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.
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.
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.
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.
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.
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:
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.
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.
