Previous incidents in the process industry are reminders of the need to understand the potential of Major Accident Hazards and the underlying risk control measures. As we have seen the consequences of major accidents, if they do occur, can be catastrophic both for the site and sometimes the surrounding population. Here in the UK, assessment and management of such sites are covered by The COMAH Regulations (2015), applied where dangerous substances are processed, stored, or could be generated by loss of control.
For sites that are new to COMAH for example battery manufacturing, green Hydrogen production or Carbon capture and storage projects there will be many questions, particularly where the company does not have a strong capability in process design and “major hazard” risk assessment (major fires, explosions, toxic releases, etc.). Typical areas of concern are likely to include:
- Does COMAH apply to the site, is this at Lower or Upper tier?
- Could better inventory management change the tier?
- When does the Safety Report have to be submitted?
- How much work is involved in preparing the Safety Report?
- Is extensive quantification required to determine the risks?
- What environmental aspects need to be addressed under COMAH, and how?
- How do we demonstrate that ‘all necessary measures’ to control risks have been taken?
- Will meeting COMAH require an expensive improvement programme?
- Is the Safety Management System adequate to meet the requirements of COMAH?
- How do we liaise with the local authority for emergency planning?
- How do we handle public disclosure of the information in the Safety Report?
At ESR Technology we have been providing support to both Operators and The Regulator for COMAH related assessment and activities for decades.
Our advice is based on over 40 years of experience of working in Major Hazards risk assessment across many industries, including working extensively with The Health and Safety Executive, giving us a unique insight into what is required in COMAH support and submissions.
Whether you are a company submitting your first COMAH notification, or approaching a periodic COMAH review, ESR Technology can offer support through:
- The type, depth and breadth of information required by the Regulator
- Assistance with the COMAH notification, Hazardous Substance Consent, Major Accident Prevention Policy (MAPP) and Safety Report for top tier sites
- Our understanding and experience of current HSE ‘hot topics’ and the latest developments and approaches to major hazards
- Safety Report gap assessment against the latest requirements
- Post-submission support to handle ‘further information’ requests
ESR Technology offer a tailored approach to COMAH based on carrying out a preliminary assessment to determine the level of analysis required for a specific site, followed by a systems review and risk assessment to determine the potential major accidents and associated consequences, frequency, and impact both on and off-site. The measures in place are reviewed to determine whether they are adequate to ensure that ALARP principles can be demonstrated or that Best Available Techniques have been applied for environmental risks.
This structured approach ensures that costs for improvements are minimised and that, where necessary, they are clearly justified on the grounds of providing cost effective risk reduction. Following Safety Report submission, ESR Technology personnel are able to offer operations and regulatory experience in assisting in understanding and responding to HSE Specialist Inspector queries and ‘legal actions’ following Intervention visits.
If you would like to know more about how ESR Technology can support you with your COMAH needs please visit https://esrtechnology.com/safety-risk/what-we-do/consultancy/comah-support/ or contact info@esrtechnology.com.