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General COMAH Compliance

COMAH 2015

Is your Safety Report ‘COMAH 2015 Compliant?’

On 1 June 2015 the COMAH Regulations 1999 were replaced by the COMAH Regulations 2015. The most significant change affecting COMAH Safety Reports is the alignment with the Classification, Labelling and Packaging (CLP) Regulations. In the majority of cases, the Descriptive Aspects will just need updating to reflect the new classifications; however, you need to be sure that the reclassification has not introduced a new major accident scenario. There are also some changes to the information expected in Safety Reports, and this must be reflected in your COMAH 2015 review.
Other COMAH 2015 changes include the requirement to re-notify to the CA, and there are also changes to the public information requirements.

The Regulations set out clear transition arrangements for updating the content of existing Safety Reports and submitting them to the CA, and the CA has taken a proactive approach to managing the transition.

In order to comply with COMAH 2015, do you have to submit an addendum to your COMAH Safety Report or even completely revise it by 31 May 2016?
The deadline may seem a long way off for a change that can be seen as minor, but an early start is always beneficial as a COMAH review inevitably grows beyond its original scope.

You may take the opportunity to carry out an interim review of your Safety Report in order to reduce the workload at the next 5-year Review stage, or just review your risk assessment to take credit for recent risk reduction initiatives.
Whatever your scope, our extensive COMAH experience can help make the transition as smooth as possible.

Notification

A COMAH Notification is a simple process, but one you need to get right. For existing COMAH sites, have you re-notified for COMAH 2015?

Hazardous Substance Planning Consent

A valid substance consent is an essential part of COMAH compliance – do you have up to date permission to store your dangerous substances?

The hazardous substances consent controls are designed to regulate the presence of hazardous substances so that they cannot be kept or used above specified quantities until the responsible authorities have had the opportunity to assess the risk of an accident and its consequences for people in the surrounding area and for the environment.

These controls ensure that the residual risk to people and the environment is properly addressed by the land use system, which then specifies the type and size of development allowed near to hazardous installations. Similarly, permission to store hazardous substances depends on the development that already surrounds the site, and specific controls can be exercised over the presence of hazardous substances.

Applications are made to the hazardous substances authority (usually the local council), which is required to consult with the Health and Safety Executive and the Environment Agency (and others) and is empowered to grant consent either unconditionally or subject to such conditions as it thinks fit. So the HSE is only a consultee the hazardous substances authority has the final say.

There is now an on-line application form available on the HSE’s website, which makes the application process easier, but does not reduce the amount of work involved. C3 can help you through the process, from deciding how much consent to apply for to advertising and providing information to the public.

Improvement Plan

Prioritising your Improvement Plan can be difficult: Is it risk based? Is it cost effective?

Action Management

Managing COMAH actions alongside a site’s other issues can be complex, but a risk based prioritisation can help.

Following a comprehensive and systematic hazard identification process such as PHA can lead to a large action list being produced, some of which can be minor actions to check data or confirm assumptions, and some can be much more involved. If the PHA is also used to identify additional measures to demonstrate ALARP, this can also add a substantial number of actions to the list.

Here at C3 we have developed several methodologies for categorising and ranking actions, each being risk based and linked to the sites individual hazard profile. When this is combined with the site’s overall improvement plan, you can be sure that the most important actions are being carried out first and that nothing is being missed.

C3 can also provide assistance with managing the action plan and the resulting responses, providing a monitoring service to check responses and tracking any follow up actions.

Intervention Support

We can help you prepare for Intervention Visits, or help you to understand and implement the CA’s requirements in a proportionate way.

Many sites are apprehensive about the CA’s Intervention Visits, usually due to the uncertainty of the approach to be taken and the depth of assessment.

C3 can carry out pre-visit audits to help you prepare, as many people prefer that we ask the awkward questions in advance of the Intervention Visit, allowing any gaps to be filled before the CA arrives. We have also attended numerous intervention visits at the invitation of our clients, either as a back-seat observer or co-leading the visit with the client.

Our experience on other COMAH sites means that we are able to provide a balanced and proportionate view of the visit and any resulting actions. We consider ourselves as an extension of your existing team, complementing it with a wealth of practical engineering experience and the use of simple methodologies that make the complex appear easy.

COMAH Safety Reports

Gap Analysis

Do you want to know how ready you are for COMAH?

The scope of COMAH compliance is vast and covers all aspects of a site and its operations. C3’s COMAH Gap Analysis can help you see where you already meet the requirements of COMAH and where additional work is required.

Our COMAH Gap Analysis methodology is fully scalable based on the size, complexity and risk profile of the site, and our experience with large and small, Upper and Lower Tier COMAH sites means that we can give proportionate and practical advice to help you towards compliance with COMAH.

A COMAH Gap Analysis can be carried out regardless of the site’s existing COMAH status. It can be used to get a site ready for COMAH Notification, or to assess an existing COMAH site against the CA’s current expectations. It can also be used to scope the work required to complete or review a COMAH Safety Report.

