Comment by: Kenneth Patrick
Focus area: Chemicals
Regulator concerned: Health and Safety Executive (HSE)
The regulator for COMAH Is the CA but his does not appear on the list but my comment does in some respects relate to the dominant position HSE have assumed in the CA.
The site where I am currently working came under the scope of COMAH in 2004 due to the storage of material of material that was dangerous for the environment. The HSE’s inspection plan had twenty issues but in respect of the environment it said” No specific COMAH related environmental issues. However, these issues will be inspected at the same time as the IPPC sheduled visits., as appropriate.”
Thus the whole site become subject to charged HSE inspections when the reason we are being regulated under COMAH are already being dealt with by separate environmental regulations.
I have seen this also at other sites. A slight change in government policy/direction could have allowed the environmental aspects of the Seveso directive to be dealt with under existing environmental regulations.
The burden of COMAH is considerable and we should not allow it to creep into areas that are already being regulated!