COMAH Consultants

Process safety legislation in the UK is predominantly enacted through the Control of Major Accident Hazards Regulations (COMAH) . Operators have a duty to take all measures necessary to prevent major accidents and limit the consequences to people and the environment.  A COMAH site is one where sufficient quantities of Dangerous Substances are stored to exceed the COMAH threshold to become an Upper Tier site or a Lower Tier site. Closely aligned with COMAH is the Planning (Hazardous Substances) Regulations which require an application to obtain permission to store certain quantities of dangerous substances.  

Sites which handle and store dangerous substances therefore need to. 

• Establish if COMAH and the Planning (Hazardous Substances) Regulations apply and, if so. 
• Apply for hazardous substances consent.
• Provide a COMAH notification to the competent authority. 
• Identify their Major Accident Hazard Scenarios. 
• Implement a Major Accident Prevention Policy (MAPP) and Safety Management System (SMS) which ensures that risks are assessed and managed appropriately. 
• Provide the necessary information to the public.
• Emergency planning. 
• For upper tier sites, prepare an off-site emergency plan and a COMAH Safety Report. 

Since UK Health and Safety legislation is based upon goal setting, compliance with the COMAH regulations has a strong link with the principal of As Low As Reasonably Practicable (ALARP). This requires a balance to be struck between the time, effort, resource and costs of improvements versus the risk reduction benefits. Typical challenges are. 

• Sufficiently competent staff who can confidently discuss the subject to the COMAH regulatory authorities. 
• Maintaining organisational competence and corporate memory at all levels of the organisation. 
• Balancing resources with COMAH requirements.
• Understanding the language and terminology used by regulatory authorities. 
• Deciding when risks are sufficiently reduced. 

In 2015 changes to the classification of some dangerous substances had an impact upon the warehouse sector through COMAH 2015. Substances which were not previously covered by COMAH now fell into the regulations and pushed many operators above the threshold quantity levels. This, combined with a shift in the U.K from manufacturing to storage, has placed warehouses into the spotlight for the COMAH regulatory authorities. Key focus area for this sector are.  

• Environmental impact of a fire and subsequent firewater runoff. 
• Requirements for containment of firewater runoff. 
• DSEAR related risk analysis and sufficiency of ventilation. 
• Reliability of fire protection systems.