Our Gap Analysis tool has also been useful for sites where they have the resource to complete the Safety Report internally: we can assess the existing work and provide guidance on what is needed before submission. We can also provide advice regarding which gaps have to be filled before submission and which can be part of the site’s Improvement Plan.

Safety Report Assessment Manual

The SRAM makes a Safety Report look easy, but how do you know the extent it applies to your site?

The Safety Report Assessment Manual (SRAM) is an incredibly useful document as it outlines the CA’s expectations for COMAH Safety Reports. However, it was written to apply to all Upper Tier COMAH sites across all industries, therefore it can be difficult to interpret how it applies to your site.

C3 personnel have been working within the COMAH regime for 15 years and have written and reviewed a great many COMAH Safety Reports, for sites ranging from those with only a small environmental footprint right up to complex chemical sites with the potential for significant off-site fatalities. In each case the COMAH Safety Report and the required demonstrations are as individual as your own finger print and need to be closely aligned to the site’s risk profile and key risk control systems.

Safety Report Templates

Don’t start with a blank sheet of paper when you can use a C3 template.

C3 consultants have over 15 years of COMAH Safety Report experience, and this has led to the development of a suite of templates for COMAH Safety Reports, containing useful information and references to help with the compilation of the reports.

We can also tailor our templates to your risk profile and Safety Management System, by carrying out a COMAH Gap Analysis, giving you a good start to the preparation of your report. Each COMAH Safety Report is unique and the demonstration of safe operation needs to be closely aligned to the site’s risk profile and key risk control systems.

We can of course write the report for you, but we (and the CA) prefer site’s to write as much of their own reports as possible, as this ensures understanding and ownership of the issues. You can delegate the report writing but you cannot delegate the responsibility!

When we do author some or all of a COMAH Safety Report, we insist in spending time with all key personnel on site to make sure they understand the content of the report.

Peer Review

You write it, we check it.

C3’s consultants are experienced in all aspects of COMAH and can provide peer review services at any stage of your COMAH journey. Once we know a little about your site’s hazards and Safety Management System we can provide practical useful feedback for any documentation associated with COMAH, from an individual procedure or risk assessment, right up to a COMAH Safety Report.

No two COMAH Safety Reports are the same, so when we carry out a Peer Review, particularly for COMAH Safety Reports, we like to get to know your site first, so that we can provide advice and feedback that is aligned to the site’s risk profile and key risk control systems.

Technical Authoring

We can take the pain away, for some or all of your COMAH Safety Report.

C3 personnel have been working within the COMAH regime for 15 years and have written and reviewed a great many COMAH Safety Reports, for sites ranging from those with only a small environmental footprint right up to complex chemical sites with the potential for significant off-site fatalities.

We can write any or all of your COMAH Safety Report depending on your own internal resource availability and technical ability, BUT we will always make sure that the relevant personnel on site validate the content and understand what is written. This ensures understanding and ownership of the issues. You can delegate the report writing but you cannot delegate the responsibility!

A common approach taken by some Upper Tier COMAH sites is to write the descriptive sections of the Safety Report internally, but to outsource the more difficult sections such as the Predictive and Technical Aspects.

Our COMAH Safety Report templates are aligned with the CA’s Safety Report Assessment Manual (SRAM) to minimise the CA’s assessment time, but we can use other structures if required, and will provide a mapping document to the SRAM, as this will be expected by the CA.

Project Management

Don’t know where to start? We can help guide you through.

Each COMAH Safety Report is unique and consequently so is our approach. At C3 we do not have a standard format and approach for each piece of work and will always take the time to learn about your site and its systems in order to provide a tailored solution.

Here at C3 we aim is always to deliver ‘Customer Centered Compliance’, therefore we will provide as much or as little support as needed to compliment your in-house resource availability, capability and budget.

There are many ways in which we can help support you with your COMAH Safety Report, such as:

  • COMAH Gap Analysis
  • Safety Report templates
  • Peer review services
  • Technical authoring
  • Predictive Aspects risk assessment, consequence modelling, etc.
  • Project management
  • Final cross-check and Safety Report compilation and submission

Please see our COMAH home page for other examples.

We have been working with some of our clients through several 5-year review cycles and have continued to support them between COMAH reviews, providing action management and technical support across a wide range of issues.

Safety Report Reviews

A lot can change in 5 years!

C3 personnel have been working within the COMAH regime for 15 years and have written and reviewed a great many COMAH Safety Reports, for sites ranging from those with only a small environmental footprint right up to complex chemical sites with the potential for significant off-site fatalities.

In our experience, most clients are surprised at the extent of the changes required to update their COMAH Safety Report, even if they perceive that very little has changed since the last review. The majority of Upper Tier sites are constantly making improvements to the site, driving the risk profile down, and this needs to be reflected in the COMAH Safety Report. Coupled with the changes in the CA’s expectations for Safety Reports, this can lead to the amount of work being underestimated. So we recommend starting early to scope the work required, maximising the work that can be done internally to minimise the cost.

