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SAFETY
Towards
COMAH 2015
Fifteen years on, the UKs COMAH regulations are
getting a facelift. Rachel McCann outlines the
main changes and their implications
COMAH 1999
at a glance
COMAH 1999 and its amendments
2005, is the enforcing regulation within
the UK of the Seveso II Directive the
main piece of EU legislation that deals
specifically with the control of onshore
major accident hazards involving
dangerous substances. The regulations
apply to any establishment storing or
otherwise handling large quantities of
industrial chemicals of a hazardous
nature. Types of establishments
include chemical warehousing,
chemical production facilities and
some distributors.
The regulations operate on two
levels lower tier and upper tier,
determined by inventory.
Lower-tier facilities must document a
major accident prevention policy.
Upper-tier facilities must produce a
full safety report which demonstrates
that all necessary measures have been
taken to minimise risks posed by the
site with regard to the environment and
local populations.
Penalties for unauthorised storage
can be severe and companies
unsure of whether or not the COMAH
regulations apply to them should seek
advice from trade associations and
local health and safety inspectors.
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SAFETY
differences between
COMAH 1999 and Seveso
III/COMAH 2015
Seveso III has not fundamentally changed
the existing framework for the regulation of
onshore major accident hazards. The key
tenets of identifying sites and applying control
and mitigation measures through a risk-based
system remain the same as do many of the
key duties and requirements. HSE has sought
to minimise the change for operators and
regulators, and much of the new regulations
will look familiar to those familiar with
COMAH.
The two main changes in the new directive
relate to scope and freedom of information.
scope
The scope of Seveso III is defined by the
CLP Regulation which sees some changes in
public information
Seveso IIIs alignment with the Aarhus
Convention (see box) creates new
responsibilities to make information
available to the public and there is an
expectation that the public has a right
to know and to be involved in matters
regarding major hazardsites.
All sites will have to make basic
information permanently and electronically
available. This will include the sites name
and address, a simple summary of the sites
activities, the hazard classification of its
inventories and its principal dangerous
characteristics. All sites will also have to
provide basic information on how the
public will be warned in the event of a major
accident and what action should be taken.
The date of the sites last inspection and
details of where further information can be
obtained will also be made available.
Upper tier sites will also need to provide
general information on the nature of
potential major accident hazards at the site,
including a summary of possible scenarios
and control measures. They must also
confirm that adequate accident response
other changes
In addition to scope and public information,
there are other changes in the proposed new
Regulations to be aware of. These include:
Emergency Plans the new regulations
propose sites that become upper tier under
COMAH 2015 solely through a change
in the CLP alignment (defined as other
establishments) be given 2 years to provide
information to produce their external
emergency plan to the local authority. This
reflects the nature of other establishments
as those where inventories, processes or
major accident hazard scenarios have
not changed and are moving tier through
the transition from CHIP to CLP and the
differences in alignment.
In addition, a requirement not in the
directive is proposed that would compel
Category 1 responders as defined by
the Civil Contingencies Act 2004 (local
authorities, emergency services, primary
healthcare trusts, port health authorities and
the environment agencies) to test external
emergency plans if deemed necessary by the
responsible local authority. This proposal
was raised through informal consultation
feedback which said that the overall efficacy
of testing was being affected by the capacity
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of some parts of the emergency services to
participate. Opinions on this proposal have
been sought via the public consultation.
Domino effects Seveso III adds a further
duty for domino groups to, as far as possible,
cooperate with neighbouring non-COMAH
sites that may be relevant to its major accident
hazard scenarios. A domino group is a group
of sites, identified by the competent authority,
where the hazard profile of one or more sites
and its proximity to other sites could trigger
or exacerbate a major accident scenario. The
competent authority also has a new duty to
provide the domino group with any additional
relevant information, such as regarding
nearby non-COMAH sites that it may hold
under another regime.
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09/07/2014 16:06:48
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