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COMAH 2015 now in force

The Control of Major Accident Hazards Regulations 2015 came into force in Scotland, Wales and England on 1 June 2015. These updated Regulations bring into force many of the parts of the Seveso III Directive.

The Directive has also resulted in updates to the hazardous substances consent legislation.

Perhaps the most significant driver for these updates to the regulations dealing with major accident hazards is the need to replace the references to the Chemicals (Hazard Information and Packaging for Supply) Regulations (CHIP) and align the new Regulations with the Classification, Labelling and Packaging Regulations (CLP).

At the time of writing, the COMAH Competent Authority information and guidance (hosted on the HSE website) is in the process of being revised.

Of note the following updates have been made, and are likely to be valuable links for all COMAH operators:

COMAH Guidance - The 3rd edition of the guide to the Control of Major Accident Hazards Regulations 2015 (L111) is now published as a final document at http://www.hse.gov.uk/pubns/books/l111.htm

Re-notification under COMAH 2015 http://www.hse.gov.uk/comah/notification/index.htm;

Making public information available http://www.hse.gov.uk/comah/submitting-public-information.htm;

The templates for notifications and public information are available for download and use.

At the time of my writing this blog (8am, 2 June 2015), the CA website had not been fully updated. However, key documents that are pending include the new version of the safety report assessment manual (SRAM).

Another significant update on the CA website – Hazardous Substances Consent applications can now be made on line (hosted by HSE): http://hazsubcon.azurewebsites.net/

More summaries of changes to follow…..

General guidance on COMAH is provided on-line by the COMAH Competent Authority at https://www.hse.gov.uk/comah/index.htm.

Blog dated 2 June 2015

The COMAH Regulations 2015

In this blog, I intend to provide overviews of selected changes to COMAH with the coming into force of COMAH 2015. Definitive and detailed guidance is available to be downloaded from the COMAH Competent Authority at: https://www.hse.gov.uk/pubns/books/l111.htm.

Changes to COMAH

1. COMAH 2015 – a summary of the main changes

The coming into force of the new Regulations will result in there being some re-organisation; but the essence of the Regulations remains very similar.
The new 2015 Regulations are underpinned by the Classification, Labelling and Packaging Regulations (CLP) in place of the Chemicals (Hazard Information and Packaging for Supply) Regulations (CHIP).
The new reference to the CLP Regulations means that all establishments will need to re-notify, and safety reports will need to be reviewed and revised to accommodate the changes to COMAH.
The new Regulations include certain changes to some of the defined terms.
There are also increased requirements to provide public information.
The Regulations come into force on 1 June 2015.

Moving now to specific topics, I'll start with the COMAH general duty, and add further topics in future blogs.

2. General Duty of the Operator

The ‘general duty’ of Regulation 4 of COMAH 1999 becomes Regulation 5(1) of COMAH 2015 with a slight modification.

Thus, COMAH ’99 Regulation 4 which stated that,

“Every operator shall take all measures necessary to prevent major accidents and limit their consequences to persons and the environment”
Is superseded by COMAH ’15 Regulation 5(1) which now requires that,
“Every operator must take all measures necessary to prevent major accidents and to limit their consequences for human health and the environment”.

COMAH 2015 introduces additional parts to Regulation 5 of COMAH 2015. These parts make specific explicit requirements in connection with the ‘general duty’:

To demonstrate to the Competent Authority that they have taken all measures necessary;
To provide the Competent Authority with all assistance necessary to perform its functions under these Regulations.

More summaries of the changes to COMAH to follow.....

General guidance on COMAH is provided on-line by the COMAH Competent Authority at https://www.hse.gov.uk/comah/index.htm.

Blog dated 22 May 2015