A key part of the COMAH review process is a review of the risk assessment and ALARP demonstration. A full review of every event in your risk assessment may not be required, and we can help you decide where to draw the line. We will not recommend change for the sake of change, but will provide proportionate advice based on our experience with other sites.

Predictive Assets

Hazard Identification

The identification of major accidents needs to be systematic and must cover normal and abnormal operations.

One of the purposes of a COMAH Safety Report is ‘demonstrating that the major accident hazards and possible major accident scenarios in relation to the establishment have been identified and that the necessary measures have been taken to prevent such accidents and to limit their consequences for human health and the environment’. A key part of this demonstration is the identification of potential Major Accident Hazards (MAH).

There is no right or wrong way to identify MAH under COMAH, and it is not a requirement of the COMAH Regulations 2015 that a quantified risk assessment is undertaken. Sometimes it is sufficient to provide a qualitative ‘description of the possible major accident scenarios and their probability or the conditions under which they might occur’, but usually an approach somewhere between the two is the most appropriate, i.e. a semi-quantified approach, depending on the risk profile of the site.

We have developed our own Process Hazard Analysis (PHA) techniques for identifying and assessing hazards, based on many years of experience with COMAH sites and feedback from the CA. We tailor our approach based on the severity of the potential hazards, and always try to utilise any existing risk assessments.

Consequence Assessment

Extent and severity: who might get hurt and how badly?

Once you have identified your potential Major Accident Hazards (MAH), you then need to provide information on the extent and severity, i.e. who might get hurt and how badly, considering both harm to people and damage to the environment.

C3 personnel have experience in determining the consequences of MAH, using techniques ranging from qualitative descriptions, to detailed dispersion modelling of the events using computerised tools such as PHAST.

Consequence assessment is an important early stage in the preparation of the COMAH Safety Report as it helps you to determine the depth of demonstration needed, i.e. where consequences are minor a limited demonstration to show operations are carried out to current and relevant good practice may be adequate, but where consequences are more severe the demonstration needs to be stronger and will require a demonstration that the risk are As Low As Reasonably Practicable (ALARP).

ALARP Demonstration

ALARP demonstration is not an add-on to a risk assessment; it should be a fundamental part of it.

A COMAH Safety Report for an Upper Tier site needs to contain a demonstration that the risks are As Low As Reasonably Practicable (ALARP), which can be a straightforward exercise if your risks are low, but has the potential to be complicated for high hazard sites or those with few control measures. Some Lower Tier sites have also been required to prepare an ALARP demonstration, and again the complexity can vary depending on the site’s risk profile.

Most risk matrices contain an area where the risks are ‘Tolerable (if ALARP)’. The key word is the ‘if’, as events in this area are only tolerable if they are ALARP, which is why ALARP demonstration is such a key part of COMAH.

At C3 we have developed a simple (spreadsheet based) tool that guides you through the ALARP demonstration process, asking the questions ‘What more could be done?’ and ‘Why have we not done it?’ Where it is not possible to qualitatively accept or reject a potential risk reduction measure, a more quantitative assessment is used based on cost benefit analysis to assess whether the cost associated with the measure is grossly disproportionate.

At C3 we know that there are many ways to achieve the same goal, therefore we will tailor our approach to align with your own existing hazard assessments and risk matrices.

C3 can also help with the initial hazard identification and risk assessment; the identification and screening of potential additional measures; comparison against good practice; and/or prioritisation of any measures that are calculated to be reasonably practicable.

Occupied Buildings Risk Assessment

Being inside a building does not always protect you from the hazards outside.

The location and design of occupied buildings has been a recurring theme since the Flixborough incident in 1974, and there have been many incidents since then such as BP Texas in 2005 that have killed or injured people who were in buildings at the time of the incident.

All Upper Tier COMAH sites need an up to date Occupied Buildings Risk Assessment (OBRA) that includes the impact of fire, explosion and toxic release events (where relevant) on the site’s occupied buildings. Many Lower Tier sites are now also being asked to complete an assessment, as part of their demonstration of safe operation.

All assessments must be completed against the guidance published by the CIA in 2010, which contains baseline data for sites without any specific data for their hazards, and also contains guidance on how the assessment should be applied to permanent and temporary buildings.

A simple hazard-based approach can often be adequate, without unnecessary and expensive detail; but if a more detailed assessment is needed, C3 believe in using existing risk assessments where possible to provide consistency and minimize additional work.

C3 personnel have completed numerous assessments for chemical processing and storage sites, of varying hazards, size and complexity. We can also provide advice on the siting and integrity of toxic refuges, potential modifications to control systems to reduce the vulnerability of control rooms, and civil engineering support for any building modifications that may be required.

