When is QRA Required for Your Facility?

If you store or handle large amounts of hazardous substances, at some point the law expects you to do a full Quantitative Risk Analysis (QRA), not just a simple risk matrix.
This article gives you a quick way to answer one question: "Do we need a QRA for this site or project?"
We cover:

• Legal triggers in the MHI Regulations 2022 and SANS 1461.
• Threshold quantities for common South African substances.
• Situations where QRA is requested even if you are below thresholds.
• Typical screening and QRA costs in Rand.

1. The Regulatory Trigger: Threshold Quantities

The primary trigger for a QRA is the quantity of hazardous substances you have on site. The MHI Regulations 2022 contain a schedule of substances with specific Threshold Quantities.
If you store or process a substance at or above this quantity, you must conduct an MHI Risk Assessment, which under SANS 1461:2018 means a full QRA.

Common Threshold Quantities in South Africa

Aggregation Rule

If you have multiple hazardous substances, you may still trigger MHI status even if each individual substance is below its threshold. The regulations use an aggregation formula:

Sum of (Quantity held ÷ Threshold quantity) for each substance
If this sum ≥ 1, you are classified as an MHI and require a QRA.
Example: A site with 30 tonnes LPG (60% of threshold) and 60 tonnes ammonia (60% of threshold) = 1.2, which triggers MHI status.

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2. Land Use Planning & New Developments

Even if you aren't an existing MHI, you might need a QRA if you are planning a new development involving hazardous materials.

Environmental Impact Assessments (EIAs)

The National Environmental Management Act (NEMA) requires EIAs for listed activities. If your project involves hazardous substances, the competent authority (DFFE or provincial department) may require a Major Hazard Risk Study as part of the EIA.
This study typically includes:

• Hazard identification.
• Consequence modelling (fire, explosion, toxic release).
• Risk contour mapping.

Municipal Town Planning

Municipalities need to know the "sterile zones" or Risk Contours around a new plant to approve zoning. In metros like Johannesburg, eThekwini, and Cape Town, the planning department may request a QRA before approving:

• Industrial rezoning applications.
• Building plan approvals for facilities near existing MHIs.
• Subdivision of land adjacent to hazardous installations.

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3. Encroachment of Residential Areas

Sometimes, the facility hasn't changed, but the neighbours have.
South Africa's rapid urbanisation means informal settlements and housing developments often encroach on industrial areas. If a housing estate, mall, or school is planned near your existing facility, local authorities may request a QRA to ensure the new development isn't being built inside your "danger zone."

Real-World SA Examples

• Secunda: Residential areas near Sasol's petrochemical complex require ongoing land-use management.
• Richards Bay: Port and industrial expansion has created tension with nearby communities.
• Johannesburg South: Fuel depots in Alrode and Wadeville face encroachment from mixed-use developments.

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4. The 5-Year Review Cycle

Under the MHI Regulations 2022, existing MHIs must reassess their risk every 5 years or whenever there is a significant change, such as:

• New process units or storage tanks.
• Increased inventory of hazardous substances.
• Changes to surrounding land use (new sensitive receptors).
• Significant incidents or near-misses.
  If your last QRA was done before 2020, you are likely due for an update.

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5. Voluntary QRA: The "Best Practice" Approach

Many top-tier companies conduct QRAs even when not strictly required by the MHI regulations. Why?

• Asset Protection: A QRA quantifies the likely financial loss from a fire or explosion, supporting capital allocation for risk reduction.
• Insurance: Insurers (especially international underwriters) often offer better premiums to facilities that can scientifically demonstrate their risk profile.
• Corporate Governance: Boards and audit committees want to know the "worst-case scenario" in numbers, not just colours on a matrix.
• Lender Requirements: Banks and development finance institutions (e.g., IDC, DBSA) may require QRA evidence before financing large industrial projects.

SA Companies That Routinely Conduct QRAs

• Sasol (Secunda, Sasolburg)
• Engen, Astron Energy, TotalEnergies (refineries and depots)
• AECI, Omnia, Sasol Chemicals (chemical manufacturing)
• Anglo American, Sibanye-Stillwater, Gold Fields (mining with bulk cyanide/ammonia)
• Tiger Brands, RCL Foods, Clover (cold storage with ammonia refrigeration)

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6. The Notification Process

If your QRA determines that you ARE a Major Hazard Installation (i.e., your risk contours extend beyond your fence line), you must:

1. Notify the Department of Employment and Labour – submit your MHI Risk Assessment report to the Chief Inspector.
2. Place an advertisement in a local newspaper – inform the public of your MHI status.
3. Notify your neighbours – provide information on the hazards and emergency procedures.
4. Register on the national MHI database – the Department maintains a register of all MHIs.
   Failure to notify is an offence under the OHS Act and can result in fines or prosecution.

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7. Screening Assessment: A Low-Cost First Step

If you're unsure whether you trigger the MHI regulations, a Screening Assessment is a cost-effective way to find out.

What's Included?

• Review of your hazardous substance inventory against threshold quantities.
• Aggregation calculation if multiple substances are present.
• Desktop review of site layout and surrounding land use.
• Written opinion on MHI status and recommended next steps.

Typical Cost

A screening assessment typically costs R15 000 – R40 000 depending on site complexity. This is a fraction of a full QRA and gives you certainty about your regulatory obligations.

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Conclusion

If you are handling bulk hazardous chemicals, relying on a simple qualitative risk matrix is likely insufficient and potentially illegal under South African law.
Key triggers for a QRA:

• Exceeding threshold quantities (single substance or aggregated).
• New developments requiring EIA or municipal approval.
• Encroachment of sensitive receptors near your facility.
• 5-year regulatory review cycle.
• Corporate governance, insurance, or lender requirements.

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Unsure If You Need a QRA?

MMRisk offers a Screening Assessment to review your inventory against the legal thresholds and advise if a full QRA is required. It's a low-cost way to ensure you aren't operating illegally.
Screening Assessment: R15 000 – R40 000
Full QRA: R150 000 – R1 500 000+ (depending on complexity)
Contact us to schedule your screening today.