Understand the requirements for Upper-Tier & Lower-Tier
A COMAH site is a business or organisation that operates daily using highly dangerous substances, often requiring the storage of these substances on their premises. Consequently, your establishment must adhere to the COMAH Regulations and ensure your staff undergoes COMAH training.
What does COMAH stand for?
In essence COMAH, which stands for Control of Major Accident Hazards is a regulated framework that is purposely aimed at preventing and mitigating the effects of major accidents involving dangerous substances, a goal of protecting people and the surrounding environment. These regulations apply to establishments that store a set quantity (thresholds determine if a site needs to be regulated under COMAH) of hazardous materials.
Who is responsible for COMAH Regulations?
In terms of who is responsible for the CHOMA Regulations, this is down to several bodies coming together, to collaborate on creating a policy of managing major accidents, and as such these include health, safety and environmental bodies.
COMAH 2015 is enforced by a Competent Authority (CA) that compromises HSE, or the Office for Nuclear Regulations (ONR) for nuclear establishments, acting jointly the appropriately environmental agency.
Competent Authority (CA)
Health and Safety Executive (HSE)
Office for Nuclear Regulation (ONR)
Environment Agency (EA)
Natural Resources Wales (NRW)
Scottish Environment Protection Agency (SEPA)
All five CA partner organisations work together through the CA Strategic Management Group (CASMG) set out in their COMAH purpose statement
Applying the COMAH Regulations
Applying the COMAH regulations means identifying whether your establishment will be an Upper-tier or Lower-tier, each tier will have it's own requirement with the Upper-tier requiring more effort. The task of finding out is to take note of the substances on site, the quantity only then can you find out what tier you the establishment will be in.
Steps to help you determine if COMAH applies to your business
Identify Dangerous Substances.
Quantity the substances
Compare with Thresholds
Assess Aggregation Rules
Determine Your Status
Identify Dangerous Substances
List all the dangerous substances present at your site. Dangerous substances are typically chemicals that are toxic, flammable, explosive, or have other hazardous properties. You can find a detailed list of these substances in Schedule 1 of the COMAH regulations.
The importance of understanding the DSEAR Regulations does align itself with the COMAH Regulations as it includes managing the risks from fire, explosion, and similar events arising from dangerous substances in the workplace.
Quantify the Substances
Determine the quantities of each dangerous substance present. This includes substances stored, used in processes, or produced as by-products.
Compare with Thresholds
Compare the quantities of your dangerous substances with the threshold quantities specified in Schedule 1 of the COMAH regulations. There are two thresholds: a lower threshold and an upper threshold. The level of regulatory requirements increases from lower tier to upper tier.
Assess Aggregation Rules
If you have multiple dangerous substances, you may need to consider the aggregation rules. This involves calculating the aggregate quantity of substances with similar hazards to see if their combined total exceeds the thresholds.
Determine Your Status
Based on the quantities and aggregation:
Lower Tier: If the quantity of any dangerous substance exceeds the lower threshold, your establishment is classified as a lower-tier site.
Upper Tier: If the quantity of any dangerous substance exceeds the upper threshold, your establishment is classified as an upper-tier site.
Seek expert advice if you're unsure
If you find this process complex or are unsure about your calculations, consider consulting with a professional who specializes in COMAH regulations and chemical safety.
A precise list of dangerous substances and their classification
criteria can be found in the Schedules of the COMAH Regulations 2015, particularly Schedule 1, which outlines the named substances and their qualifying quantities.
COMAH Threshold example
Once an inventory has taken place, you are then able to find out if you are in the UPPER or LOWER Tier threshold. Below are two establishments applying the COMAH regulations based on their own threshold.
Company
Chemical Manufacturing Ltd (Company A)
Storage Solutions Ltd (Company B)
Activity
Manufactures industrial chemicals.
Provides storage facilities for chemical products
Substances Stored
Hydrochloric Acid (HCl)
50 tons
Ammonia (NH3)
20 tons
Diesel fuel
100 tons
Lubricating oil
50 tons
Threshold Level
Upper Tier
Lower Tier
Reason
Chemical Manufacturing Ltd. stores significant quantities of hazardous substances (Hydrochloric Acid and Ammonia) that exceed the Upper Tier threshold limits specified by the COMAH regulations. Due to the quantities stored, they are categorized as an Upper Tier COMAH establishment.