Environmental Aspects

CDOIF MATTE Assessment

Environmental risk assessments should be carried out using the CDOIF guidance.

The COMAH Competent Authority considers the CDOIF (Chemical and Downstream Oil Industries Forum) guidance document ‘Environmental Risk Tolerability for COMAH Establishments’ to be a benchmark standard and expects that COMAH sites (Upper Tier and Lower Tier) consider the CDOIF guidance when carrying out or reviewing their environmental risk assessments.

Previous guidance on the tolerability of Major Accidents to the Environment (MATTE) was overly conservative as there was only one level of MATTE, with very low tolerability levels that could be difficult to achieve. The new guidance now sub-divides MATTEs into four levels, A to D, depending on the extent and severity of the incident combined with the duration of harm. Each of these four consequence levels has different tolerability boundaries; two levels are below the single MATTE boundaries from the old guidance.

Although the guidance may seem lengthy and onerous, it could provide financial benefits to many sites due to the more realistic tolerability boundaries that reflect a lower environmental risk. A more accurate and proportionate ERA will result in better informed ALARP decisions; targeting financial resources more effectively, and avoiding unnecessary spend.

Here at C3, we are constantly improving our products and services to meet the needs of our clients and also of the regulators. We have already completed many ERAs using the CDOIF guidance and have also incorporated the guidance into our PHA tools; calibrating our environmental risk matrix against the CDOIF guidance. The CDOIF tolerability bands can then be used during a PHA and/or during any subsequent ALARP decisions. Investing in a CDOIF assessment by C3, before your PHA or ALARP demonstration, can in many cases lead to significant reductions in the size and cost of the subsequent improvement plan.

Firewater Run Off

For any COMAH site, regardless of the substances stored, one of the most significant major accidents can be the release of firewater.

For any COMAH site, regardless of the substances stored, one of the most significant major accidents can be the release of firewater. The firewater can contain combustion products but can also contain significant amounts of unburnt substances, which can be harmful to people or the environment.

This can be particularly important for chemical warehouses, which often contain a diverse mixture of substances, some of which can be COMAH dangerous substances but also other ‘benign’ substances. Even if the warehouse does not contain flammable substances, there are usually lots of combustible materials present and the consequences of a warehouse fire must be considered, as there can be significant impacts to people from radiation or smoke, plus impacts to the environment from the firewater runoff.

The guidance document PPG 28 (Controlled Burn) considers situations where a controlled burn strategy could be used to restrict or avoid the application of firefighting media such as water. However, this strategy could have adverse impacts by allowing or increasing the formation of hazardous gaseous by-products. PPG 28 also states that the protection of people must always take precedence over environmental concerns; therefore a controlled burn may not be appropriate as the impact on people from the smoke plume can be far greater than the impact on the environment caused by contaminated firewater runoff.

C3 can help you to estimate the concentration of substances in the firewater and then help you to estimate the impacts and categorise any potential MATTE using the CDOIF guidance. We can also estimate the contents of a smoke plume, and model it’s dispersion to estimate the potential harm to people from the plume.

Technical Aspects

Safety Report Support

Describing a site’s equipment and safety systems is easy; demonstrating their adequacy and linkage to the site’s major accidents is much more involved.

The COMAH Regulations 2015 require a Safety Report to demonstrate that ‘adequate safety and reliability have been incorporated into the design and construction of the installation’. You should also include a ‘description of the technical parameters and equipment used for the safety of the installations and a description of the equipment installed in the plant to limit the consequences of major accidents’.

The Technical Aspects section of a COMAH Safety Report is assessed by up to 4 different specialists, each having different expectations:

  • Process Safety
  • Mechanical
  • Control and Instrumentation, and
  • Human Factors

The key words for this section are ‘linkage’ and ‘demonstration’. A simple description of the equipment is not adequate; instead the Report must link the equipment and systems to the major accidents identified in the report and demonstrate why it is effective. The section must also show that the equipment and systems conform to good practice as a minimum.

The information in the Safety Report is examined at face value to determine whether the measures meet current good practice AND whether the arguments for not adopting further measures demonstrate that the ALARP principles have been adequately justified and applied. The CA will then carry out Intervention Visits to verify the demonstrations made in the report.

At the core of C3 is a team of hugely experienced engineers, all of who have gained consultancy experience following successful careers in operational and senior management positions on Top Tier and Lower Tier COMAH sites across the UK. This collective experience makes us well placed to help you with the potentially complex demonstrations required to comply with the Technical Aspects of COMAH.

Alarm Management

Alarms need to be identified and categorised, and must require a defined response to an abnormal event, otherwise they are not alarms!

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Asset Integrity

What to inspect, how and when; prioritised and achievable.

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Ageing Plant

The ‘age’ of equipment depends not only on the time in service, but also how it has been operated and maintained.

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Containment

Secondary and Tertiary containment systems are often taken for granted, but can be critical for sites with the potential for significant releases of environmentally harmful substances or firewater.

