A site that falls within Lower Tier COMAH must supply basic details to the Competent Authority (full details are given in Schedule 3 of the Regulations).

If a site is entering COMAH because of an increase in the quantity of dangerous substances held on site, notification must be made before the start of construction and/or operation. However, if the site is entering COMAH because of a change in regulations by the Competent Authority, eg change in threshold quantity for a substance, they should submit a notification within three months of the change.

The site must take all measures necessary to prevent major accidents and limit their consequences to people and the environment.

A MAPP is required (Major Accident Prevention Policy). This is usually a fairly short and simple document that sets out the policy for preventing major accidents and details how this is to be achieved. It includes further references to the safety management system that will be used to put the policy into action.

Requirements are much less than for Lower Tier than for Upper Tier.

Hazardous substance planning consent should be applied for separately via the site’s Hazardous Substance Authority (usually part of your Local Authority). If the site is entering COMAH Lower Tier because of changes made by the Competent Authority, “deemed planning “consent” may apply, otherwise the full planning process will have to be gone through.

Useful links to HSE MAPP advice - HSE Information Sheet CHIS3 and Planning information.

For more details, contact Janet on 01422 24 22 22 or email janet@ttenvironmental.co.uk.