Designing, building and operating a facility in line with the COMAH Regulations requires detailed expert knowledge in several areas.
More often than not, clients approach us with an already detailed process design and in some cases having already purchased equipment, only for the HSE to determine the design to be inadequate or the equipment unfit for purpose.
A COMAH submission can be a lengthy and sometimes challenging process. It commonly incorporates various studies and assessments and getting it right the first time is key to smoothly progressing through a submission.
Whilst we acknowledge that some businesses may have the capability to perform a given safety study, the key aspect to back up these studies is experience – something which can often be overlooked.
Every COMAH site is different and experience is crucial in order to ask the right questions and to find answers which are not necessarily found in guidance or regulation.
The studies and assessments for COMAH compliance include:
- Hazard Identification (HAZID) and Hazard and Operability (HAZOP) studies on the process
- Explosion, fire and toxic dispersion modelling
- DSEAR assessments
- Quantitative Risk Assessments (QRA) supported by modelling
- Layer of Protection Analysis (LOPA), and other analyses such as BowTie
Here’s our advice for COMAH compliance success:
- Whether you are in the design, construction or operational phase of your COMAH journey, the relevant Competent Authority must be notified within a reasonable timescale.
- Obtain a Hazardous Substances Consent – This is a planning control which enables the Hazardous Substances Authority (HSA) to make a formed judgement as to whether the quantity of hazardous substance present at the facility will have a detrimental impact on the safety of the community should an incident occur.
- Prepare a MAPP (Major Accident Prevention Policy) – This is your statement on how your processes and safety management procedures in place will prevent a major accident from occurring.
- If you are a Top Tier COMAH site, you need to produce a Safety Report as well as a MAPP. This must detail the management of major accident hazards at your facility, describing what the people, plant and systems do.
Start early
Engaging with a safety and risk analysis partner at the earliest stages of your plans can potentially save you time and expense.
Gexcon can provide support to a COMAH submission from initial application through to lifetime management.
Our aim is to share our knowledge and expertise so businesses and organisations can operate safely.
We combine our in-depth knowledge of past industrial accidents with our experience of similar facilities to identify potential hazards.
For further information or to discuss how Gexcon can support you, please contact us
Useful links: Control Of Major Accident Hazards Regulations 2015 (COMAH) (hse.gov.uk)
