Upper Tier COMAH
For Upper Tier COMAH, 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)
- Details of the safety management system that implements the MAPP
- Identification of all potential major accidents including human and environmental consequences
- Risk assessment of potential impacts on human safety and health and also an environmental risk assessment, either as part of the Safety Report, or as a stand-alone document
- 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).
The minimum information required for a Safety Report is given in Schedule 3 of the COMAH Regulations 2015.
The Safety Report is submitted to the Competent Authority (the HSE and appropriate Environment Agency) for assessment and review, and the assessment costs are charged back to the site, instead of there being an application fee as happens with the Environmental Permit regime. Like Lower Tier sites, all Upper Tier sites will also be charged for Competent Authority visits.
Normally, if a site is entering Upper Tier COMAH, the rules on when notification must be made to the HSE are quite straightforward:
- when the rules change to take your site into Upper Tier COMAH, or
- when you increase your hazardous inventory above the Upper Tier COMAH threshold.
However, in the period from 1st June 2015 to 1st June 2016, slightly different rules apply, including a requirement for existing COMAH sites to re-notify. For more details, see our COMAH notification page.
Hazardous substance planning consent should be applied for separately via the site’s Hazardous Substance Authority (usually part of your Local Authority).
TT Environmental can provide help with many of the requirements of Upper Tier COMAH, and advice on sourcing help with other aspects. Our main speciality is the COMAH ERA.
For more details, contact Janet on 01422 24 22 22 or email Janet.