ICPE and responsibilities: operator, owner, manager, shareholder

ICPE regulations use the term "operator". In practice, various players – owner or lessor, manager(s), shareholder(s) – are likely to be involved.

• How do you identify these different people?

• What is everyone's role during operation and on closure of the facility?

• Who is liable to the authorities and third parties?

The legal definition of ICPE refers to "installations operated or owned by any natural or legal person, public or private", thus distinguishing between the notions of operator and owner (to which may be added those of managers and/or shareholders). However, only the operator is subject to the obligations laid down by the ICPE regulations, whether in terms of compliance with operating, closure or rehabilitation requirements.