Understanding COMAH: Key Regulations for High-Hazard Industries

Importance and Benefits

The establishment of COMAH was prompted by the 1976 Seveso Disaster in Italy, where a toxin release killed thousands of animals and caused severe health issues in hundreds of people. Other disasters in the UK (e.g., the 1974 Flixborough explosion and the 2005 Buncefield fire) underscored the need for stringent Environmental, Health, and Safety (EHS) regulations to prevent accidents and subsequent illnesses and fatalities.

Companies that adhere to COMAH’s rigorous requirements gain numerous benefits. These are the top five:

• Minimized likelihood of major accidents – A sustained focus on prevention through proactive hazardous substance evaluation and control contributes to lower rates of catastrophes in regulated industries.
• Better human health and environmental protection – With an emphasis on implementing best practices in safety management, companies can better safeguard their workforce, the community they belong to, and their surroundings.
• Higher savings – Non-compliance can result in substantial fines, legal fees, and expensive costs associated with reforming a tarnished reputation.
• Stronger safety culture – COMAH requires active employee involvement, regular training, and continuous improvements. Workers become more conscious and proactive when safety is embedded into the operations.
• Improved business resilience – Because the mandate zeroes in on emergency preparedness, the company is better positioned to weather unforeseen events and recover faster.

COMAH Site Classification

The COMAH Regulations 2015’s statutory requirements provide extensive details about the law. One of the most vital is its two main classifications:

Lower-Tier COMAH Site

This type of establishment stores or uses dangerous substances at or above the lower threshold quantity. The numbers vary by substance type (e.g., toxic, flammable, environmental hazard) and concentration. These are the specific requirements:

• Notify the competent authority using Form COMAH 1.
• Prepare and implement a Major Accident Prevention Policy.
• Maintain a proportional safety management plan.

Upper-Tier COMAH Site

This type of facility holds dangerous substances at or above the upper threshold specified by the mandate. Because these sites have the highest potential for catastrophic incidents involving widespread harm to people or the environment, they face more stringent and detailed oversight. Here are the requirements:

• Notify the competent authority.
• Prepare a Major Accident Prevention Policy.
• Submit a detailed COMAH safety report detailing risk control measures, emergency planning, and mitigation strategies.
• Prepare and test an on-site emergency plan.
• Cooperate with the local authorities to develop an off-site emergency plan.

Learn more about the classification, specific requirements, and revisions from earlier versions by reviewing the Health and Safety Authority guide. A complete list of controlled and hazardous substances with the corresponding thresholds is also published. 

Key Requirements of the Regulations

Learn more about the requirements enumerated in the lower and upper-tier COMAH sites and the responsibilities of safety personnel, health professionals, and environmental specialists:

Hazard Identification and Risk Assessment

Identifying hazards and assessing risks are the foundation for all safety planning. Operators should systematically determine all potential major accident hazards and evaluate the likelihood and consequences of those events. Designated EHS teams should do the following:

• Conduct a comprehensive hazard analysis for all relevant substances and processes.
• Perform quantified risk assessments to understand the worst-case scenarios.
• Document findings in line with COMAH requirements.

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Safety Management Systems (SMS)

Safety shouldn’t be treated as a one-time effort. The system should evolve with workforce changes and technological developments to continuously monitor and address risks in every aspect of the operation.

• Establish and maintain a formal SMS suitable for the level of risk.
• Allocate clear roles and responsibilities for safety-critical functions.
• Continuously monitor and improve the SMS based on findings from inspections or incidents.

Notification and Reporting

Operators must formally notify the competent authority of their activities and submit reports on major accidents and safety compliance. This ensures regulatory oversight, timely and proper investigation, prevention of recurrence, and public assurance.

• Submit the COMAH 1 notification before commencing operations.
• Update the notification when there are significant changes to site operations or inventory.
• Report any near-misses or major accidents without delay.

Major Accident Prevention Policy (MAPP)

The MAPP is a written policy that outlines the operator’s aims and principles for controlling and managing major accident hazards. This provides a strategic foundation for workplace safety and demonstrates a full commitment to accident prevention.

• Develop a documented MAPP that reflects the nature and scale of the hazards.
• Integrate this into the overall safety management system.
• Communicate the policy across the workforce.

Emergency Planning

Accidents may still occur even with robust preventive strategies. A tested emergency plan reduces harm and enables a swift, coordinated response for both on-site and off-site (for upper-tier class) responses to major accidents.

• Test and review the emergency plans regularly. Train staff on emergency procedures and roles.
• Provide information to emergency services in nearby communities.
• As aforementioned, an off-site emergency plan should be created in collaboration with local authorities for upper-tier facilities.

Safety Reports

Submitted by upper-tier operators, this comprehensive document demonstrates that all major accident hazards have been identified and adequately controlled.

• Submit a detailed safety report before operations begin and periodically afterward. HSE provides guidelines on how to create this.
• Include a description of the site, hazards identified, risk assessment results, and preventive or mitigating measures.
• Update the report after significant changes in operations or after major accidents.

The UK’s HSE allows the general public to search for information about establishments covered by COMAH 2015. This drives responsibility, accountability, and continuous compliance with EHS standards among operators in high-risk industries.

Overcoming Challenges

Achieving the goals of the Control of Major Accident Hazards regulations is a formidable task. Because this is a complex undertaking, expect obstacles that may hinder the success of the company’s plans. Here are the most common hurdles and how to clear them.

• Lack of resources and capacity – Companies without financial, human, or technical resources risk gaps in assessment, delayed safety reports, and inadequate emergency plans. Aside from utilizing digital tools to streamline tasks like hazard tracking and document control, implementing a phased approach is one of the best ways to overcome this challenge.
• Low employee awareness and inadequate training – If frontline staff and contractors are unaware of their duties, the best-written safety report and policy become ineffective. Hence, developing a specific induction and ongoing training program ensures every team member can contribute to building a safety culture.
• Keeping up with regulatory changes – Failure to stay updated means companies could fall out of compliance and knowingly miss deadlines or fail to implement new safety practices. Leveraging horizon scanning tools, subscribing to compliance newsletters, and attending industry forums can help EHS personnel know when changes are made.