Storage Solutions Ltd. stores relatively smaller quantities of substances (Diesel fuel and Lubricating oil) that fall below the Upper Tier threshold but exceed the Lower Tier threshold defined by the COMAH regulations. Therefore, they are classified as a Lower Tier COMAH establishment.
Due to COMAH Aggregation Company A is recognised as the Upper-Tier because of the hazardous substances stored, ammonia is highly toxic and flammable compared to Company B with its lubricating oil, which is identified as a Lower-Tier. Not only is it based on the quantity but also as whole, there are substances when grouped together far more dangerous - you may need to consider aggregation rules.
When you have determined your COMAH status you will need to notify the Competent Authority (CA), which includes details about your establishment, the hazardous substances and their quantities and this can be a MAPP document (for Lower-tier site) or a Safety Report (for Upper-tier site).
Preparing a Major Accident Prevention Policy (MAPP)
MAPP Policy Structure for a Lower Tier
Introduction
Policy Statement
Objectives
Organisational Structure and Responsibilities
Safety Management System (SMS)
Communication
Review and Continuous Improvement
Sign-off
Having been able to put your organisation in threshold, you will be needed to create a MAPP. This a document contains content that clearly shows your organisations preventive effort towards your safety process.
Establishments that fall within the UPPER tier threshold are required to develop a comprehensive Safety Report. This report must detail the implementation and maintenance of a Safety Management System (SMS), which is crucial for managing major accident hazards effectively. Conversely, establishments that meet the LOWER tier threshold are not required to prepare a detailed Safety Report. Instead, they must develop a Major Accident Prevention Policy (MAPP) that includes a description of the SMS to manage major accident hazards.
Major Accident Prevention Policy (MAPP) Document Example
Below are two examples of how the document may look for an Upper and Lower tier. This is only a framework example, at best, a starting point as we you will need a document tailored to your own COMAH establishment and reflect the specific circumstances and hazards of your facility.
MAPP for a Lower Tier Site
1. Introduction
Company Name: SafeChem Ltd.
Location: Industrial Estate, City, Country
Date: 1st July 2024
2. Policy Statement
SafeChem Ltd. is committed to preventing major accidents involving dangerous substances. As a lower tier COMAH establishment, we recognize our responsibility to ensure the safety of our employees, the public, and the environment.
3. Objectives
Prevent major accidents involving hazardous substances.
Minimize the consequences of any incidents.
Ensure compliance with COMAH regulations and other relevant safety legislation.
Continuously improve our safety performance.
4. Organisational Structure and Responsibilities
Managing Director: Overall responsibility for the MAPP and ensuring adequate resources are allocated.
Safety Manager: Responsible for implementing the MAPP, maintaining the Safety Management System (SMS), and coordinating safety activities.
Department Heads: Ensure compliance with safety procedures within their respective areas.
All Employees: Follow safety procedures and participate in training programs.
5. Safety Management System (SMS)
Our SMS includes the following elements:
5.1 Risk Assessment:
Identify major accident hazards through regular risk assessments.
Use quantitative and qualitative methods to evaluate risks.
Implement control measures to mitigate identified risks.
5.2 Operational Control:
Develop and maintain standard operating procedures (SOPs) for all hazardous activities.
Ensure proper maintenance of equipment to prevent failures.
5.3 Management of Change:
Evaluate safety implications of changes in processes, materials, or equipment.
Update risk assessments and SOPs as necessary.
5.4 Emergency Planning:
Develop and maintain an on-site emergency plan.
Conduct regular emergency drills and revise plans based on outcomes.
Coordinate with local emergency services for effective response to incidents.
5.5 Training and Competence:
Provide regular safety training to all employees.
Ensure employees are competent in their roles and aware of the hazards.
5.6 Performance Monitoring:
Conduct regular safety audits and inspections.
Monitor safety performance through incident reporting and investigation.
Use key performance indicators (KPIs) to track safety performance and identify areas for improvement.