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Safety Critical Equipment Maintenance

Different approaches can be used to determine what equipment is ‘safety critical’, but once defined, what does it mean?

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DSEAR

Compliance with DSEAR has Hazardous Area Classification at its core, but covers other issues too.

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Functional Safety

Functional Safety covers so much more than just SIL determination and must be applied to both new and existing systems.

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Best Practice

Under the risk based approach to compliance adopted within the UK, meeting the required level of compliance is more fifty shades of grey and then black and white however, one thing that is a ‘given’ is that all COMAH sites are expected to comply with good practice.

For new sites, current good practice must be applied at the design stage, but for existing installations, the HSE expects that duty holders apply current good practice to the extent necessary to satisfy the relevant law.

As UK law requires risks to have been reduced ALARP, HSE will, where the duty-holder wishes to adopt a different approach to controlling risks, seek assurance that the risks are no greater than that which would have been achieved through adoption of good practice and so are ALARP for that different approach.

In circumstances where established good practice does not exist, is out of date or the situation is complex and the relevance of individual good practices is questionable (e.g. high hazard sites), the decision making process on risk reduction action is less straightforward.

The use of Cost Benefit Analysis (CBA) can aid the decision making process by giving monetary values to the costs and benefits and to enable a comparison of like quantities. The analysis can help make an informed choice between risk reduction options.

Demonstration of compliance with good practice is also an integral part of a COMAH Safety Report but many sites struggle to know what is applicable to them.

In all these areas C3 can help you to identify relevant good practice and assess your compliance against it, and ideally before the regulator does!

Management of Change

Modifications of all types must be adequately conceived, designed, installed and tested.

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Permit to Work

Permit to work (PtW) systems are all too often taken for granted, they exist and get audited but few people ever stop to ask “Are they effective?” Well not until after the incident…

The HSE remains focused on ensuring every operator has a robust Permit to Work system in place and failure to do so is likely to cost you dearly not just in £’s but all too often and sadly in people.

C3’s team have over 100 years of combined experience industrial experience and can assist you in reviewing, redesigning and rolling out new systems design to manage the risk posed by the 21st century.

Our team will help you through every step starting with the basics and general principles, through looking at the types of risk assessment your business needs (such as Hot Work / Confined Space / Excavation etc) and if necessary assisting with training and auditing.

C3 believes our strength comes from working with our clients in integrated teams, and our commitment starts from the very first contact. What do we mean, well simply put give us a call or drop us an email and we’ll be more than happy to discuss your specific needs either over the phone or face to face at your site for free.

MAPP and SMS Aspects

Major Accident Prevention Policy

A MAPP need only be a short document, but must be linked to your major accidents.

A Major Accident Prevention Policy (MAPP) is a statement of general intent that should set out your policy on the prevention of major accidents. The MAPP doesn’t need to contain a detailed description of your Safety Management System (SMS). However, it should give sufficient detail to show you have systems in place to cover all the required aspects.

The key to the MAPP is the link to your potential major accidents, to both people and the environment.

Your MAPP must contain your policy setting out your aims and principles of action concerning the prevention of major accidents, and a description of the SMS for achieving these aims. It does not need to be a long document and can refer to other documentation where relevant.

There is plenty of guidance available about the required information, but the trick is linking it to your major accidents and including a proportionate amount of detail. C3’s experienced consultants can help you get the balance right.

Safety Management Systems

A SMS must be proportionate to the hazards, activities and complexity of the site.

A Safety Management System (SMS) is a key part of COMAH compliance and is covered by Regulation 7 of COMAH 2015, which states that:
A safety management system must -

  1. be proportionate to the hazards, industrial activities and complexity of the organisation in the establishment;
  2. be based on assessment of the risks;
  3. include within its scope the general management system including the organisational structure, responsibilities, practices, procedures, processes and resources for determining and implementing the major accident prevention policy.

Most sites already have systems in place for most of the required areas (e.g. roles & responsibilities, training, procedures, etc.), but find that some improvements need to be made to demonstrate the linkage to the site’s risk profile. In C3’s experience more substantial improvements are often required around the topics of: hazard identification and risk assessment; design and modifications of installations; and emergency procedures.

C3 can assist you with all aspects of your site’s safety management system, using our collective knowledge of systems that have been successfully implemented elsewhere. We can also provide good practice audits that generate practical and pragmatic advice for how your systems can be improved.

Key Risk Control Systems

Do you know which of your systems are key to the prevention and control of major accidents?

Over recent years we have seen a shift in emphasis of the UK regulator away from broad high-level audits to more focused and challenging intervention visits aimed at specific areas of good practice. These include an increased focus on Permit to Work, Competency and Management of Change (MoC) to name but a few.

As a consequence C3 has been requested by our clients to assist them in reviewing their core Risk Control Systems as well has helping put in place a sustainable and meaningful suite of Process Safety KPIs.

