Describing a site's equipment and safety systems is easy; demonstrating their adequacy and linkage to the site's major accidents is much more involved.
The COMAH Regulations 2015 require a Safety Report to demonstrate that 'adequate safety and reliability have been incorporated into the design and construction of the installation'. You should also include a 'description of the technical parameters and equipment used for the safety of the installations and a description of the equipment installed in the plant to limit the consequences of major accidents'.
The Technical Aspects section of a COMAH Safety Report is assessed by up to 4 different specialists, each having different expectations:
The key words for this section are 'linkage' and 'demonstration'. A simple description of the equipment is not adequate; instead the Report must link the equipment and systems to the major accidents identified in the report and demonstrate why it is effective. The section must also show that the equipment and systems conform to good practice as a minimum.
The information in the Safety Report is examined at face value to determine whether the measures meet current good practice AND whether the arguments for not adopting further measures demonstrate that the ALARP principles have been adequately justified and applied. The CA will then carry out Intervention Visits to verify the demonstrations made in the report.
At the core of C3 is a team of hugely experienced engineers, all of who have gained consultancy experience following successful careers in operational and senior management positions on Top Tier and Lower Tier COMAH sites across the UK. This collective experience makes us well placed to help you with the potentially complex demonstrations required to comply with the Technical Aspects of COMAH.
Permit to work (PtW) systems are all too often taken for granted, they exist and get audited but few people ever stop to ask "Are they effective?" Well not until after the incident.
The HSE remains focused on ensuring every operator has a robust Permit to Work system in place and failure to do so is likely to cost you dearly not just in £'s but all too often and sadly in people.
C3's team have over 100 years of combined experience industrial experience and can assist you in reviewing, redesigning and rolling out new systems design to manage the risk posed by the 21st century.
Our team will help you through every step starting with the basics and general principles, through looking at the types of risk assessment your business needs (such as Hot Work / Confined Space / Excavation etc) and if necessary assisting with training and auditing.
C3 believes our strength comes from working with our clients in integrated teams, and our commitment starts from the very first contact. What do we mean, well simply put give us a call or drop us an email and we’ll be more than happy to discuss your specific needs either over the phone or face to face at your site for free.
Under the risk based approach to compliance adopted within the UK, meeting the required level of compliance is more fifty shades of grey and then black and white however, one thing that is a 'given' is that all COMAH sites are expected to comply with good practice.
For new sites, current good practice must be applied at the design stage, but for existing installations, the HSE expects that duty holders apply current good practice to the extent necessary to satisfy the relevant law.
As UK law requires risks to have been reduced ALARP, HSE will, where the duty-holder wishes to adopt a different approach to controlling risks, seek assurance that the risks are no greater than that which would have been achieved through adoption of good practice and so are ALARP for that different approach.
In circumstances where established good practice does not exist, is out of date or the situation is complex and the relevance of individual good practices is questionable (e.g. high hazard sites), the decision making process on risk reduction action is less straightforward.
The use of Cost Benefit Analysis (CBA) can aid the decision making process by giving monetary values to the costs and benefits and to enable a comparison of like quantities. The analysis can help make an informed choice between risk reduction options.
Demonstration of compliance with good practice is also an integral part of a COMAH Safety Report but many sites struggle to know what is applicable to them.
In all these areas C3 can help you to identify relevant good practice and assess your compliance against it, and ideally before the regulator does!
Alarms need to be identified and categorised, and must require a defined response to an abnormal event, otherwise they are not alarms!
What to inspect, how and when; prioritised and achievable.
The 'age' of equipment depends not only on the time in service, but also how it has been operated and maintained.
Secondary and Tertiary containment systems are often taken for granted, but can be critical for sites with the potential for significant releases of environmentally harmful substances or firewater.
Different approaches can be used to determine what equipment is 'safety critical', but once defined, what does it mean?
Compliance with DSEAR has Hazardous Area Classification at its core, but covers other issues too.
Functional Safety covers so much more than just SIL determination and must be applied to both new and existing systems.
Modifications of all types must be adequately conceived, designed, installed and tested.