Introduction
Top-tier COMAH sites have to produce a Safety Report, and this unit explains how a COMAH safety report should be developed and identifies the expected contents. It also introduces another important concept: ALARP.
Before you start, it’s important for you to know that when you have completed this short unit, as evidence of your understanding you will be asked to read and review your own site and/or plant COMAH Safety Report.
6.1
The expected features of a top-tier COMAH Site Safety Report
Key elements
Safety Report
For top tier COMAH sites, i.e. those with particularly high quantities of dangerous substances, operators must describe their control measures to prevent major accidents in a Safety Report.
High consequence, low frequency events must be specifically identified and addressed in the Safety Report.
A Safety Report is a document written by the site operator and sent to the Competent Authority (Health and Safety Executive and/or Environment Agency) to demonstrate that all the necessary measures have been taken to prevent major accidents and to limit their consequences to people and the environment.
To write a Safety Report, operators have to look systematically and carefully at how they manufacture, store and use dangerous substances. This helps them to identify any necessary improvements to their management systems, plant, equipment or safety procedures, and so reduce the risk of a major accident occurring.
Operators must also review the Safety Report at least every five years, and also when any changes occur that could have a significant effect on the safety of the site.
The operator must tell the Competent Authority of any changes made to the safety case resulting from these reviews.
6.2
The expected features of a top-tier COMAH Site Safety Report
ALARP
Reasonable and Practicable Standards
An important principle within COMAH is the ALARP demonstration. ALARP stands for: As Low As is Reasonably Practicable An operator of a site must answer these two fundamental questions:
What more could I do to reduce the risk further?
Why have I not done it?
These are always the key questions that the regulator will want answers to.
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For further reading click on the available resources.
6.3
The expected features of a top-tier COMAH Site Safety Report
ALARP
Applying the Principle of ALARP
Let’s look now at how ALARP answers two important questions within Process Safety and operational management.
Why Might you not do something that would further reduce risk
By demonstrating that the amount of resources you would have to invest is grossly disproportionate to the benefits that would accrue.
What Benchmark can be used to determine how low the risk factor should be?
The level of the risk factor should be measured by reasonable and practicable standards.
6.4
The expected features of a top-tier COMAH Site Safety Report
Reviewing your company’s COMAH Safety Report
The tabs below contain important information regarding the task linked to this unit.
Top Tier Top Tier
If you work at a top tier COMAH site you should read and review your own site and/or plant COMAH Safety Report. Once you have done this you should have a good understanding of your operation’s major accident hazard scenarios, the precautions established to manage these hazards, and the residual risk.
Tasks and assessments on later units will depend upon you having gained this understanding.
Lower Tier
If you work on a lower tier COMAH site you should read and review your Major Accident Prevention Policy (MAPP). Although this is a shorter and simpler document than a safety report, it must still define the major accident hazard scenarios, the precautions established to manage these hazards, and the residual risk.
The ALARP principle is also applicable to lower tier sites.