve the goals of the safety legislation; (iii) safety legislation is respected by the duty holders; (iv) objectives are continuously applied in the future by allowing objective measurement, evaluation, reporting to stakeholders, and consultation; and (v) critical technical review by a third party is provided when needed [59]. This is besides the monitoring strategies that ensure: (a) post-licensing oversight plans imposing a series of planned visits to monitor site progress; (b) annual inspection scrutinizing the SMS implementation and the control identified by the SC; (c) annual reviews at an individual MHF level (micro level) conducted after the inspections; and (d) annual review at a sector level (macro level) [59].

More recent efforts on integrating additional land use planning (LUP) considerations in the MHF regulatory system seem to be occurring nowadays, knowing that some pre-existing initiatives exist<fnref n="14" />. For instance, the Victorian Government, through its Department of Environment, Land, Water and Planning (DELWP), created the Major Hazard Facilities Advisory Committee (MHFAC) in July 2018 and updated the Victorian Planning Provisions (VPPs) to cope with urban planning around MHFs [60]. This is by

<footnote n="14">¹⁴ The pre-existing initiatives include 2010 guidance note, 2015 Major Hazard Advisory Committee, Victoria Planning Provisions (VPP), and so on.</footnote>
<figure><img src="image_6.png" /><figcaption>Fig. 4. The enforcement pyramid (source: adapted from Ref. [78] and the Australian National Compliance and Enforcement Policy (NCEP)).</figcaption></figure>

deploying buffer zones and zoning systems according to the committee's recommendations. It is related to the increase in population density and urban expansion, leading to a certain closeness to remote sites or sites that were considered far from cities and residential areas.

Industrial facilities in Australia are classified according to the quantities of hazardous chemicals of different kinds stored on the site. The most hazardous sites with the largest aggregated quantity of chemicals are classified as major hazard facilities (MHFs) [85]. MHFs include a variety of industries, sizes, and maturity levels. These facilities, which include chemical processing plants, oil refineries, fuel terminals, and warehousing, are subject to this unique MHF risk policy. The chemical, plastics, and petroleum sectors dominate most of the MHFs in Victoria. For instance, industries range from oil refining (e.g., Viva Energy Refinery in Geelong), manufacturing (e.g., Qenos for olefins and polymers) through to chemical storage (e.g., ExxonMobil, a big chemical storage facility).

Victoria is home to 40 MHFs in 2023, geographically distributed across the State, with two localized areas or industrial clusters around the Melbourne area and another industrial cluster in Geelong. These areas not only host industrial facilities but also accommodate significant urban populations. For instance, the population, as per March 2023 data, consists of 6 766 600 individuals; this corresponds to an estimated population density of 29.73 individually per square kilometer [61].

## 3. Methodology

This study relies on a constructivist approach, assuming that social realities are co-constructed by the people and researchers' interpretations [62], so an effective risk prevention policy is reflected by a competing collection of stakeholders' interests [63]. In safety and management research, constructivism was encouraged to observe phenomena within contextually rich environments [14, 64]. The pragmatic philosophy is adopted since concepts are only relevant when they support actions to effectively implement risk policies. The relationship of the case studies with the constructivism and pragmatism philosophies enables the application of thematic analyses and triangulation<fnref n="15" /> of sources of evidence to systematically and constructively organize data collection, analyze the cases, and guarantee a high-quality study [62]. These considerations lead us directly to using a research approach of comparative case studies with interviews as the primary data collection method.

The research strategy relies on two iterative qualitative case studies of chemical site risk policies in action in two jurisdictions: the Normandy Region (France) and the State of Victoria (Australia). They allow an in-depth, holistic, and comprehensive investigation of an issue [38]. As risk policy assessment is context-related complex issues under development involving various actors and objectives, the multiple-subject case studies are especially useful in this specific context [39]. Also, case studies can serve the “how” and “why” research questions<fnref n="16" /> that have little research control. Each case allows the exploration of elements’ dynamics within single settings [65]. Also, multiple cases mean identifying different configurations constructs that are activations to certain assessment criteria modalities. These criteria emphasize that there is no such thing as a good or bad case, only an “adapted” risk policy system based on explicit assessment criteria. Within the iterative perspective, the goal is to use the collected accumulation of information to highlight either similarities or differences, enriching the understanding of this policy effectiveness phenomenon [40] and revealing its multi-criteria nature.

<footnote n="15">¹⁵ Different qualitative methods are mobilized to collect data and information on these aspects by relying on semi-directive interviews, field observations, and desktop reviews while including some quantitative elements. This triangulation of methods allows the collection of both primary and secondary data on a sensitive issue related to risks, risk-related policies, public actions, and the implicit responsibilities of different stakeholders.</footnote>

<footnote n="16">¹⁶ In this case, the research question is the following: How is an effective risk policy system around high-risk sites perceived by the main stakeholders and what aspects drive this perceived effectiveness?</footnote>
Qualitative data are collected to serve the assessment of industrial risk policy by examining what is prescribed in a risk policy and what is applied in practice taking into account the risk policy system (Fig. 1). For instance, to examine “what is applied” in practice, the data is collected through interviews from the actors who deal with, mobilize, and apply the policies and regulations in practice and hence experience their effectiveness in preventing major risks (bottom-up approach). Additionally, in order to understand certain policy requirements and track the motivation behind the evolution of “what is prescribed”, a desktop analysis of the legal texts and organizational/institutional documents is conducted [3,66–68,85]. The force of evidence relies on the interview verbatims<fnref n="17" />, the fieldwork logbooks, and the official assessment reports published both in scientific literature and organizational/institutional documents.

Face-to-face semi-structured interviews are chosen as they normally allow the researcher to understand the “how” and “what” makes a policy effective as per the Regional and the State actors for these Normandy and Victorian case studies. The interview protocol includes questions crafted as per the technique proposed by Jiménez & Orozco [69] and focused on several themes, including the following<fnref n="18" />:

* A theme on the role of MHF regulators and inspectors, their relationship with other actors, and the governance system around them.

