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Beyond Compliance with COMAH

Compliance. Safety. Peace Of Mind

Background to the case study

COMAH stands for The Control of Major Accident Hazards. It is about helping businesses to take all the necessary measures to prevent major accidents with hazardous substances. In addition, it helps to reduce risks and potential problems by ensuring that enforcing regulations on hazardous substances will protect people and the environment.

Ligtas worked with this client, a multinational consumer goods corporation, who needed to safely store aerosols, to review their safety report to determine how effective their systems are in preventing, controlling and mitigating any potential risks. As well as asking the question, how do we know that these systems are effective?

Safety reports need to be submitted for approval by the HSE and Environment Agency (the Competent Authority) on a five-yearly basis. In this instance, it required significant improvements. Ligtas needed to support the resubmission of the Safety Case Report and mentor the relevant personnel so that they could manage this going forward.

Client requirements

Our client wanted to be more than compliant, setting high standards so that they could ensure that what they were doing was safe and could provide peace of mind. For this, they needed support for their current requirements and to be capable of managing this going forward.

  • Assistance in their Safety Report submission, ensuring that it would meet agreed standards
  • Support and mentor so that they could upskill the team to be aware of what was now required and supporting them to create the new
  • Safety Report Because the client was storing aerosols, they additionally needed support under the Dangerous Substances and Explosive Atmosphere (DSEAR) Regulations
  • Ongoing competency in-house to manage own risks
  • A third-party expert to guide them through their current requirements and mentor them to manage in-house for the future

Our solution

Once Ligtas fully understood the requirements, we were able to formulate a plan to empower the team to manage COMAH and DSEAR going forward. Our solution included:

  • Assigning an experienced ex-HSE inspector to the project
  • Assess, and undertake a variety of analyses (gap, cause and effect, risk) to understand the nature of the problem
  • Creating a detailed specification which was agreed upon with the senior management team, ensuring that all of the required technical content was included within the documentation
  • Following the assessment by putting controls in place to prevent issues, which meant training and mentoring people to understand what was required
  • Mentoring the team to write the current Safety Report and then teach them how to write and manage it, so that they can take ownership of the CSR emergency response, liaison with the community, consider any on and offsite action and interaction with the local authority
  • Additional specialised consultancy and support were provided for the Safety Case Report, as required under the Dangerous Substances and Explosive Atmosphere (DSEAR) Regulations
  • A site-specific COMAH awareness course was also developed
  • The site’s safety team were also coached in how to deliver the course to their staff

Benefits

  • The client truly ‘owned’ the Safety Report and had a full understanding of its contents. A common issue identified by the HSE when Safety Reports are produced by third-parties is that the site has no true understanding of the technical content. By using the approach agreed, this was avoided.
  • True competency development of the Safety Manager allowing them to effectively self-manage the Safety Report going forward.
  • A single provider who could not only assist in the development of the Safety Report resubmission but undertake the specialised assessments required for this type of highly technical documentation.