C3 stands alone amongst our competitors being able to offer a wide range of operational support including the review, audit and where necessary overhaul of your Key Risk Control Systems, because our team includes individuals who have held senior site based roles on Upper Tier COMAH installations and therefore at our core C3 understands the challenges and responsibility operating complex manufacturing sites bring.

Process Safety KPIs

Measuring performance - early warning before catastrophic failure

A guidance document (HSG254 ‘Developing Process Safety Indicators’) has been produced by the HSE and the Chemical Industries Association (CIA), and includes the following paragraph in its abstract, which concisely summarises the aims:

‘Too many organisations rely heavily on failure data to monitor performance, so improvements or changes are only determined after something has gone wrong. Discovering weaknesses in control systems by having a major incident is too late and too costly. Early warning of dangerous deterioration within critical systems provides an opportunity to avoid major incidents. Knowing that process risks are effectively controlled has a clear link with business efficiency, as several indicators can be used to show plant availability and optimised operating conditions.’

Developing Process Safety KPIs must always start with the identification of major accidents and the key risk control systems that are in place to prevent and control them. For each key risk control system a leading and lagging indicator is then developed to provide ‘dual assurance’ to confirm that the risk control system is operating as intended or providing a warning that problems are starting to develop.

C3 consultants have many years of working with key risk control systems, both within consultancy but also as senior managers on Upper Tier COMAH installations, providing a unique perspective on the relevant issues to help you develop a suite of indicators that is relevant and effective.

Competence Management

Ensuring competence involves so much more than just having a training plan.

The majority of Intervention Visits relating to competence follow the CA’s Operational Delivery Guide ‘Inspection of Competence Management Systems at COMAH Establishments’.

The HSE carries out the inspection in two parts:

  • Part A is used to give a broad overview of how the Operator is managing competence and focuses on whether key personnel are achieving the desired outcomes when undertaking critical tasks. It is used where there is direct evidence of competent people undertaking critical tasks in a competent manner, i.e. there is evidence to suggest that the Operator has an effective CMS, is managing and implementing it, and it is delivering desired outcomes.
  • The Part B Inspection is a more in-depth inspection of the management of competence, and is normally only undertaken when the initial Part A Inspection gives rise to concern about the way in which competence is managed. However, a Part B Inspection can also be considered at sites where, from previous regulatory activity, the CA already has significant concerns regarding the management of competence, such as during the assessment of a Safety Report. In such circumstances, it is unnecessary to undertake a Part A Inspection first.

Although the Competence Delivery Guide is freely available on the HSE’s website, it is written to cover a wide range of installations; therefore it can be difficult to know how to apply it to a specific site and its risk profile.

C3 consultants can provide you with a variety of support, ranging from a Human Factors Health Check of your systems against the HSE’s expectations up to the implementation of a Competence Management System.

Lower Tier Compliance

Major Accident Prevention Policy

A MAPP need only be a short document, but must be linked to your major accidents.

A Major Accident Prevention Policy (MAPP) is a statement of general intent that should set out your policy on the prevention of major accidents. The MAPP doesn’t need to contain a detailed description of your Safety Management System (SMS). However, it should give sufficient detail to show you have systems in place to cover all the required aspects.

The key to the MAPP is the link to your potential major accidents, to both people and the environment.

Your MAPP must contain your policy setting out your aims and principles of action concerning the prevention of major accidents, and a description of the SMS for achieving these aims. It does not need to be a long document and can refer to other documentation where relevant.

There is plenty of guidance available about the required information, but the trick is linking it to your major accidents and including a proportionate amount of detail. C3’s experienced consultants can help you get the balance right.

Safety Management Systems

A SMS must be proportionate to the hazards, activities and complexity of the site.

A Safety Management System (SMS) is a key part of COMAH compliance and is covered by Regulation 7 of COMAH 2015, which states that:
A safety management system must -

  1. be proportionate to the hazards, industrial activities and complexity of the organisation in the establishment;
  2. be based on assessment of the risks;
  3. include within its scope the general management system including the organisational structure, responsibilities, practices, procedures, processes and resources for determining and implementing the major accident prevention policy.

Most sites already have systems in place for most of the required areas (e.g. roles & responsibilities, training, procedures, etc.), but find that some improvements need to be made to demonstrate the linkage to the site’s risk profile. In C3’s experience more substantial improvements are often required around the topics of: hazard identification and risk assessment; design and modifications of installations; and emergency procedures.

C3 can assist you with all aspects of your site’s safety management system, using our collective knowledge of systems that have been successfully implemented elsewhere. We can also provide good practice audits that generate practical and pragmatic advice for how your systems can be improved.

Notification

A COMAH Notification is a simple process, but one you need to get right. For existing COMAH sites, have you re-notified for COMAH 2015?

Hazardous Substance Planning Consent

A valid substance consent is an essential part of COMAH compliance – do you have up to date permission to store your dangerous substances?