* A theme on the perceptions and the feedback regarding the use of different prevention tools such as safety cases, inspections, sanctions, etc.

The sampling method is a combination of purposive sampling (via professional contacts, networking at conferences, and online searches) and snowballing. Recruitment proceeded until the saturation<fnref n="19" /> point was reached for the main questions raised in the interview protocol, which occurred at the nineteenth interview for the Normandy case study and the seventeenth interview for the Victorian case study. Interviewees were recruited through purposive sampling by especially focusing on the regional actors in Normandy and the state actors in Victoria. Inclusion criteria required individuals to be actors in the industrial risk governance who are especially involved in elaborating and implementing risk policies and regulations within these two areas. Potential interviewees were identified through online channels and professional recommendations. The online recruitment was conducted via the professional website, contact form of their entities, and their personal LinkedIn page leading to twenty-seven interviewees participating in this study. Two interviewees were also identified through professional networking events (e.g., conferences and research days on risk and safety-related topics). Fourteen were recruited throughout the process based on recommendations of former interviewees. Consequently, 43 interviewees, including 25 and 18 were interviewed<fnref n="20" /> for the Normandy and Victorian case studies, respectively. They are outlined in Table 1. Normandy interviews were conducted and transcribed using Microsoft Word and NVivo™ in French before being translated into English using the DeepL online translation tool (www.deepl.com). DeepL was selected for its advanced neural network technology, which allows an understanding of textual contexts and nuances, resulting in more accurate and reliable translations. The authors reviewed and edited the translated content for consistency and validation purposes. Also, field visits in both Normandy (France) and Victoria (Australia) allowed the integration of some direct observations.

Thematic analysis was chosen for its flexibility and systematic way of looking into patterns, also called themes, related to the research question [70] while coping with large and rich datasets representing the interviewees' perception in this study. Driven by the abductive approach, it goes through the whole interview transcriptions to look for these two pre-mentioned themes on actors' roles and policy tools (deductive approach) and allows the exploration of the data and the emergence of new themes derived from the data in an undiscriminating way (inductive approach). The interview protocols obtained approval from the Research Ethics Committee of Paris Dauphine University - PSL (certificate number 2023-05). Pseudonyms are used for both the interviewees and their entities to guarantee anonymity. The ethics certificate and more details can be found in Appendix B.

Systems<fnref n="21" /> thinking is adopted to ease and organize the findings of each of the case studies. Its enables the dissection of the interconnections between regional actors, policy tools, and the perceived effectiveness of the risk-related policy. It offers a distinct approach to comprehensively address complex policy problems such as environmental regulations and urban development policies [71]. It provides the policy arena with a way of handling an increasingly complex and uncertain public policy ecosystem by considering processes, relationships, and interrelationships that go beyond linear procedures and isolated interventions to understand real-world complexity [72,73]. Consequently, this paper moves the assessment from a human-centered to a jurisdiction-centered system.

# 4. Main findings and discussions

## 4.1. Dialogue, participation, and cooperation between actors as a driver for an effective risk policy implementation

This section addresses the first part of the risk policy activities assessment [74] related to the regulatory institutions (e.g., Ministry,

<footnote n="17">¹⁷ Pseudonyms (a randomly chosen number) are produced and used for both the interviewees and their entities to guarantee anonymity. In this paper, these pseudonyms are associated with interview quotes and certain analyzed data. Some anonymized verbatims can be made available upon request.</footnote>

<footnote n="18">¹⁸ More on this technique can be found in Appendix B.</footnote>

<footnote n="19">¹⁹ The data was considered saturated when the data collected from the interviewees became redundant, with no emerging or new themes appearing. This conclusion was reached knowing that a diverse range of interviewees is included, as detailed in Table 1.</footnote>

<footnote n="20">²⁰ The difference in the number of interviewees is driven by the relatively simpler legislation arrangement in Victoria with fewer agencies involved and so fewer categories of stakeholders to interview.</footnote>

<footnote n="21">²¹ A system is described as a set of interrelated parts characterized by specific relations with a system boundary [72].</footnote>
<table><caption>**Table 1**
The number of research interviewees for the Normand and Victorian case studies.</caption><thead><tr><th>Stakeholders (Groups)</th><th>Number of interviewees in Normandy</th><th>Number of interviewees in Victoria</th></tr></thead><tbody><tr><td>Operating companies or MHF representatives (e.g., Health, Safety, and Environment (HSE) Managers, Directors, etc.)</td><td>3</td><td>6</td></tr><tr><td>Decentralized State Services, Inspectors, OHS Regulators, or other regulators</td><td>11</td><td>9</td></tr><tr><td>Local authorities or councils</td><td>3</td><td>0</td></tr><tr><td>Others (associations, consultants, etc.)</td><td>8</td><td>3</td></tr><tr><td>Total</td><td>25</td><td>18</td></tr></tbody></table>

DGPR<fnref n="22" />, etc.) and their interactions with the actors implementing the regulations (DREAL<fnref n="23" />, operating companies (OCs), WorkSafe Victoria (WSV), etc.).

In Normandy, based on interviewees' perceptions, the actors mapping (Fig. 5) reveal that the main<fnref n="24" /> actors with whom the DREAL appeared to exchange, include OCs, inter-ministerial department for land and coastal management (DDTM)<fnref n="25" /> on risk prevention plans (PPRT)²⁶, Regional Inter-ministerial Service for Civil and Economic Affairs, Defense and Civil Protection (CIRACEDPC) service of the Prefecture on crisis management aspects, and department emergency services (Sdis)<fnref n="27" /> on emergency exercises. For instance, DREAL-OC, representing the relationship between the control authority and the operating companies in this region, appeared to be one of the key relationships; it seemed to depend on the approach taken by the DREAL, which can be variable depending on several aspects such as the DREAL departmental units practices, the experience of the inspector, and the expertise<fnref n="28" /> of OCs.

