COMAH 2015 Compliance
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.
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COMAH Safety Report
Don’t know where to start? We can help guide you through the update and submission of your COMAH Safety Report.
KK Risk personnel have been working with the COMAH regime for 15 years and have written and reviewed COMAH Safety Reports for sites ranging from those with small environmental footprint, right up to complex chemical sites with the potential for significant off-site impacts.
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Hazardous Substance Consent
The lessons from explosions such as at the Flixborough chemical works in Humberside in 1974, Seveso in Italy in 1976 and Buncefield in 2005 underline the importance of controlling sites where hazardous substances could be present and where development is proposed near them.
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Notification
A COMAH notification is a simple process that applies to lower and upper tier COMAH establishments, and sites that are planning to be outside the COMAH regime.
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Actions Management
Managing COMAH actions alongside a site’s other concerns can be complex, but a risk based prioritisation can help.
Following a comprehensive and systematic Process Hazard Analysis, a large list of actions can be produced, some of which can be minor actions to check data or confirm assumptions, and some can be much more involved. If the Process Hazard Analysis is also used to identify additional measures to demonstrate ALARP, this can also add a substantial number of actions to the list.
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Intervention Support
We can help you prepare for COMAH Intervention Visits, or help you to understand and implement the Competent Authority’s requirements in a proportionate way.
KK Risk can carry out pre-visit audits, thereby allowing any gaps to be filled before the Competent Authority arrives. We have also attended numerous intervention visits at the invitation of our clients, either as an independent observer or co-leading the visit with the client.
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MATTE Assessment
An assessment of major accident to the environment (MATTE) is a critical element of the risk management practice required to ensure compliance with COMAH Regulations. It is not possible to provide a scientific definition of the changes in the environment caused by an event at an establishment that would constitute a major accident to the environment.
At KK Risk, we believe the more extensive the areas and quantities of natural and semi-natural resources damaged as a result of a major accident event, the longer the effects are likely to last, and the more intense or severe these effects, then the more likely it is that the major accident event should be regarded as a major accident to the environment.
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