The Problem
A complex chemical manufacturing site operating under upper-tier COMAH requirements
was struggling to demonstrate that all major accident hazards (MAHs) had been fully
identified and assessed. The root of the issue lay in gaps within the corporate risk
assessment procedures, which were not fully aligned with UK regulatory expectations.
While the client recognised the need for improvement, they were keen to remain actively
involved in the process and were clear that they did not want to replace their existing
procedures entirely.
We were hired because of our active role in the Chemical and Downstream Oil Industry
Forum (CDOIF) technical working group, where we contribute to the development of
COMAH risk assessment guidance and updates to industry approaches in this area.
My Approach
We began by conducting a detailed gap analysis of the client’s existing corporate risk
assessment procedures against recognised good practice for COMAH risk assessment.
Rather than replacing the existing framework, we worked collaboratively with the client to
suggest targeted updates that would align their procedures with UK regulatory
expectations.
To support this, we also proposed a set of bolt-on procedures designed to address
specific gaps without disrupting the broader corporate system. This approach allowed
the client to retain ownership of their COMAM risk assessment process while ensuring
that all major accident hazards could be identified and assessed in line with COMAH
requirements.
The Result
The project achieved the following results:
- Enhanced site competence in identifying and assessing major accident hazards, with tailored guidance without disrupting corporate systems.
- Strengthened the client’s existing risk assessment framework through targeted updates and bolt-on procedures aligned with COMAH good practice
- Developed intelligent customer capability by involving the client throughout the process, enabling them to better understand risk assessment outputs
- Provided a scalable approach that could be applied across other sites and processes within the organisation
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