The common debate regarding DREAL roles and approaches, especially when it comes to their “role in practice towards and with OCs”, appeared to concern (i) their prescribed and mostly applied role as the environmental police<fnref n="29" /> or sworn officials<fnref n="30" /> and (ii) their expected and appreciated role by some actors as advisors<fnref n="31" /> providing a certain support role. In particular, their police<fnref n="32" /> role focuses on compliance driven by a regalian approach with respect to ministerial decrees, prefectural orders, and so on. This also means that they engage with the OCs to make them understand and comply with the regulations. We have noticed that their expected role as a consultant, which seemed to be likely and appreciated by some of OCs, was described as a role with a more practical approach. While the DREAL interviewees made sure to insist on their avoidance of consulting, they also helped OCs comply with the regulations and stayed loyal to the equity of treatment principle that enforces the same regulations across sites. For instance, one of the inspectors (#30) pointing out these two divergent aspects was quoted in Appendix C.

Additionally, beyond the prescribed roles of DREAL inspectors (Appendix A), their perceived roles, as explained by themselves, appeared to be commonly categorized under (i) file instruction<fnref n="33" />; (ii) inspections-related tasks coupled with a regular exchange with the OCs; and (iii) the communication about their role and their inspections reports and notices to the public. This was especially emphasized after the 2019 LNL fire within the effort to be more pedagogic and enhance transparency, equity of treatment, and openness toward the public. One of the common inspectors' answers about their roles supporting this is detailed in Appendix C.

In Victoria, based on the interviewees' responses, the actors mapping (Fig. 6) explained how WorkSafe Victoria's main interactions appeared to be with MHFs and other regulators such as Environmental Protection Agency (EPA), Energy Safe Victoria (ESV), and Fire Rescue Victoria (FRV) especially through the licensing process of an MHF and on the safety case (SC). Other actors were also mentioned, such as Courts when explaining penal measures, local councils and communities when addressing the urban planning and communication aspects, and multiple actors involved in large-scale emergency plans/exercises such as the emergency services. In particular, WSV-MHF, representing the relationship between the regulatory agency and the major hazard facilities in that State, appears as one of the main key interactions whose quality varies depending on regulators' resources, competencies, and site maturity. For example, some interviewees (including regulators) argued that WSV has sufficient resources and competence in Victoria to do the job,

<footnote n="22">²² DGPR stands for “Direction Générale de la Prévention des Risques” in French. It refers to General Directorate for Risk Prevention.</footnote>

<footnote n="23">²³ DREAL stands for “Directions Régionales de l’Environnement, de l’Aménagement et du Logement” in French. It refers to the Regional Directorate of the Environment, Planning and Housing. It is the current control authority. It includes the inspection services of the classified facilities (IC).</footnote>

<footnote n="24">²⁴ The role of inspection services combined with the roles of OCs and the Prefects appeared central in determining the effectiveness of risk policies as their responsibilities can be translated into each stage of a site's lifecycle, from licensing requests through file instructions, file reporting, site controls, and so on.</footnote>

<footnote n="25">²⁵ DDTM stands for “Direction Départementale des Territoires et de la Mer”. It can be translated to the Departmental Directorate of Territories and the Sea. It refers to the inter-ministerial department for land and coastal management.</footnote>

<footnote n="27">²⁷ Sdis stands for “Service Départemental d'Incendie et de Secours”. It refers to the departmental fire and rescue service or what is commonly known as the fire emergency services.</footnote>

<footnote n="28">²⁸ This was explained by the interviewees as in-house health, safety, and environment management capacities, the sufficient interactions when needed, and the reactive responses when they are solicited by DREAL.</footnote>

<footnote n="29">²⁹ In French, it is “police de l'environnement”.</footnote>

<footnote n="30">³⁰ In French, it is “agent assentement”.</footnote>

<footnote n="31">³¹ In French, it is “conseillé” referring to more supporting or consulting roles that OCs appeared to generally appreciate. This role is also called “un accompagnement”.</footnote>

<footnote n="32">³² The police role in French terms refers to controlling the duties and enforcing them using coercive measures.</footnote>

<footnote n="33">³³ In French, it is called “instruction du dossier”. It is the process related to the licensing of a new site, a modification of its file, or the review of their hazard assessment studies (EDD) after five years or upon certain site changes.</footnote>
<figure><img src="image_7.png" /></figure>

**CGEDD:** The general counsel for the environment and sustainable development of the Ministry of Ecological Transition and Territorial Cohesion.

**CHSCT:** The committee on health, safety and working conditions. CHSCTs were replaced by CSE since January 2020. CSE stands for the social and economic committee. It refers to the social and economic committee that is required for any company that has more than 11 employees. For Seveso establishments, both CSE and CSSCT (health, safety and conditions commission) are mandatory.

**CIRACED-PC:** The regional inter-ministerial service for civil and economic affairs, defense and civil protection service of the Prefecture on crisis management aspects.

**CODERST:** The departmental council for the environment, health and technological risks.

**Prefect:** A high-ranking civil servant who represents the national government at a departmental (dep.) or regional level in France.

**CSS:** The site monitoring committee. CSSs were launched by the Risk Law of 30 July 2003 to encourage discussions and information sharing among the various stakeholders around Seveso upper tier sites.

**DDTM:** The departmental directorate of territories and the sea working. They work in pairs with the DREAL on the elaboration and implementation of technological risk prevention plans (PPRT).

**DGPR:** The General Directorate for Risk Prevention. It operates under the authority of the Ministry of Ecological Transition to ensure the development and implementation of policies, regulations, and strategies related to risk prevention in France.

**DREAL:** The Regional Directorate for the Environment, Planning, and Housing. It is responsible for several services in the region, including the industrial risk service (SRI).

**EDD:** The hazard study. They rely on risk assessment and focus on reducing risks at their source. An EDD includes internal scenarios referring to the scenarios whose consequences are within the site boundary. It also includes scenarios as per the Environmental Code that go beyond the site boundaries. The OC must carry it out for licensing and revisions. It is submitted to DREAL and Prefect for review and supervision.

