Be prepared – 12 months until new COMAH Regulations 2015 come into force
New Control of Major Accident Hazards (COMAH) Regulations will come into force in Great Britain on 1 June 2015. The main COMAH duties will stay the same as now but there are some important changes particularly on how dangerous substances are classified and information that has to be made available to the public. For the first time, lower tier operators will have to provide public information about their site and its hazards. Both top tier (now referred to as upper tier) and lower tier operators will need to provide public information electronically and keep it up to date.
Steps you can take in the next 12 months to help you prepare include:
• Be involved in the consultation – get a good indication of how you may be affected by looking at the draft new COMAH Regulations 2015. Have your say – the consultation closes on 27 June http://www.hse.gov.uk/consult/condocs/cd266.htm
• Check whether your COMAH status is likely to change (in or out of scope, upper or lower tier)by referring to Schedule 1 of the draft Regulations to see the hazard categories and named dangerous substances that are in scope and their quantities, and then compare to your substance inventory. You will need to convert your inventory from CHIP classification to CLP. Guidance on classification is available at http://www.hse.gov.uk/chemical-classification/classification/index.htm
• Be aware that all COMAH operators are likely to have to send a new notification to the Competent Authority (CA) by 1 June 2016; the updated information includes CLP categories of dangerous substances and more detail about site surroundings (draft Regulation 6). More information will follow on this shortly
• Consider what new information may need to be included in major accident prevention policies and off-site emergency plans (draft Regulations 7 and 12)
• Start putting plans in place for your summary of public information that will be provided electronically by looking at what information will be required (draft Regulation 16). The CA is planning to provide an IT system to host this information, more detailed guidance on this will follow
• Review draft Regulation 9 setting out the requirements and timescales for submission of Safety Reports and consider what new information may be required.
• Note that upper tier operators will still have to prepare public information zone (PIZ) information as now (draft Regulation 17).
In the next 12 months the CA will help you prepare by:
• Making guidance available for upper tier operators who are reviewing safety reports before June 2015 on what new information will need to be included after June 2015. If operators chose to, the new information can be included in advance thereby avoiding the need to update safety reports when the new Regulations come into force. This guidance should also be useful for all upper tier operators to indicate what new information will be required
• Publishing a response to the consultation document in Autumn 2014 to say how we will take the new Regulations forward
• Publishing guidance on the new Regulations in March 2015
• Aiming to launch the IT system for public information in advance of the Regulations coming into force.
• Updating the Seveso and COMAH pages on HSE’s website. We will develop the list of FAQs from questions submitted to the email enquiry account Seveso.III.Enquiries@hse.gsi.gov.uk