COMAH Deconstructed WEBINAR RECORDING

Summary

In this webinar, Callum Christie and Clive Salas from Decora discuss the essentials of the COMAH (Control of Major Accident Hazards) report, its significance, and how it differs from other safety assessments like HAZOP and Seveso reports. They break down the structure of the report, explaining its six volumes, including the Major Accident Prevention Policy, Safety Management System, Process Description, Hazard Identification, Major Accident Hazards, and Emergency Planning. The webinar also emphasizes the importance of the COMAH report as a 'living document' that evolves with changes in operations, ensuring ongoing safety and compliance in high-risk environments.

Takeaways

• 😀 The COMAH report (Control of Major Accident Hazards) is essential for communicating risks and emergency planning to competent authorities like the Health and Safety Executive (HSE).
• 😀 COMAH regulations differ from other safety assessments like HazOps or Cervezo reports. HazOp is a key part of the COMAH report, while Cervezo is the same as COMAH, just called differently in some countries.
• 😀 A COMAH report must be renewed every five years, but it’s important to continuously engage with emergency services to ensure that the report stays relevant and reflects current risks and resources.
• 😀 The COMAH regulations are divided into two tiers: lower and upper. Organizations must calculate their chemical quantities to determine which tier applies to them.
• 😀 The tier system in COMAH is based on the quantities of hazardous substances on-site, with aggregation of chemicals taken into account to determine the correct tier (lower or upper).
• 😀 The six sections (or volumes) of a COMAH report include major accident prevention policy, safety management systems, process descriptions, identification of hazards, assessment of risks, and emergency planning.
• 😀 Volume 1 of the COMAH report details the Major Accident Prevention Policy, which outlines how the organization plans to prevent accidents, now and in the future.
• 😀 Volume 6 of the report focuses on emergency planning, ensuring that organizations have a clear and agreed-upon plan with emergency services like fire brigades and ambulances.
• 😀 The COMAH report must be a living document, meaning it should be updated whenever there are significant changes to processes, chemicals, or emergency plans.
• 😀 For security purposes, the COMAH report must be protected from unauthorized access, as it contains sensitive information about potential major hazards that could be targeted. Encryption and secure access methods like locked PDFs are common solutions.

Q & A

What is the purpose of the COMAH regulations?

The COMAH (Control of Major Accident Hazards) regulations require organizations to assess and manage the risks associated with handling dangerous substances. The goal is to prevent major accidents and to minimize the impact if accidents do occur, by ensuring companies implement appropriate safety measures and emergency plans.

How is a COMAH report structured?

The COMAH report is structured into six volumes: Volume 1 (Major Accident Prevention Policy), Volume 2 (Safety Management System), Volume 3 (Process Description), Volume 4 (List of Significant Hazards), Volume 5 (Major Accident Hazards), and Volume 6 (Emergency Planning). These volumes outline safety practices, risk assessments, and emergency preparedness.

What is the difference between lower-tier and upper-tier COMAH sites?

Lower-tier COMAH sites have fewer safety requirements and smaller quantities of hazardous substances, whereas upper-tier COMAH sites have stricter regulations, including detailed risk assessments and more comprehensive safety systems due to larger quantities of dangerous substances.

What does a 'living document' mean in the context of the COMAH report?

A 'living document' refers to the idea that the COMAH report should be regularly updated to reflect any changes at the site, such as new chemicals, new processes, or changes to emergency response plans. This ensures the report remains accurate and relevant.

How should companies handle security for the COMAH report?

Due to the sensitive nature of the COMAH report, security is crucial. Two main security methods are used: a 'locked box' (where only authorized individuals have access to the report) and encryption (which requires distributing security keys, though this can reduce security if not managed properly).

What are the primary hazards identified in a COMAH report?

The primary hazards in a COMAH report include major accident hazards (such as fires, explosions, or toxic releases), significant hazards that might not be as severe but still pose a risk, and the various processes and chemicals that could lead to such incidents if not properly managed.

Are flammable aerosols regulated under COMAH?

Flammable aerosols are not typically subject to COMAH unless their total quantity at a site exceeds the specified threshold. The key regulatory factor is the total mass of hazardous substances present, not the volume of individual items like aerosols.

How do COMAH regulations help with emergency response planning?

COMAH regulations ensure that sites with hazardous substances have detailed emergency response plans, coordinated with local emergency services. Volume 6 of the COMAH report specifically addresses these plans, ensuring that there are clear procedures in place to respond to major accidents.

What is the importance of the Safety Management System (Volume 2) in the COMAH report?

The Safety Management System (Volume 2) is crucial for ensuring that the policies and practices described in the Major Accident Prevention Policy (Volume 1) are effectively implemented. It outlines how safety is managed on an ongoing basis, including training, monitoring, and continuous improvement.

How can a company determine if they need to comply with COMAH regulations?

A company must assess whether the quantities of dangerous substances they hold exceed the thresholds set by COMAH regulations. If they do, the company must comply with either lower-tier or upper-tier regulations, depending on the amount and type of hazardous substances on site.