On 1 June 2015, the COMAH Regulations 1999 were replaced by the COMAH Regulations 2015. The most significant change affecting COMAH Safety Report is the alignment with the Classification, Labelling and Packaging (CLP) Regulations. In the majority of cases, the Descriptive Aspects will require updating to reflect the new classifications; however, COMAH site operators are expected confirm that the reclassification has not introduced a new major accident scenario.

There are also some changes to the information expected in Safety Reports, and this must be reflected in the COMAH 2015 review. Other COMAH 2015 changes include the requirement to re-notify to the Competent Authority, and there are also changes to the public information requirements.

In order to comply with COMAH Regulations 2015, do you have to submit an addendum to your COMAH Safety Report or even completely revise it by 31 May 2016? The deadline may seem like a long way off for a change that can be seen as minor, but an early start is always beneficial as a COMAH review inevitably grows beyond its original scope.

You may take the opportunity to carry out an interim review of your Safety Report in order to reduce the workload at the next 5-year Review stage, or just review your risk assessment to take credit for recent risk reduction initiatives. Whatever your scope, our extensive COMAH experience can help make the transition as smooth as possible.