Lower Tier Compliance

In practical terms, the main difference between Upper Tier and Lower Tier COMAH Establishments is that the former are required to submit a COMAH safety Report and the latter make their demonstration through their Major Accident Prevention Policy (MAPP) and Safety Management System (SMS).   

A Major Accident Prevention Policy (MAPP) is a powerful and important tool in any organisation's commitment to safety. It is a valuable statement of intent, requiring only a concise document to effectively communicate the organisation's dedication to preventing major accidents. The MAPP should clearly link to the site's major accident hazards and provide sufficient detail to demonstrate that all relevant aspects are being adequately addressed. It should also feature a policy that outlines the goals and principles of action for major accident prevention and a description of the Safety Management System (SMS) that will help achieve these goals. Where necessary, the MAPP may refer to other documents for further detail and guidance. In this way, the MAPP serves as an invaluable tool for providing clear and effective guidance for major accident prevention. 

Without the COMAH safety report structure to guide you, it can be difficult to demonstrate compliance. But don't worry - there are several steps you can take to ensure your Safety Management System (SMS) is up to standard. One of the most important is to create a comprehensive Process Hazard Analysis. This will help you identify any Major Accident Hazards (MAHs) and the safeguards in place to prevent them. Remember, MAHs can include events that don't have fatal consequences - so it's important to consider all possibilities when striving for COMAH compliance. 

Are you feeling lost and not sure where to begin? Then a Lower Tier Gap Analysis is the perfect solution for you! This review of the necessary site documentation will establish if the MAPP and SMS cover all the necessary requirements of COMAH, and is of the required quality. 

In addition to the Lower Tier Gap analysis, we offer comprehensive process safety management and Lower Tier compliance services to help organisations reach their safety goals. Our services include facilitating hazard studies, screening for COMAH Major Accident Hazard Scenarios, and assessing risk to ensure it is as low as reasonably practicable. Our in-depth Gap Analysis will provide an overview of the current state of your safety management systems, helping you to identify and address any areas of concern. Investing in process safety management and Lower Tier compliance can help you to attain the highest levels of safety, helping to protect your workers and the environment.