**ICPE:** The classified facility for environmental protection. Such sites can operate under different licenses such as Environmental Authorization (AE), Declaration (D), or Registration (E) licenses.

**INERIS:** The national institute of industrial environment and risks.

**Orsec:** The organization of civil security responses. An Orsec plan is a tool that manages response to emergencies by minimizing damage and protecting the population in the event of disasters or large-scale incidents.

**PPI:** The external emergency plans or special intervention plans. They concern scenarios where hazards' impacts can go beyond sites. It considers the major scenario. It concerns the off-site crisis management.

**PPRT:** The technological risk prevention plans. They serve urbanization and vulnerability reduction. They include EDD's scenarios that go beyond site boundaries. The funding responsibility is distributed between the State, local authorities, and industry.

**SDIs:** The departmental fire and rescue service. They collaborate with other actors on reviewing plans such as PPI and Orsec plans. They participate in some inspections visits and organize some emergency exercise.

**76:** It is the number of the Seine-Maritime department.

<caption>Fig. 5. Map of the main actors as described by the 25 interviewees in the Normandy Region (source: author's elaboration based on interviews).</caption>
<figure><img src="image_8.png" /></figure>

**CSIRO:** It is a national science organization. It provides support to WorkSafe Victoria by researching new technologies, models, and so on.

**DEECA:** The Department of Energy, Environment and Climate Action. In 2023, the Department of Environment, Land, Water and Planning (DELWP) was renamed to DEECA while the planning functions of DELWP were transferred to the Department of Transport and Planning.

**DELWP:** The Department of Environment, Land, Water and Planning. It created the Major Hazard Facilities Advisory Committee (MHFAC) and updated Victoria Planning Provisions (VPPs) to cope with urban planning around major hazard facilities.

**EPA:** The Environmental Protection Agency. It has a licensing system for higher-risk activities, which was described as a tool to put those sites "higher on their radar" than a low-impact farm as an example.

**ESC:** The Essential Services Commission. It regulates Victoria's energy, water and transport sectors among different aspects.

**ESV:** The Energy Safe Victoria. ESV is responsible for regulating the safe generation, supply, and use of electricity, gas, and pipelines in Victoria.

**FRV:** The Fire Rescue Victoria. They provide written advice and contribution to the assessment of safety cases and licensing processes of major hazard facilities.

**HSE:** Health, Safety, and Environment.

**HSR:** The Health and Safety Representatives. As elected representatives by co-workers, they work on resolving health and safety issues in the workplace and maintaining safe working conditions.

**MHAC:** The Major Hazard Advisory Committee. It can provide advice to WorkSafe Victoria.

**MHF:** The Major Hazard Facility. MHFs are the highest licensing grades in Victoria.

**NOPSEMA:** The National Offshore Petroleum Safety and Environmental Management Authority. They collaborate and exchange information on offshore facilities and pipelines connected to onshore MHFs.

**SC:** The Safety Case. It is based on (i) the demonstration of a safety management system as a comprehensive and integrated management of risk control related to major incident hazards and (ii) the adequacy of risk control measures.

**VCAT:** The Victorian Civil and Administration Tribunal. MHFs can appeal an unfavorable decision regarding a license, a decision, and so on to VCAT.

**WSV:** The WorkSafe Victoria. It is the regulatory agency that includes a Major Hazard Unit regulating around 40 MHFs.

<caption>Fig. 6. A simplified map of the main actors around WSV in Victoria (source: author's elaboration based on interviews).</caption>

while others argued that more resources were needed (#7, 8, 12, 14, 16, 17). In general, despite the well-resourced team, around 2017, it seems that a sense of degradation in the approach of WSV was noticed by some experienced interviewees who witnessed the genesis of WSV and the regulatory system in Victoria. This was attributed to practices that were described as getting further from the intent of Royal Commission recommendations (#16). At the same time, WSV practices have been evolving<fnref n="34" /> throughout the years: in the beginning, some regulators' practices were described as more detrimental due to the perceived "delaying tactics" (#14) by asking the industry for more information. It seems that it represented a difficulty in forming an opinion<fnref n="35" /> in a timely manner (#14). Afterward, this was improved through training and recruitment. This represented an improvement till the past few years when some degradations were noted by two interviewees<fnref n="36" />.

WSV roles were explained and categorized under (i) the Analyst's role especially focused on reviewing SC submissions and checking whether appropriate demonstrations have been made regarding understanding risks and selecting adequate controls, so the risk is reduced SFAIRP<fnref n="37" />. For this, process safety knowledge is described as central; it appears to focus on "risk, prioritization of risk, specialization role as well as competency to do those specializations role" (#7). The role was not perceived as necessarily an enforcement role in terms of issuing improvement notices by emphasizing that "I am a regulator but not an enforcer" (#7); (ii) the inspectors' role

<footnote n="34">³⁴ More on the early licensing rounds is explained by Cooke et al. [59] and Cooke & Sheers [57].</footnote>

<footnote n="35">³⁵ An opinion regarding the SC examination, license decision, etc.</footnote>

<footnote n="36">³⁶ The interview quotes are explained in Appendix C</footnote>

<footnote n="37">³⁷ The general Occupational, Health, and Safety (OHS) duties require a duty holder to protect health and safety, so far as is reasonably practicable (SFAIRP). More on this can be found on the WorkSafe Victoria website</footnote>
appeared to focus on whether companies have done what their safety case said they would do. For this, OHS and process safety knowledge combined were considered both important. The role included the ability to enforce the law as individuals, not only collectively as a team; and (iii) the manager's role with an outreach post achieved through the coordination with stakeholders who are both onsite (e.g., across 40 MHFs) and outside the site (e.g., councils, government, community groups, etc.). This includes interacting with local councils to which they provided advice on MHF's land-use planning matters (iv).