The hazardous substances consent controls are designed to regulate the presence of hazardous substances so that they cannot be kept or used above specified quantities until the responsible authorities have had the opportunity to assess the risk of an accident and its consequences for people in the surrounding area and for the environment.

These controls ensure that the residual risk to people and the environment is properly addressed by the land use system, which then specifies the type and size of development allowed near to hazardous installations. Similarly, permission to store hazardous substances depends on the development that already surrounds the site, and specific controls can be exercised over the presence of hazardous substances.

Applications are made to the hazardous substances authority (usually the local council), which is required to consult with the Health and Safety Executive and the Environment Agency (and others) and is empowered to grant consent either unconditionally or subject to such conditions as it thinks fit. So the HSE is only a consultee the hazardous substances authority has the final say.

There is now an on-line application form available on the HSE’s website, which makes the application process easier, but does not reduce the amount of work involved. C3 can help you through the process, from deciding how much consent to apply for to advertising and providing information to the public.

Hazard Identification

The identification of major accidents needs to be systematic and must cover normal and abnormal operations.

One of the purposes of a COMAH Safety Report is ‘demonstrating that the major accident hazards and possible major accident scenarios in relation to the establishment have been identified and that the necessary measures have been taken to prevent such accidents and to limit their consequences for human health and the environment’. A key part of this demonstration is the identification of potential Major Accident Hazards (MAH).

There is no right or wrong way to identify MAH under COMAH, and it is not a requirement of the COMAH Regulations 2015 that a quantified risk assessment is undertaken. Sometimes it is sufficient to provide a qualitative ‘description of the possible major accident scenarios and their probability or the conditions under which they might occur’, but usually an approach somewhere between the two is the most appropriate, i.e. a semi-quantified approach, depending on the risk profile of the site.

We have developed our own Process Hazard Analysis (PHA) techniques for identifying and assessing hazards, based on many years of experience with COMAH sites and feedback from the CA. We tailor our approach based on the severity of the potential hazards, and always try to utilise any existing risk assessments.

ALARP Demonstration

ALARP demonstration is not an add-on to a risk assessment; it should be a fundamental part of it.

A COMAH Safety Report for an Upper Tier site needs to contain a demonstration that the risks are As Low As Reasonably Practicable (ALARP), which can be a straightforward exercise if your risks are low, but has the potential to be complicated for high hazard sites or those with few control measures. Some Lower Tier sites have also been required to prepare an ALARP demonstration, and again the complexity can vary depending on the site’s risk profile.

Most risk matrices contain an area where the risks are ‘Tolerable (if ALARP)’. The key word is the ‘if’, as events in this area are only tolerable if they are ALARP, which is why ALARP demonstration is such a key part of COMAH.

At C3 we have developed a simple (spreadsheet based) tool that guides you through the ALARP demonstration process, asking the questions ‘What more could be done?’ and ‘Why have we not done it?’ Where it is not possible to qualitatively accept or reject a potential risk reduction measure, a more quantitative assessment is used based on cost benefit analysis to assess whether the cost associated with the measure is grossly disproportionate.

At C3 we know that there are many ways to achieve the same goal, therefore we will tailor our approach to align with your own existing hazard assessments and risk matrices.

C3 can also help with the initial hazard identification and risk assessment; the identification and screening of potential additional measures; comparison against good practice; and/or prioritisation of any measures that are calculated to be reasonably practicable.

Human Factors

Human Factors in COMAH

The HSE have 10 key topics: how do you know which apply to you?

Human and organisational factors have contributed to the causes of several incidents, in a variety of safety critical industries. There are important lessons for all major hazard industries detailed within the investigate reports, and it is learning such as this that focuses the expectations on COMAH sites.

Many companies, even if aware of ‘human failure’, will still focus on engineering reliability, but it is important not to forget the human element. For example, the assurance of reliability of an alarm in a control room has two parts: firstly there are the engineering aspects such as redundancy, testing etc. However, the human response is equally important to ensure that the operator will always respond in the correct manner, considering factors that may result in an inappropriate response (such as tiredness, distractions, overload, prominence of the alarm indication etc.). Only when such factors are identified and managed can human reliability be assured.

There is a wealth of guidance available, but with so many human factors aspects to consider, it can be hard to know where to start to provide the required ‘demonstration of a structured, systematic approach to managing human performance’.

C3’s human factors experience has been gained working on high hazard sites that are regulated under COMAH. We can therefore provide proportionate practical tailored solutions that are directly linked to your hazard profile.

Other relevant topics:

  • Competence Management
  • Critical Procedures
  • Human HAZOP
  • Identification of Critical Tasks
  • Alarm Management
  • Organisational Change

Competence Management

Ensuring competence involves so much more than just having a training plan.

The majority of Intervention Visits relating to competence follow the CA’s Operational Delivery Guide ‘Inspection of Competence Management Systems at COMAH Establishments’.

