This year, a keenly anticipated new guidance on risk assessment is due to be published by the Chemical and Downstream Oil Industries Forum (CDOIF) titled ‘Understanding Major Hazard Human Harm Risk Assessment (MHHHRA) for COMAH ‘. At RAS, we have been involved in the development of this guidance, and we are spreading the word across the industry to ensure they are prepared and informed on how it will affect them.
The new guidance will apply to all COMAH operators from simple storage facilities through to complex chemical processing – are you ready?
Why was the guidance created?
This guidance has been in development since 2021 by the CDOIF Risk Assessment Working Group which comprises of representatives from industry and the regulator. The production of the guidance reflected a lack of existing published good practice and an inconsistency of approach across various high hazard sectors and within the regulatory enforcement by the COMAH Competent Authority.
The intention is that once published, the guidance will establish industry good practice on risk assessment and act to promote consistency of approach to the assessment of major hazards and providing operators, third parties and regulators with a common agreed methodology contained in a single reference.
What is in the guidance?
The guidance provides a structured approach to MHHHRA based on good practice across industry, splitting it into 4 main sections: the identification of major accident hazard scenarios, analysis, assessment, and the ALARP demonstration. Each section is then further broken into its guiding principles and a suggested methodology to achieve industry good practice.
It provides a framework for the operator of a COMAH establishment, or their risk assessment practitioner, to undertake a suitable and sufficient risk assessment of major accidents under the COMAH regulations. The guidance is adequately detailed to act as a practical guide to support the application of best practice across industry and provides worked examples of how to apply the suggested approach.
Applying the methodology outlined in the CDOIF guidance, will ensure that major accident hazard scenarios are given sufficient scrutiny and that risks are managed to level that is As Low As Reasonably Practicable. The MHHHRA guideline is applicable to preparing a risk assessment from scratch, or when reviewing and updating an existing assessment.
Current status
This new guidance applies to everyone and we encourage you to engage with the consultation process for this key new reference to make sure your views are heard. The best way to do this is via your relevant industry body, trade association or by contacting the CDOIF working group directly.
Once the consultation process is complete, it is anticipated that the MHHHRA guidance will be updated to reflect the comments received and then published later in 2026. Once published, the new guidance will stand as an established checkpoint for good practice and, therefore, there will be an expectation from the regulator to meet the guidance.
Are you ready?
To comply with the new guidance will not mean to start from scratch. We suggest using a gap analysis to review your current compliance against the guidance, to illustrate the work that would need to be done to meet the established good practice. Due to the level of detail in the MHHHRA guidance, it is not anticipated that compliance will happen overnight. It will be a longer term process of gradually working towards the good practice in a pragmatic way that makes sense for your operations and your unique risk profile.
How we can help
RAS have been involved in developing the new CDOIF guidance and therefore, we are already familiar with the content, and we have practical insights from trialling the guidance across a range of different facilities. We can support you with checking where you are now and what you need to do next to meet the guidance.
If you would like to get in touch, please email us at enquiries@ras.ltd.uk or go to our website: ras.ltd.uk.