Overall, our interviews highlighted the heavy burden and almost contradictory roles expected to be played by the DREALs, which are constantly changing and expanding [34,67,75,76]. This observation leads us to believe that, in view of what they have to do, their role as a "transmission link" in terms of sharing information between the regional and central levels and between the various actors at the regional level may not be carried out as imagined *stricto sensu* in the regulation. This may give rise to a perception of a lack of information sharing or even a lack of efficiency. On the other hand, for the Victorian case study, the coordination between WSV, ESV, and EPA and the coherence of their legislative boundaries<fnref n="38" /> must be carefully thought out when implemented on MHFs due to their effects on responsibilities distributions among different regulators overseeing safety matters under different angles and approaches. This appeared to require extra collaborative efforts before conducting inspections or when events occur at sites' boundaries<fnref n="39" />.

Therefore, we propose an assessment criterion related to “actors’ dialogue, cooperation, and participation” which appears to be directly related to how responsibilities are perceived and expected to be distributed to ensure an effective implementation of the risk policy. The clarity of the roles and the dialogue among actors allow parties to easily understand what is going on, make it easy for parties such as the public, associations, or non-institutional actors to participate in the process, promote constructive cooperation among key players, assign duties and responsibilities at appropriate levels, and promote responsible<fnref n="40" /> health/environmental citizenship. As explored in Figs. 5 and 6 within this section, we argue that this distribution or dilution of responsibility<fnref n="41" /> and accountability<fnref n="42" /> (both horizontal and vertical accountability as explained in Ref. [77]) among numerous actors can be challenged by the decentralization of the risk policy system and its multi-actors nature. This is while noting that the regulations emphasize that risk prevention is the primary responsibility of the operating companies.

## 4.2. Adaptivity, flexibility, relevance, and coherence of policy tools as main contributors to an effective risk policy

This section reveals another key determinant criterion that was revealed by the interviewees when they described the way they perceive an effective risk policy and the main tools that can promote such effectiveness.

Among the numerous risk policies' tools prescribed by the 2022 Environmental Code in France and the 2017 OHS legislation in Victoria, the main tools used by inspectors are mapped in Fig. 7 for the Normand system and in Fig. 8 for the Victorian system, knowing they are both part of a larger set of global policy tools<fnref n="43" />, including safety cases, emergency plans, and other tools that are not covered by this paper. The importance of these tools was revealed by the majority of the interviewees when they were asked about the main tools that they mobilize and perceive as effective to prevent risks. In practice, interviewees from both case studies recognize the need for practical tools that simplify risk policy implementation and can be quickly updated to reflect real-life changes in sites. Both also appear to evolve around the centrality of hazard studies or safety cases for licensing, monitoring, and enforcement purposes. Cooperative tools, improvement notices, and cooperative relationships appeared to be often favored over so-called “punitive measures”. Both in Normandy and Victoria, the tools that seemed to be most used, cited, and preferred by inspectors included (i) inspections with OCs and (ii) formal<fnref n="44" />/improvement notice propositions. This is besides licenses as a less flexible tool in Victoria.

The efficacy of inspections<fnref n="45" />, often referred to as “the presence on the field” in Normandy, was described as a way to make things advance through exchanges, support, and follow-up. However, some inspectors noted that the increase in inspection numbers to the detriment of the quality of inspections and exchanges with OCs appeared to be counterproductive in some cases. In Victoria, WSV annual inspections were perceived by WSV regulators and inspectors as a tool of certain efficacy in maintaining a high safety level on MHFs. This was attributed to its power ability to detect early signs, as expressed by the following interviewee: “if you're there annually checking on things, you've got more chance of picking it up early before it continues for a period of time” (#16). The scrutiny and knowledge

<footnote n="38">³⁸ Karlene Roberts argues that such places where parts of organizations come together must be thoroughly investigated because many errors can occur at these “interstices” [90]. This aligns with the results of the interviews with some regulators who expressed their concerns and efforts at these boundaries or interstices.</footnote>

<footnote n="39">³⁹ As an example, imagine a major hazard facility that is regulated by WSV and includes pipelines that are regulated by WSV</footnote>

<footnote n="40">⁴⁰ This is also related to the concept of societal cohesion and respect for stakeholders' points of view and values [84,91]. For instance, the extent to which risk policy considers social, economic, environmental, and cultural factors can contribute to social division and exclusion to promote social inclusion, solidarity, and a sense of belonging among individuals and communities within a society.</footnote>

<footnote n="41">⁴¹ Van Der Meer & Edelenbos [77] looked into the balance between what is called institutional accountability (i.e., vertical accountability involving hierarchical relationships with subordinates accountable) and cooperation (i.e., horizontal accountability representing relationships that are on non-hierarchical structures) for multi-actors policy.</footnote>

<footnote n="42">⁴² This also concerns the transparency of evidence provided by these actors to contest certain practices while preserving the learning process, allowing a policy to improve and adapt to its context while also collecting evidence from different entities and actors.</footnote>

<footnote n="43">⁴³ Refer to Tannous & Merad [79] for more insights on the larger set of risk policy tools. Risk policy refers to policies focused on risk prevention and crisis management.</footnote>

<footnote n="44">⁴⁴ In the French system, the formal notice is proposed by the inspector to the Prefect who himself or herself applies sanctions and formal notices to OCs, if needed.</footnote>

