A MAPP need only be a short document, but must be linked to your major accidents.
A Major Accident Prevention Policy (MAPP) is a statement of general intent that should set out your policy on the prevention of major accidents. The MAPP doesn't need to contain a detailed description of your Safety Management System (SMS). However, it should give sufficient detail to show you have systems in place to cover all the required aspects.
The key to the MAPP is the link to your potential major accidents, to both people and the environment.
Your MAPP must contain your policy setting out your aims and principles of action concerning the prevention of major accidents, and a description of the SMS for achieving these aims. It does not need to be a long document and can refer to other documentation where relevant.
There is plenty of guidance available about the required information, but the trick is linking it to your major accidents and including a proportionate amount of detail. C3's experienced consultants can help you get the balance right.
A SMS must be proportionate to the hazards, activities and complexity of the site.
A Safety Management System (SMS) is a key part of COMAH compliance and is covered by Regulation 7 of COMAH 2015, which states that:
Most sites already have systems in place for most of the required areas (e.g. roles & responsibilities, training, procedures, etc.), but find that some improvements need to be made to demonstrate the linkage to the site's risk profile. In C3's experience more substantial improvements are often required around the topics of: hazard identification and risk assessment; design and modifications of installations; and emergency procedures.
C3 can assist you with all aspects of your site's safety management system, using our collective knowledge of systems that have been successfully implemented elsewhere. We can also provide good practice audits that generate practical and pragmatic advice for how your systems can be improved.
A COMAH Notification is a simple process, but one you need to get right. For existing COMAH sites, have you re-notified for COMAH 2015?
A valid substance consent is an essential part of COMAH compliance – do you have up to date permission to store your dangerous substances?
The hazardous substances consent controls are designed to regulate the presence of hazardous substances so that they cannot be kept or used above specified quantities until the responsible authorities have had the opportunity to assess the risk of an accident and its consequences for people in the surrounding area and for the environment.
These controls ensure that the residual risk to people and the environment is properly addressed by the land use system, which then specifies the type and size of development allowed near to hazardous installations. Similarly, permission to store hazardous substances depends on the development that already surrounds the site, and specific controls can be exercised over the presence of hazardous substances.
Applications are made to the hazardous substances authority (usually the local council), which is required to consult with the Health and Safety Executive and the Environment Agency (and others) and is empowered to grant consent either unconditionally or subject to such conditions as it thinks fit. So the HSE is only a consultee the hazardous substances authority has the final say.
There is now an on-line application form available on the HSE’s website, which makes the application process easier, but does not reduce the amount of work involved. C3 can help you through the process, from deciding how much consent to apply for to advertising and providing information to the public.
The identification of major accidents needs to be systematic and must cover normal and abnormal operations.
One of the purposes of a COMAH Safety Report is 'demonstrating that the major accident hazards and possible major accident scenarios in relation to the establishment have been identified and that the necessary measures have been taken to prevent such accidents and to limit their consequences for human health and the environment'. A key part of this demonstration is the identification of potential Major Accident Hazards (MAH).
There is no right or wrong way to identify MAH under COMAH, and it is not a requirement of the COMAH Regulations 2015 that a quantified risk assessment is undertaken. Sometimes it is sufficient to provide a qualitative 'description of the possible major accident scenarios and their probability or the conditions under which they might occur', but usually an approach somewhere between the two is the most appropriate, i.e. a semi-quantified approach, depending on the risk profile of the site.
We have developed our own Process Hazard Analysis (PHA) techniques for identifying and assessing hazards, based on many years of experience with COMAH sites and feedback from the CA. We tailor our approach based on the severity of the potential hazards, and always try to utilise any existing risk assessments.
ALARP demonstration is not an add-on to a risk assessment; it should be a fundamental part of it.
A COMAH Safety Report for an Upper Tier site needs to contain a demonstration that the risks are As Low As Reasonably Practicable (ALARP), which can be a straightforward exercise if your risks are low, but has the potential to be complicated for high hazard sites or those with few control measures. Some Lower Tier sites have also been required to prepare an ALARP demonstration, and again the complexity can vary depending on the site's risk profile.
Most risk matrices contain an area where the risks are 'Tolerable (if ALARP)'. The key word is the 'if', as events in this area are only tolerable if they are ALARP, which is why ALARP demonstration is such a key part of COMAH.
At C3 we have developed a simple (spreadsheet based) tool that guides you through the ALARP demonstration process, asking the questions 'What more could be done?' and 'Why have we not done it?' Where it is not possible to qualitatively accept or reject a potential risk reduction measure, a more quantitative assessment is used based on cost benefit analysis to assess whether the cost associated with the measure is grossly disproportionate.
At C3 we know that there are many ways to achieve the same goal, therefore we will tailor our approach to align with your own existing hazard assessments and risk matrices.
C3 can also help with the initial hazard identification and risk assessment; the identification and screening of potential additional measures; comparison against good practice; and/or prioritisation of any measures that are calculated to be reasonably practicable.