The Control of Major Accident Hazards
The “whys, whats, whos, and hows”
It has been recognised for many years that certain industrial activities involving dangerous substances have the potential to cause accidents. Some of them give rise to serious injury to people or damage to the environment both close to, and further away from, the site of the accident. Such incidents have come to be known as major accident hazards.
In 1999 the “Control of Major Accident Hazards Regulations” (COMAH) were introduced in Great Britain, replacing earlier legislation, with the aim of preventing major accidents involving dangerous substances and to limit the consequences to people and the environment of any which do occur.
As with any industrial site there is the potential for accidents to occur. However it must be stressed that our petrochemical industries have a good safety record and the occurrence of a “worst case” COMAH scenario is very unlikely.
What & Who?
The COMAH Regulations give detailed advice about the scope of, and the duties imposed by the legislation to the Operators of such establishments, the Emergency Services and the Local Authorities. A key feature of the COMAH Regulations is that they are enforced by a ”Competent Authority”, which comprises of the Health & Safety Executive and the Environment Agency.
COMAH establishments are graded by the Competent Authority as either “Top-Tier” or “Lower- Tier” dependant on the quantities and types of substances they produce and/or store.
The COMAH Regulations require that the Operator of a “Top-Tier” Establishment produces two plans:
(a) an On-site Emergency Plan, which is prepared by the Operator, to specify the response to an emergency which may affect those who work on the site.
(b) an Off-site Emergency Plan, which has to be prepared by the Local Authority which specifies the co-ordinated response of partner agencies to an emergency which has any off-site effects.
The Essex Civil Protection and Emergency Planning (ECPEM) Team undertakes this role on behalf of Essex Council. There is also a requirement for the Local Authorities to review and update the adequacy and effectiveness of the components of these plans and how they dovetail together. This requirement leads to the regular test and exercises of both the “on” & “off-site” plans. Some of the exercises involve the actual response of the resources and personnel from the Emergency Services as if the exercise scenario was a real incident, whilst others take the form of simulations without the need for the deployment of actual resources. In every case a full de-brief takes place and any lessons learned are put into the revised plans.
Public Information (Regulation 14)
One of the important features of the COMAH Regulations is that there is a requirement upon the Operator of a “Top-Tier” establishment to provided specified information to people liable to be affected by a major accident at that establishment. This includes the potential major hazards and the safety measures that are in place.
It is the duty of the “Competent Authority” to determine the area around a COMAH establishment to which this information (in writing) must be made available. This area is known as the Public Information Zone (PIZ).
In many cases the Operators of the “Top-Tier” establishments have worked with the ECPEM Team to undertake the task of preparing the appropriate letter to warn and inform the public within the PIZ.
Generally this is done by way of a letter sent out by Operators under Regulation 14 to all addresses within the PIZ. This letter must contain the name and address of the operator and establishment. It must also contain (in non technical language which is easy to understand by a lay person) confirmation that the establishment is one to which the COMAH Regulations apply and give an explanation in simple terms of the activity or activities undertaken at that establishment.
The raw materials and the end product can be mentioned to help describe the activity being undertaken and it may also help to describe the history and development of that on-site activity in the case of established installations.
The common (or generic) names, or the general danger classification, of the substances or preparations involved at the establishment should be described, particularly those which will be the most important in the event of a major accident. The delayed and long term effects following acute exposure should also be included.
The letter must contain adequate information on how the population concerned will be warned and kept informed in the event of a major accident and the actions that they should take. Reference should also be made to the Off-site Emergency Plan prepared by the relevant authority in conjunction with the Operator and the Emergency Services. There may also be reference to a contact point where further information could be obtained.
The Following Operators are Registered as “Top Tier” COMAH Establishments
Further information about any of the Operators can be obtained from their Company Websites. General information on COMAH can be obtained from the Health and Safety Executive and Environment Agency websites.