<footnote n="45">⁴⁵ Inspections can be driven by both national and regional themes and include different types, such as announced and unannounced inspections. The announced appeared to be usually driven by (i) the license type referring to the required inspection depending on the type of licensed facilities such as “priority establishments”; (ii) national themes determined by the DGPR; (iii) regional themes that emerge from the detected weak signals by the DREAL as explained by several inspectors. There is also the Implementation and Enforcement of Environmental Law (IMPEL) feedback network for all DREAL across France. It consists of a network of authorities responsible, created since 1992, for the application and enforcement of environmental law at Member States in the European Union [92]; and (iv) the complaints from competing OCs or neighboring residents. As for the unannounced inspections, they appeared to be usually conducted within some emergency exercises (POI) context.</footnote>
<figure><img src="image_9.png" /><figcaption>Fig. 7. Main tools related to the DREAL interacting with the main actors (source: author's elaboration based on interviews).</figcaption></figure>

of the inspectors were described as a driver leading MHFs to generally have higher standards than non-MHF facilities through the inspectors' presence on site and their ability to explain the issues when encountered. This was not always perceived as effective by MHFs since, in certain cases, inspectors appeared to be probing what was perceived as less important by the MHF in terms of safety and more focused on compliance (#15). Within the annual inspection report, actions for the site were described as more leaning towards the sites improving their systems to ensure that they do not get non-compliance, so WSV interviewees described that they had a little bit more freedom to give the companies guidance to improve the system. It was also described as a more collaborative way with the site to encourage not doing certain things. Furthermore, in relation to annual checks, apart from their compliance and collaborative roles, they also ensured that all sites were held to the same standard (equity of treatment).

Moreover, in Normandy, formal notices were described as the “habitually used tool” to ensure an effective follow-up and make changes. They are not applied by DREAL directly to OCs. However, DREAL delivers an inspection report and a proposition to apply a formal notice with a due date to the Prefect, who can accept or reject applying this administrative measure on OCs to comply, as explained by a senior inspector. It is, therefore, the Prefect’s responsibility to deliver a prefectorial decree of formal notice<fnref n="46" />. The efficacy of these formal notices is perceived as an easy measure to apply and a guaranteed measure to make things change quickly, as expressed by both an inspector and a safety manager (#1 and 18) (interview quotes in Appendix C).

Similarly, improvement notices in Victoria were described as the most commonly used reactive enforcement tools (Fig. 4) on MHFs for their perceived efficacy in inducing changes in behaviors onsite within a given period. In general, when dealing with MHFs, sites were described as quite mature<fnref n="47" /> sites to use prohibition notices—sites where immediate risks do not usually arise to apply the latter. Hence, other notices are said to be more commonly used, like the improvement notices, for their efficacy and time efficiency in inducing a change. One of the former inspectors explained that (#12) as detailed in Appendix C.

On a more rigid note, representing fewer common cases, in France, the Procurer can take penal measures in case of an offense or a crime following formal notice (administrative measure) that was not respected. One of the common practices applied by some DREALs in Normandy is to always combine a formal notice proposition<fnref n="48" /> with an official document<fnref n="49" /> to leave the freedom<fnref n="50" /> to the Procurer to decide whether to pursue the penal process or wait for the OC to comply. Similarly, some rigid elements were attributed to license revocation in Victoria as licenses were described as “messy to use” but also a “good tool” and “good process”. The messy aspects were attributed to license terms and conditions that might be written in a vague way to avoid certain specificities-related problems and,

<footnote n="46">⁴⁶ This decree is called “arrêt préfectoral d’une mise en demeure” in French</footnote>

<footnote n="47">⁴⁷ A mature site was explained as follows: “[...] the maturity of a site, a really mature site, will actually demonstrate continuous improvement through that process so they're not just giving you the same safety case with the same information, and they haven't really actually modified it. That helps us understand their maturity levels” (#7).</footnote>

<footnote n="48">⁴⁸ This formal notice proposition is commonly referred to as “mise en demeure” in French.</footnote>

<footnote n="49">⁴⁹ This official document is commonly referred to as “procès-verbal” in French.</footnote>

<footnote n="50">⁵⁰ This reflects that, despite the significant prescriptions, local specificities and organizational cultures have an influence on the implementation of certain policy practices.</footnote>
<figure><img src="image_10.png" /><figcaption>**Fig. 8.** Some of the main policy tools for major hazard facilities (MHF) related to WSV interactions with main actors (source: author's elaboration based on interviews).</figcaption></figure>

hence, request some general improvements with no sufficient demonstrations and explanations of how they have improved. If these conditions were not met, licenses were not immediately pulled as the issues must be serious enough to pull a license and cease operation like that; the reason why license conditions and terms were considered "messy to use". The good aspects of licenses were attributed to the capacity to push<sup>51</sup> sites to implement significant changes on time. Some mentioned that some imposed changes might tend to focus more on compliance with regulations rather than necessarily improved safety performance (#12).

Consequently, we propose to consider the criterion of "adaptivity, flexibility, relevance, and coherence" of policy tools for risk prevention at high-risk sites as a key determining condition for an effective policy at regional and State levels. An effective policy appeared to tend to be coherent<sup>52</sup> with its context/circumstances (e.g., site, industry, local conditions, changing knowledge and risk environment, etc.) and its actors' expectations, as was previously demonstrated by Ayres & Braithwaite [78] on "responsive regulation". For this, identifying and learning from past mistakes and others' experiences is one of the information sources that can be integrated into the policy (feedback loops) without compromising its efficiency and efficacy in producing certain impacts and without introducing conflicting incentives. Our mapping of tools related to inspectors, coupled with previous mapping conducted by Tannous & Merad [79] emphasized the centrality of certain tools (e.g., hazard studies (EDDs) and safety cases (SCs)) in determining how other tools (e.g., inspections, interactions, etc.) can be developed to prevent industrial risks. It can also be noticed that the multiplication<sup>53</sup> of

<footnote n="51">51 The role of licenses can be explained as a carrot, rather than a stick.</footnote>

<footnote n="52">52 Nilsson et al. [93] described policy coherence as "an attribute of policy that systematically reduces conflicts and promotes synergies between and within different policy areas to achieve the outcomes associated with jointly agreed policy objectives". The complexity in implementation related to the coherence of intertwined policy tools in France was also examined by Ref. [94]. This is further emphasized in what is called "responsive regulation", where responsiveness "implies not only a new view of what triggers regulatory intervention, but leads us to innovative notions of what the response should be" [78].</footnote>

<footnote n="53">53 Fragmentation and diversification of policy tools make the search for any one source or mode of accountability highly challenging, especially when the command-and-control type of regulations are put in place, as debated by Baldwin et al. [86] and Lascoumes & Le Gales [87]. The preference of some OCs to have more market-based regulations within the AZF period was explained by Bonnaud & Martinais [95]. This is generally coupled with unnecessary, inflexible, and complex rules pushing towards legalism and over-regulation that can strangle industrial competition, managerial freedom, and so on.</footnote>
rigid prescribed tools appeared to push the emergence<fnref n="54" /> of simplified, concise, and flexible tools capable of representing real-life issues in the field and integrating the local practices<fnref n="55" /> and common practices.

