Are you managing your risks?
For facilities handling dangerous substances, few regulatory frameworks are more important than those designed to prevent and mitigate major accidents.
In the UK, this is governed by the Control of Major Accident Hazards (COMAH) Regulations. Similar major hazard regulations apply across Europe and internationally, including the Seveso III Directive.
However, the obligations placed on operators are often underestimated until an issue occurs.
What does COMAH mean for your site?
COMAH regulations apply to sites that store or use dangerous substances above defined thresholds. Sites are classified as either Lower Tier or Upper Tier, with Upper Tier sites subject to the most stringent requirements.
These sites handle dangerous substances in quantities that could lead to major accidents. These include fires, explosions and toxic releases. Such events can cause serious harm to people, property, and the environment.
“Managing a major hazard site requires a structured approach to process safety that goes beyond routine health and safety management".
Seona Turner.
Key COMAH requirements include:
- Implementing a Major Accident Prevention Policy (MAPP)
- For Upper Tier sites, maintaining a Safety Report accepted by the Competent Authority
- Identification of major accident hazards and ensure residual risks satisfy risk tolerance criteria through appropriate safeguards
- Maintaining an on-site emergency plan and provide information to support local authority off-site emergency planning
- Demonstrating that Safety Instrumented Systems (SIS) and other protection layers meet required integrity levels
- Managing ageing assets and infrastructure where original design documentation may be lacking
- Keeping pace with regulatory changes and Competent Authority expectations
- Maintaining sufficient process safety competence and capability
The cost of getting it wrong
Failure to meet these obligations can have consequences far beyond regulatory penalties. A major incident may result in fatalities, serious injuries and environmental damage.
Sites may face enforcement action, prohibition notices or prosecution. The commercial and reputational impact can also be severe and long lasting.
In addressing these requirements, a Process Safety Management system must be regularly reviewed and maintained to remain effective.
Key elements include:
- Up-to-date Process Safety Information
- Hazard Identification and Risk Assessment
- Operational Control, including SOPs
- Preventive Maintenance
- Management of Change
- Training and Competence
- Emergency Response Planning
"Whether operating under COMAH or equivalent major hazard regulations elsewhere in the world, the fundamental objective remains the same: preventing major accidents and protecting people, assets and the environment".
Seona Turner
Head of Process Safety, UK
