More about COMAH
Regulations
The Control of Major Accident Hazards (COMAH) Regulations 1999 came into force on 1st April 1999. They implement the requirements of the Seveso II Directive, replacing the Control of Industrial Major Accident Hazards (CIMAH) Regulations 1984.
COMAH applies mainly to the chemical processing industry but it also applies to some storage activities, explosives and nuclear sites, depending on the quantities of dangerous substances being stored or used.
The main aim of the Regulations is to prevent and mitigate the effects of major accidents involving dangerous substances, which can cause serious damage/harm to people and/or the environment. The COMAH Regulations treat risks to the environment as seriously as those to people.
Background to COMAH
The background to the introduction of the Regulations is as follows:
- > 1982: European Directive on Major Accident Hazards issued (Seveso Directive)
- > 1984: Seveso Directive implemented in Great Britain under the Control of Industrial
Major Accident Hazards (CIMAH) Regulations
- > 1988: CIMAH Regulations revised
- > 1990: CIMAH Regulations revised
- > 1996: Seveso Directive reviewed giving rise to Seveso II
- > 1999: Seveso II Directive implemented in Great Britain under the Control of Major
Accident Hazards (COMAH) Regulations
- > 2005: Seveso II Directive amended (reclassification/introduction of new substances
plus changes to threshold values)
Summary of Key Aspects
COMAH addresses the entire manufacturing operation rather than isolated areas of plant. As such it is necessary to demonstrate that:
- > All Major Accident Hazards (MAH) have been identified
- > The potential scenarios giving rise to, and the potential consequences of, a major
accident are fully understood
- > A Major Accident Prevention Policy (MAPP) and a Safety Management System (SMS)
for implementing it have been put into effect
- > Adequate safety and reliability have been incorporated into the design, construction,
operation and maintenance of plant
- > The necessary measures to prevent or limit the consequences of major accidents
to people and the environment are in place
- > On-site emergency plans have been drawn up taking into account interaction with
off-site emergency services
The operators of top tier COMAH sites are required to present this information to the Competent Authority (CA) in the form of a safety report.
What Does the Competent Authority look for in a Safety Report?
The first stage in the assessment process seeks to identify significant deficiencies in the content of the safety report. It includes a provisional screening of the predictive aspects to ensure that they have been addressed systematically. This approach came about because many reports failed to satisfy the predictive requirements, and it is more cost effective to the operator and the CA to identify such deficiencies at an early stage in the assessment process.
Assuming all appears to be in order then the report will be deemed good enough to undergo a second stage, more thorough, assessment of its descriptive, predictive, MAPP, safety management systems, technical and emergency response aspects. The second assessment can take considerable time to complete, with the CA’s comments taking several months to come through.
The final stage of the assessment is audit and inspection. This can begin soon into the assessment process and can continue for some time after the safety report has been accepted. One objective is to verify the contents of the report and so it is important that the safety report “tells the truth” about the condition of the establishment and the systems in place.
Common Deficiencies in Safety Reports
In our experience, one of the major difficulties in presenting a satisfactory COMAH submission centres on the ability to develop a clearly structured argument showing a logical progression from identification of hazards through to implementation of the appropriate prevention, control and mitigation measures. This view is supported by the Competent Authority, which has identified a number of common areas of weakness in submissions to date, which include:
- > A failure to demonstrate that a systematic approach has been used to evaluate major
accident hazards
- > A failure to demonstrate linkage between the major accident hazards and the measures
for prevention and control
- > The risk assessment process has often not been sufficiently robust. Also, operators
have failed to demonstrate that the results from the assessment have been used as the
basis for selecting, prioritising and scheduling further risk reduction measures to reduce
the risks to the ALARP level
- > Descriptions of Safety Management Systems have failed to focus on the management
of major accident hazards
- > A failure to show an adequate appreciation of human factors, in particular the part
that human failure can play in initiating major accident and the reliability of safeguards
which depend on human action
HFL Risk Services have developed a methodology to enable the argument to be developed in a systematic and orderly manner. Potential limitations and areas for improvement are automatically captured as part of this approach, aiding improvement planning work, and making efficient use of time and resources.
Our services also include the preparation of re-submissions for those companies unfortunate enough to have had their safety reports returned.
Scoping Studies
Our COMAH scoping study service involves a review of the information that is currently available within the existing management systems together with the systems, standards and procedures relating to the design and continued safe operation of the facility. Generally, a large proportion of the information required for demonstration under COMAH will be contained within this documentation.
The information from the gap analysis is used to generate a “route map” that shows how and where the components of the identified documentation fulfil (or partially fulfil) the requirements of COMAH. This minimises the cost to the client and avoids unnecessary duplication of effort.
HFL Risk Services can provide templates, management services, guidance and peer review services. Alternatively we can prepare the entire safety report, committing as little client resource as practicable, whilst still providing a safety report that is a true reflection of the establishment.
HAZID and Consequence Modelling
A critical stage in the preparation of a COMAH safety report involves the identification of potential Major Accident Hazards (MAH). The hazard identification (HAZID) and screening methodologies used by HFL Risk Services are well established and can be used to generate a document that provides a detailed hazard profile for any given site. Using a series of process hazard analysis software tools, we are also able to analyse the consequences of chemical releases, e.g. to predict the flammable and toxic effects from designed and accidental atmospheric releases.
The extent of the frequency, consequence and risk assessment carried out is different for each COMAH safety report, depending on the scale and nature of the hazards present on site. Qualitative, semi-quantitative or quantitative risk assessment methodologies can be used, and the most appropriate one is chosen to make the required demonstration.
MATTE Reviews
Our experienced environmental consultants can help to address the assessment of potential incidents, which may lead to a Major Accident to the Environment (MATTE), and consider the issues arising from the clean up and environmental recovery of such incidents.
Emergency Planning
Successful Emergency Planning depends on the identification and assessment of all potential scenarios in advance so that appropriate resources can be made available. Using their experience in the process industries, and knowledge of good practice and guidelines, our consultants can assist in the development of a coherent response plan.