Through this section, the tools and actors' interconnectedness reveal some preferences to focus on certain tools perceived as effective due to (i) their flexibility to adapt to local specificities and emerging needs, (ii) their efficacy in inducing behavioral changes at Seveso UT and MHFs, and (iii) their time efficiency in coping with the detected problems. These perceptions depend on contextual aspects that appear to be different or similar in practice in Normandy and Victoria as summarized in Table 2.

One might ask now: what does all of this mean? Is the French Normandy risk policy effective? Is the Victorian risk policy effective? The answer will for sure include “a yes”, “a no”, and “it depends” elements. If we want to explain the two systems in simple terms, we can say that both systems revolve around the demonstration principle manifested through a document/file called a Hazard Study (EDD) for the French Normandy case and a Safety Case (SC) for Victoria. This, in theory, places the primary responsibility of risk prevention on the operating companies (e.g., Seveso UT and MHF). While the French risk regulatory system is commonly referred to as a command-and-control where compliance with specific requirements is central, the Victorian one is considered more goal-based, allowing certain flexibility in implementation. In practice, both systems appear to have some elements of rigidity of compliance against regulations as well as flexibility in implementation, providing advice, encouraging compliance, etc.

Finally, the main components of what determines the effectiveness of risk policy systems as described by interviewees enrich the conceptual thinking behind what makes an effective risk policy and aims to surface the reflections on tradeoffs and uncertainties [35]. It helps in fostering reflections, especially focused on the problem-framing phase [36,41,80] within decision-aid science on risk policies. Just like real-life problems, risk policy's problems are complex: multi-actors, multi-objectives, and multi-criteria- prone to media misinformation; efficiency cannot be the only assessment criterion to consider when addressing a policy that can save lives, prevent accidents, and maintain a vital sector. Therefore, dialogue, flexibility, transparency, and responsibility distributions among different components of an effective risk policy for high-risk sites appeared important by key actors implementing these policies.

## 5. Conclusion

Various risk regulatory approaches can be found in systems rooted in the Civil Law tradition based on “Napoleonic” or “Roman” Law, like in France or the Common Law traditions in Australia. As major accidents and their risk policy assessments do not occur frequently, this study encourages iterative qualitative comparative studies highlighting different components of effective risk policy systems. It unlocks the main “effective” policy tools for risk prevention at high-risk sites as per the interactions between tools and actors.

Overall, Normandy and Victoria share some common ground in their efforts to regulate high-risk facilities based on the quantity of stored chemicals and impose similar responsibilities on operators, including documentation submission, hazard assessment, and incident identification. Both prioritize inspections and enforcement mechanisms to ensure that their legislation and the declared documentation represent the “real-life” application onsite. However, differences related to the regulatory authority structures, documentation requirements, licensing tiers, and actors’ engagement appeared to be significant, reflecting variations in institutional dynamics, governance structure, and legal frameworks between the two systems.

Our findings demonstrated how the effectiveness of high-risk policy systems appeared to be especially conditioned by (i) the dialogue, participation, and cooperation among different actors and their induced responsibilities' distribution within the jurisdiction's risk governance structure; and (ii) the adaptivity, flexibility, relevance, and coherence of policy tools for risk prevention to accommodate for the real-life specificities and emerging needs allowing interventions in a timely manner. We encourage the inclusion of these criteria when assessing the effectiveness of risk policies for their importance in determining the responsibilities distributions among different actors and the policy implementation ease and coherence with respect to field specificities. These criteria constitute two out of more than ten assessment criteria that will be proposed in a comprehensive qualitative policy assessment framework in the future at the science-policy interface [81,82]. Some limitations are related to the methodological choices that relied on qualitative and constructivist approaches and deployed iterative case studies, thematic analysis, and system thinking to assess data and discuss findings. While this can provide a deep understanding of systems, its generalization can be difficult. For this, some more ethnographic case studies approach with sufficient immersion time could help in providing a richer set of data. This was not possible due to the strict three-year period and several delays related to external, budget, and organizational factors that limited field presence. Also, as a continuity to this work, other policy tools for risk prevention, initially explored in Tannous & Merad [79] will deserve a separate study to investigate their effectiveness under this multi-criteria approach.

## CRediT authorship contribution statement

**Scarlett Tannous:** Writing – original draft, Visualization, Methodology, Investigation, Formal analysis, Data curation, Conceptualization. **Myriam Merad:** Writing – review & editing, Supervision, Resources, Methodology, Conceptualization. **Jan Hayes:** Writing – review & editing, Supervision, Methodology.

<footnote n="54">⁵⁴ On tools choice: policy instruments are not value-free or axiologically neutral as they bear values fueled by social interpretations and preferred notions of the mode of regulations [87].</footnote>

<footnote n="55">⁵⁵ These practices appeared to be variable among DREAL departmental units.</footnote>
<table><caption>**Table 2**

