Industry Shake up as changes to COMAH legislation come into force…

New COMAH regulations are now in force (as of 1st June 2015) – meaning that some smaller facilities, not COMAH registered previously, now fall within the COMAH legislation. The changes relate to the types and quantities of substances covered by the regulations, in a bid to prevent those accidents caused by dangerous substances. In fact, some substances now come under COMAH for the first time, as the legislation is aligned with CLP regulations (Classification, Labelling and Packaging of substances and mixtures).

Obviously there will be a degree of initial teething problems as these companies now have to present certain documentation and information relating to the chemicals they store, such as the preparation of a MAPP (Major Accident Prevention Policy), not to mention the initial COMAH registration process, which I understand has to be completed within 12 months.

It seems that storage facilities such as warehouses will be most affected. However in order to keep the amount of new entrants down, tonnage allowances have been increased. Seemingly though, the changes do not only result in new COMAH facilities – the amendments will also cause previously ‘lower tier’ facilities to now be ‘promoted’ so to speak,  to ‘top tier’ status, resulting in more onerous requirements such as frequent safety reports.

Safety must come first…

It is inevitable that there will be some initial problems; however, safety has to be paramount and the new changes must be embraced. There are still far too many accidents caused by mishandling of hazardous chemicals and substances. In my opinion, and I’m sure most will agree, one accident is too many. Some will argue that these changes are unnecessary, and perhaps understandably so with other regulations such as COSHH in force, but surely the amendments to these regulations can only be a good thing. I believe we will see a reduction in the amount accidents/incidents/near misses resulting from mishandling of hazardous substances due to these changes.

Nevertheless, effective Asset Integrity Management may now play a big part on these sites. This will most likely be the case for those sites jumping to the ‘upper’ tier, as they must demonstrate with “objective evidence to the HSE “ that plans are in place to control and manage such things as Integrity and Corrosion with a focus on enhanced safety and reduced risk.

Support is available…

Finally, I think that it is important that these new companies are made aware of resources available to help integrate them to COMAH, such as training courses for employees, and the range of tools and technologies available in order to achieve objective evidence of control where required.

I have included links here to the relative pages on the HSE website detailing the new changes.

http://www.hse.gov.uk/comah/notification/index.htm

http://www.hse.gov.uk/comah/guidance/understanding-comah-new-entrants.pdf

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