The HSE carries out the inspection in two parts:

  • Part A is used to give a broad overview of how the Operator is managing competence and focuses on whether key personnel are achieving the desired outcomes when undertaking critical tasks. It is used where there is direct evidence of competent people undertaking critical tasks in a competent manner, i.e. there is evidence to suggest that the Operator has an effective CMS, is managing and implementing it, and it is delivering desired outcomes.
  • The Part B Inspection is a more in-depth inspection of the management of competence, and is normally only undertaken when the initial Part A Inspection gives rise to concern about the way in which competence is managed. However, a Part B Inspection can also be considered at sites where, from previous regulatory activity, the CA already has significant concerns regarding the management of competence, such as during the assessment of a Safety Report. In such circumstances, it is unnecessary to undertake a Part A Inspection first.

Although the Competence Delivery Guide is freely available on the HSE’s website, it is written to cover a wide range of installations; therefore it can be difficult to know how to apply it to a specific site and its risk profile.

C3 consultants can provide you with a variety of support, ranging from a Human Factors Health Check of your systems against the HSE’s expectations up to the implementation of a Competence Management System.

Identification of Critical Tasks

Safety Critical Tasks should be closely linked to a site’s potential major accidents – do you know what yours are?

According to the Safety Report Assessment Manual; ‘A human action is Safety Critical if either its failure could cause or contribute substantially to a major accident, or its purpose is to prevent or limit the effect of, a major accident’.

Safety Critical Tasks are generally categorised into the following groups:

Operational Tasks:
Human Error Initiation

Actions that have the potential to initiate an event sequence, e.g. inappropriate valve operation causing a loss of containment.

Intervention Actions

Actions required to stop an incident sequence, e.g. activation of ESD system.

Maintenance Tasks:
Escalation Prevention Actions

Actions that may escalate an incident, e.g. inadequate maintenance of a deluge system.

Some sites will instinctively know some of their Safety Critical Tasks, but you need to be able to demonstrate that you have identified all of them. C3 can help you to identify your Safety Critical Tasks by applying a systematic screen to your existing PHA to identify tasks in each of the three categories listed above. We can then help you to analyse the potential for failure using our Human-HAZOP methodology.

Human Hazop

The potential for human error cannot be eliminated, so must be managed.

Human-HAZOP is a Risk Control System (RCS) used to ensure that appropriate controls are in place to manage the performance of humans engaged on Safety Critical Tasks so as to prevent, control and mitigate major accident hazards (MAH).

C3’s Human-HAZOP methodology has been tried as tested on numerous Upper Tier and Lower Tier sites, receiving positive feedback from the CA as it aligns with the guidance within the HSE’s Human Factors Toolkit. The methodology can also be adapted to suit the proportionality of the site and its risk profile: including enough detail to provide the right outcome but not necessarily including all the layers of assessment detail that would only be required for industries such as rail and nuclear.

Our methodology begins with a walk-through / talk-through Task Analysis. For any failures that can result in significant consequences, a detailed Human Reliability Assessment is carried out, which includes identifying and optimising the Performance Influencing Factors (PIF).

We also provide training and mentoring to allow site personnel to carry out future assessments in-house, and can also help with the follow-on work around the relevant procedures, training and competence management.

Critical Procedures

Procedures are used to minimise errors, and should therefore be managed like any other Risk Control System.

Operating procedures may not be the best way of controlling hazards, at least not as the sole defence against human error. Problems with procedures are linked to numerous incidents and frequently cited as one of the causes of major accidents. The inadequate management of procedures have not only contributed to disasters such as Bhopal, Piper Alpha and Clapham Junction, but also to fatalities, personal injuries and ill health. The main causes are too much reliance placed on procedures to control risk, a failure to follow safe working procedures or the use of inadequate procedures.

Procedures may include step-by-step instructions, checklists, decision aids, diagrams, flow-charts and other types of job aids. There must be a system for managing procedures, covering how they are generated and reviewed, and the development of procedures should be informed by appropriate risk assessment such as Human-HAZOP. Participating in the risk assessment is also a good method of ensuring that the user is involved, which is important to ensure their buy-in.

C3 can help you to identify your Safety Critical Tasks and Procedures and carry out a Human-HAZOP to ensure that the procedure is appropriate, fit for purpose, owned, up to date and above all – used!

Alarm Management

Do you know how many alarms you have? Are they really alarms, or just alerts?

Read more

Organisational Change

Changes to an organisation should be managed as carefully as changes to equipment.

Organisational changes such as reducing staffing levels, using contractors or outsourcing, combining departments, or changes to roles & responsibilities are usually not analysed and controlled as thoroughly as plant or process changes. Such changes can, if inadequately conceived or implemented, have a detrimental effect on safety. Even subtle changes to organisations can have significant impacts on the management of hazards.

C3 can help you to carry out an Organisational Change Risk Assessment in order to identify and assess the direct and indirect effects of a proposed change.