Comparative analysis of the risk policy system in Normandy (France) and Victoria (Australia).</caption><thead><tr><th></th><th>Normandy Region in France</th><th>State of Victoria in Australia</th></tr></thead><tbody><tr><td>Main legal text<sup>b</sup></td><td>Environmental Code.</td><td>OHS Regulation and Act.</td></tr><tr><td>Main regulatory approach</td><td>More command-and-control<sup>c</sup> approach.</td><td>More goal-based<sup>d</sup> approach.</td></tr><tr><td>Main responsibility of risk prevention and reduction</td><td>OCs with a relative tendency to head towards a shared form of responsibility.</td><td>MHFs with consistent reminders and practices related to the duty of care.</td></tr><tr><td>Main regulating or controlling entity</td><td>DREAL Normandy (Ministry of Ecological Transition).</td><td>WorkSafe Victoria (WSV).</td></tr><tr><td>Main stakeholders interactions on high-risk sites</td><td>DREAL-OC, DREAL-CIREACEDPC/Prefecture Sdis-OC-DREAL, and DREAL-DDTM.</td><td>WSV-MHF, WSV-EPA-ESV, and WSV-FRV.</td></tr><tr><td>Preferred inspectors' policy tools</td><td>Inspections and formal notices.</td><td>Inspections and formal notices.</td></tr><tr><td>A responsible operating company</td><td>It is called a "serious"<sup>e</sup> site by inspectors.</td><td>It is called a "mature"<sup>f</sup> site by inspectors.</td></tr><tr><td>Main factors determining the effectiveness of a risk policy system as noted by interviewees</td><td>Dialogue and cooperation between implementation actors.<br>Efficiency and efficacy of controlling Authority.<br>Transparency and adequacy of OC practices.</td><td>Dialogue and cooperation between different regulators and MHFs.<br>Adequacy of an independent regulatory agency.<br>Efficiency and efficacy of the regulatory agency.</td></tr><tr><td></td><td>Adequacy and robustness of the regulatory arena.</td><td>Responsibility of a mature MHFs and its leadership.</td></tr><tr><td></td><td>Flexibility and coherence of certain policy tools.</td><td>Efficacy of inspections and notices.</td></tr><tr><td></td><td>Efficacy of inspections and notices</td><td>Coherence and adequacy of the legislative boundaries.</td></tr><tr><td></td><td>Responsibilities' clarity through simpler policy system.</td><td>Equity in treating different sites.</td></tr><tr><td></td><td>Equity in treating different sites.</td><td></td></tr></tbody></table>

## Declaration of generative AI and AI-assisted technologies in the writing process

During the preparation of this work the authors used DeepL in order to translate the interview quotes from French to English. After using this tool, the authors reviewed and edited the content as needed and take full responsibility for the content of the publication.

## Declaration of competing interest

The authors declare that they have no known competing financial interests or personal relationships that could have appeared to influence the work reported in this paper.

## Data availability

Data will be made available on request.

## Acknowledgments

This work was funded by LAMSADE – UMR CNRS 7243 – Paris-Dauphine University – PSL, to whom we are grateful. Our thanks also go to the doctoral school, SDOSE – Management Program, which helped cover part of the expenses of the first author’s fieldwork in Melbourne through an AFMI research grant. We also acknowledge the scientific input inspired by the scientific immersion of the first author at the Dauphine Research in Management (DRM) unit. This study would not have been possible without the valuable contributions and openness of the 43 interviewees in Normandy, France and Victoria, Australia.

## Appendix A. Supplementary data

Supplementary data to this article can be found online at https://doi.org/10.1016/j.ijdrr.2024.104600.

<footnote><sup>a</sup> A mature site was explained as follows: "[...] the maturity of a site, a really mature site, will actually demonstrate continuous improvement through that process so they're not just giving you the same safety case with the same information, and they haven't really actually modified it. That helps us understand their maturity levels" (#7).</footnote>

<footnote><sup>b</sup> It can be noticed that, unlike in France, the Victoria OHS legislation (or Labor Code) is central to regulating high-risk sites, whereas, in France, the Environmental Code is central to regulating major risks, knowing that the Labor Code also plays a role when it comes to occupational risks at these sites.</footnote>

<footnote><sup>c</sup> In simple terms, command-and-control tends to involve laws, regulations, and tools that rely on prescriptive rules backed by some type of sanctions to enforce compliance [86,87].</footnote>

<footnote><sup>d</sup> In simple terms, the goal-based approach infers that operating companies must demonstrate that hazards have been identified and associated risks have been managed appropriately, including that everyone on site understands their roles in major hazard accident prevention. Documentary evidence is provided to demonstrate that (Occupational Health and Safety Regulations, 2017).</footnote>

<footnote><sup>e</sup> To refer to the way the operating company take compliance, safety, and documentation seriously when dealing with their DREAL inspectors.</footnote>
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Scarlett TANNOUS is a PhD degree holder in Management at LAMSADE<fnref n="56" /> - Paris Dauphine University – PSL where she investigated the effectiveness of risk-related public policies, especially focused on high-risk sites in Normandy, France and Victoria, Australia. She also holds a chemical engineering degree, a minor in petroleum engineering, and a master's degree in engineering management. Her research experience encompasses environmental and socio-economic analyses of different energy systems and petroleum equipment.

Myriam MERAD is a Research Director/Professor at CNRS<fnref n="57" /> - LAMSADE at Paris Dauphine University – PSL. She leads research in risk, resilience, and sustainability governance and decisions in security, health, safety, and environment. She is primarily interested in the link between Science and Decision and mainly in expertise framing, regulatory and policy analysis, and participative/deliberative decision analysis.

Jan HAYES is a Professor at the School of Property, Construction, and Project Management at RMIT<fnref n="58" /> University in Australia. She is a former member of the Advisory Board of the National Offshore Petroleum Safety and Environmental Management Authority with more than 30 years of experience in safety and risk management. Her research in organizational accident prevention covers many sectors, such as energy, chemicals, nuclear, and aviation.

<footnote n="56">⁵⁶ LAMSADE stands for “Laboratoire d’Analyse et de Modélisation de Systèmes d’Aide à la Décision” in French. It is the Laboratory for Analysis and Modeling of Decision Support Systems at Paris-Dauphine University – PSL.</footnote>

<footnote n="57">⁵⁷ CNRS stands for “Centre national de la recherche scientifique” in French. It refers to French National Centre for Scientific Research.</footnote>

<footnote n="58">⁵⁸ RMIT stands for “Royal Melbourne Institute of Technology”.</footnote>