On 1 June 2015 the Manage of Significant Accident Hazards Regulations 2015 (CoMAH) replaced CoMAH 1999, which has now been revoked. The objective of the CoMAH regulations is to prevent key accidents involving dangerous substances – such as a major emission, fire, or explosion – and limit the consequences to folks and the environment of any accidents which do happen. In this short post*, we discover the background to CoMAH, as well as highlighting the crucial modifications you require to be conscious of.
Background to CoMAH
Like a lot of safety regulations, CoMAH was a response to a severe industrial accident. At about 12.30pm on ten July 1976, a runaway reaction occurred in a modest chemical plant close to the town of Seveso in the Lombardy area of Italy. This led to the release of around 1kg of two, 3, 7, eight-tetrachlorodi-benzo-p-dioxin (TCDD) into the atmosphere. It was by far the highest environmental dioxin release to date, contaminating approximately six square miles of soil surrounding the chemical plant. The release killed more than three,000 animals (largely poultry and rabbits). A additional 80,000 were slaughtered to stop the dioxin entering the food chain. No human deaths were attributed to the dioxin release, despite the fact that many men and women fell ill (about 500 instances of the skin illness chloracne have been reported). The monetary price, which integrated a massive clean-up operation, sooner or later rose to about $ 150 million.
The Seveso disaster resulted in a new European Directive on the key accident hazards of certain industrial activities. Adopted in June 1982, Council Directive 82/501/EEC became a lot more frequently recognized as the Seveso Directive right after the town most impacted by the disaster.
The directive, which was later amended in view of the lessons discovered from accidents such as Bhopal, specifically covers these websites manufacturing, employing or handling massive quantities of hazardous substances. At the moment, Seveso applies to much more than 10,000 industrial establishments in the EU.
The all round aim of CoMAH is to make sure that needed measures are taken to avoid and limit the effects of significant accidents involving harmful substances. Under the regulations establishments fall into three major groups:
- Upper tier establishments: related with the highest possible risks (these have been referred to as prime tier internet sites in CoMAH 1999)
- Decrease tier establishments: associated with lower threat but are nevertheless within the scope of CoMAH
- Internet sites which do not fall within the scope of CoMAH
The hazards and amounts of substances on-internet site determine whether or not that web site falls into the scope of CoMAH and, if so, to which tier that web site belongs. Qualifying quantities primarily based on classification are offered in Schedule 1, Portion 1 of the regulations. Some substances are designated as named substances which have diverse qualifying quantities from those of the generic classification. For every of these substances the qualifying quantity is specified in Schedule 1, Component 2 (Element two overrides Component 1).
The primary functions/specifications of the regulations contain:
- Notification: where quantities of hazardous substances on a web site meet or exceed thresholds laid down by CoMAH, the operator need to notify the relevant Competent Authority (CA).
- MAPP: All CoMAH establishments must prepare a Key Accident Prevention Policy. This does not have to go into detail, but is rather a general statement about how the web site will prevent key accidents.
- SMS: all establishments need to have a Security Management System to implement the MAPP.
- CoMAH Security Report: (upper tier establishments only). This is a detailed report of the arrangements in spot to avert and limit the effects of key accidents.
- On-internet site emergency plan (upper tier establishments only). Sites should prepare, evaluation and test an on-web site emergency plan to control, include and mitigate the effects of a key accident.
- Provision of details to be made available to
- Local authorities for off-internet site emergency preparing purposes (upper tier establishments only).
- The public, specifically these most likely to be most impacted by a major accident.
- A neighbouring member state which could be affected by a key accident.
- Other nearby web sites which might themselves have inventories of hazardous substances.
In Fantastic Britain, CoMAH is enforced by the CoMAH Competent Authority (CA), which consists of the Health and Security Executive (or in the case of nuclear internet sites, the Office for Nuclear Regulation) with each other with the relevant regional environment agency. The CA’s part is “to oversee and coordinate the regulation of main hazards in the UK and make certain that the regime operates effectively”.
Principal changes to CoMAH
According to the HSE:
‘Change has been kept to a minimum as far as attainable in producing the COMAH Regulations 2015 to implement the Seveso III Directive. However, there are adjustments that operators and other stakeholders will want to familiarise themselves with.
The Seveso III Directive, and by extension the COMAH Regulations 2015, apply to any business exactly where harmful substances, as set out in Annex 1 of the Directive, are either present on internet site at or above the threshold quantities or could be generated in the occasion of an accident. All sorts of companies with unsafe substances are covered, not just those in the chemical sector.’
The adjustments from Seveso II to III have been summarised right here.
The alterations described in this report may possibly be painful in the short term. Even so, the prospective rewards of this move towards globalisation incorporate a more uniform strategy to overall health and safety and the financial largess of a level playing field.
Provided the complexity of this activity, one particular choice for internet sites may possibly be to get specialist assist. Guidance is also accessible from HSE, which has developed a comprehensive guidance document to the regulations, that can be downloaded for free of charge from the HSE web site.
*This post is an abridged version of an article written by Nick Cook that initially appeared in RoSPA’s Occupational Security & Wellness Journal.
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