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.

For Upper Tier, a Safety Report is required which usually includes:
► A full description of the site, substances stored and handled, the local environment etc
► A policy on how to prevent and mitigate major accidents (MAPP) (shorter than for Lower Tier sites)
► Details of the safety management system that implements the MAPP
► Identification of major accidents including human and environmental consequences
► Information on physical safety precautions, operating and control systems, shutdown systems and alarms, and emergency equipment such as relief systems and fire fighting equipment
► Justification for the types and frequency of testing, maintenance and inspection of mechanical and instrumented systems.
► Information about the emergency plan for the site. This is also used by the local authority for the preparation of an off-site emergency plan.
► A demonstration to show that risks from the installation are ALARP (As Low As Reasonably Practicable).

Hazardous substance planning consent should be applied for separately via the site’s Hazardous Substance Authority (usually part of your Local Authority).

Useful links to the HSE Safety Report guidance and Planning information.

For more details contact Sandra on 01422 24 22 22 or email sandra@ttenvironmental.co.uk.