6. Communication
Maintain open communication channels for reporting safety concerns.
Provide information to employees and contractors about the hazards and safety measures.
Inform the public and relevant authorities about the nature of hazards and emergency procedures.
7. Review and Continuous Improvement
Review the MAPP annually or following significant changes in operations.
Implement findings from audits, inspections, and incident investigations to improve safety measures.
Encourage feedback from employees and other stakeholders to enhance safety practices.
Signed: John Smith Managing Director
SafeChem Ltd.
1st July 2024
MAPP for an Upper Tier Site
1. Introduction
Company Name: MegaChem Industries Plc.
Location: Chemical Manufacturing Complex, City, Country
Date: 1st July 2024
2. Policy Statement
MegaChem Industries Plc. operates as an upper tier COMAH establishment. Our policy is to prevent major accidents and mitigate their consequences through robust safety management and continuous improvement.
3. Objectives
Prevent major accidents involving hazardous substances.
Minimize the impact of any incidents on people and the environment.
Ensure comprehensive compliance with COMAH and other safety regulations.
Continuously improve our safety performance through proactive risk management.
4. Organisational Structure and Responsibilities
Managing Director: Overall responsibility for the MAPP and ensuring adequate resources and support for safety measures.
Safety Director: Oversees the implementation of the MAPP and ensures the Safety Management System (SMS) is effective and up-to-date.
Site Safety Manager: Day-to-day management of safety activities, coordination of safety training, and maintenance of emergency plans.
Department Heads: Ensure adherence to safety procedures and conduct regular risk assessments in their departments.
All Employees: Follow safety procedures, participate in training programs, and report any safety concerns.
5. Safety Management System (SMS)
Our SMS is comprehensive and includes:
5.1 Policy and Objectives:
Establish clear safety objectives aligned with our commitment to preventing major accidents.
Ensure continuous improvement in safety performance.
5.2 Risk Assessment and Management:
Identify major accident hazards through systematic risk assessments.
Evaluate risks using quantitative and qualitative methods.
Implement control measures to mitigate identified risks.
5.3 Operational Control:
Develop and maintain standard operating procedures (SOPs) for all hazardous activities.
Ensure proper maintenance and inspection of equipment to prevent failures.
5.4 Management of Change:
Evaluate safety implications of changes in processes, materials, or equipment.
Update risk assessments and SOPs to reflect changes.
5.5 Emergency Planning:
Develop and maintain detailed on-site and off-site emergency plans.
Conduct regular emergency drills involving employees and local emergency services.
Review and update emergency plans based on drill outcomes and incident analyses.
5.6 Training and Competence:
Provide comprehensive safety training for all employees and contractors.
Ensure employees are competent in their roles and understand the hazards.
Maintain records of training and competency assessments.
5.7 Performance Monitoring and Audit
Conduct regular safety audits and inspections.
Monitor safety performance through incident reporting and investigation.
Use key performance indicators (KPIs) to track safety performance and identify areas for improvement.
Implement corrective actions based on audit findings and incident investigations.
5.8 Continuous Improvement:
Encourage feedback from employees, contractors, and other stakeholders to improve safety practices.
Review and update the MAPP annually or following significant changes in operations.
Implement recommendations from audits, inspections, and investigations.
6 Communication
6.1 Internal Communication:
Maintain open communication channels for reporting safety concerns and incidents.
Provide regular updates on safety performance and improvements to all employees.
6.2 External Communication:
Inform the public and relevant authorities about the nature of hazards and safety measures in place.
Coordinate with local emergency services and authorities for effective incident response.
Ensure transparency and openness in communication with stakeholders.
7. Review and Continuous Improvement
Review the MAPP annually or after significant changes in processes or after any major incident.
Incorporate lessons learned from incidents and audits into the safety management system.
Foster a culture of continuous improvement and proactive risk management.
Signed:
Jane Doe CEO
MegaChem Industries Plc.
1st July 2024
Understanding the COMAH Regulations is crucial for successfully applying safety measures in your business. All employees working in environments where dangerous substances are stored will benefit from the online training.
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Understand the requirements for Upper-Tier & Lower-Tier
