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