From June 2015 there will be changes to the way major hazard sites are managed in the UK. The Seveso III Directive that was adopted by the European Commission in July 2012 must be implemented by each member state by June 2015. In the UK this is enabled through the Control of Major Accident Hazard (COMAH) 2015 Regulations.
The COMAH regulations were first introduced in 1999 and provide the main piece of legislation that deals with the control of onshore major accident hazards involving dangerous substances. The legislation applies to establishments storing or handling large quantities of hazardous chemicals (as defined in Schedule 1 of the Regulations). Sites are defined as being lower or upper tier depending on the quantities of hazardous chemicals at the site.
The driver for change has been the replacement of the Chemicals Hazard Information and Packaging for Supply Regulations (otherwise known as CHIP) with a Globally Harmonised System (GHS) for classifying and labelling chemicals. CHIP was used to define the scope of COMAH dangerous substances and this will now be replaced by GHS. Furthermore, the European Commission wished to align the directive with the Aarhus Convention that will require operators to share more information with the public.
These changes, however, have not altered the fundamental framework of COMAH, and the application of a risk-based approach for major hazard control is still at the heart of the Regulations. The main changes concern the scope of substances and freedom of information. There have been changes to some of the dangerous substance categories resulting in some substances moving in and out of scope and so impacting what sites are covered by COMAH or the tier they come under. All sites will now also have to make available basic information on their activities and the nature of the potential major accident hazards, their control and emergency response procedures.
Operators will need to familiarise themselves with the changes to ensure compliance and guidance to help them to achieve this is available from the competent authority.
ERM has been helping existing COMAH operators and new entrants to meet the continuing challenges of COMAH compliance. The cornerstone of this has been to work in partnership with them to develop a compliant safety report. We also support operators in gaining an improved understanding of the requirements of the Regulation so that, going forward, they have ownership and the knowledge to defend the report.
A critical improvement of this process is to demystify risk management by promoting a transparent approach from hazard identification, through risk assessment, to identification of safety and environmental barriers and their performance and how barrier performance is managed on site. This enables operators to fully understand the importance of individual safety critical tasks in maintaining barrier performance and the specific role of the barrier in controlling risk.
COMAH operators will therefore need to construct safety reports that present a clear picture of the hazards and risks, both safety and environmental, presented by the site by June 2015 in line with the changes required by SEVESO III. We actively promote the use of these reports, not only for ensuring regulatory compliance but also as a key Process Safety Management tool as part of the overall sustainability programme for the site.
Want to know more?
For further information about COMAH 2015, please contact Suzanne Knights, Principal Consultant in ERM’s Global Risk Practice.