COMAH compliance requires a range of risk management controls, studies and documentation depending on the tier level and the chemicals that are used or stored within the facility.
It encompasses all aspects of process safety and is intended to be thorough and robust.
Appropriate measures need to be in place to demonstrate that the risk associated with each process and activity has been reduced to a level considered As Low As Reasonably Practicable (ALARP). The demonstration forms parts of the facility’s Safety Report for upper-tier establishments.
A poor approach to the development of your COMAH Safety Report could lead to failure to adequately identify and mitigate risks, which could have severe consequences.
At the very least, a poor submission is often found to omit a number of important considerations and will generate much greater involvement from the Competent Authority (CA), with potential for enforcement notices to be provided.
When assessing a Safety Report, the regulator will select a team of in house specialists to ensure the operator has adequately demonstrated the fundamental aim of the regulations – which is to prevent major accidents and limit the effects of any accidents which do occur.
The Safety Report should therefore be prepared with this same approach, selecting a team of competent individuals who can provide a number of perspectives when evaluating the hazards and controls on site.
Louise Black, Senior Engineer and COMAH Sector Lead at Gexcon UK, explains:
“When operators attempt to prepare the COMAH Safety Report in-house, this often leads to a realisation that the time and effort involved exceeds expectations, as well as not having all the required resources.
“However, the value of strong involvement internally should not be underestimated, an external consultant cannot possess the in-depth knowledge of the processes on-site or fully understand the hazards and hazardous events that can arise.
“A collaborative approach is therefore required, using the on-site team’s knowledge and experience with specialist services from an external process safety provider to bridge the gap between understanding of the process and its hazards, and demonstration of compliance with the regulations. “
Are you Ready?
Complete our COMAH Safety Report questionnaire to see how ready you are.
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