For over 20 years, the storage and handling of hazardous substances in the UK has been controlled under the Control of Major Accident Hazards (COMAH) Regulations. The duties placed upon operators under these regulations can feel onerous, particularly for newcomers to COMAH. By implementing a pragmatic approach, it is possible to reduce the burden of the COMAH regime.
The COMAH regulations were revised significantly in 2015, replacing the earlier 1999 legislation, placing new duties upon COMAH operators. The intention of the COMAH regulations is to minimise the risk posed by hazardous substances to both people and the environment. The level of work to prevent or mitigate the consequences of major accidents caused by dangerous substances is proportionate to the level of risk for the facility.
The requirements under COMAH include performing a robust risk assessment, developing emergency response procedures and preparing a safety report. Operators of COMAH sites must demonstrate that they have taken all measures necessary to minimise the risk of major accidents.
Establishments across the UK have been operating under these requirements for over 10 years and we can all learn from our shared experience in managing the expectations of the legislation.
The COMAH Review Cycle
Within the COMAH regulations there is a requirement to review the management of your risks in line with the principle of continual improvement, considering technical advancement and the latest industry best practice.
For Upper-Tier establishments, they must formally review their safety reports every 5 years, to ensure that they accurately reflect the last information for the facility and the current operational picture.
The burden of performing the review cycle required under COMAH can be minimised by:
Keeping up to date with the latest industry publications and regulatory expectations
Adopting a pragmatic approach to the updates
Summarising and clearly communicating the changes at the facility during the review cycle
Implementing these steps throughout the operation of a COMAH establishment can avoid the last-minute rush before the 5 year deadline.
Latest Regulatory Expectations
When it comes to the evolving expectation of the regulator, the best action you can take is staying ahead of the game. Keeping up to date with the latest advancements in industry will give you an insight into future landscape and enable you to take reasonable steps over a longer time frame to meet expectations when they become industry good practice.
The best way to do this is to actively engage in industry bodies and take part in cross sector information sharing. At RAS, we support a range of different clients across a variety of sectors, participate in working bodies to drive good practice and therefore, we can provide expert advice on the evolving expectations.
A Pragmatic Approach
When updating COMAH compliance documentation, taking a pragmatic approach will streamline with process. We recommend fully reviewing the last iteration and where information has not changed, do not update it if there is no need to.
Consider the material changes at the facility since the last iteration of the documentation and then perform the updates required where necessary, performing a 5 yearly review does not mean starting from scratch.
COMAH reports are an area of particular expertise at RAS, and we provide ongoing support to number of long-term clients throughout their review cycle.
Communicating the Change
Clearly communicating the changes at the facility as part of the review will support the regulator to understand the updates since the previous iteration and focus their attention on the most critical aspects of the review. By working with the regulator and taking them on a journey through the documents, the review cycle will be more effective and there are less likely to be follow up queries from the regulator.
Our Secrets to Delivering a Successful COMAH Study Review
RAS develop a long standing, collaborative relationship with our clients. This creates a familiarity and enables us to seamlessly update documents during a review cycle due to our existing knowledge of the site operations.
This doesn’t mean cutting corners – we always undertake a thorough review with site representatives to ensure we have all the updated information we need. The aim of the review is to ensure that the safety report reflects the current site equipment, systems and operational process.
At RAS we always work on a case-by-case basis and therefore, we develop a bespoke plan that is the right fit for the unique nature of each COMAH operator. We can also advise where there is new guidance available or improvements in industry good practice that you may want to consider moving forward, to ensure that you stay up to date on regulatory expectations.
We support our clients in establishing positive relationships with the regulator, to set expectations, clearly communication changes and streamline the review evaluation process.
About RAS Limited
RAS Limited is a Chester-based process and technical safety consultancy with 30 years of experience across sectors including pharmaceuticals, energy, aviation, and chemicals. With a team of expert consultants, RAS is a trusted partner for managing complex risk in industrial operations and delivering long-term value. If you would like to get in touch, please email us at enquiries@ras.ltd.uk or go to our website: ras.ltd.uk.
