Comment by: Anonymous Anonymous
Focus area: Chemicals
Regulator concerned: Health and Safety Executive (HSE)
Focus group consensus was that the Safety Case report was a pure cost to satisfy HSE as we (responsible operators) have management systems that cover the key areas of COMAH and in reality do not use the Safety Case other than to justify Capex to our finance depts.
We also felt that COMAH as applied by HSE is a revenue generator or operator tax that penalised us for operating our businesses.
We valued the liaison with HSE inspectors and specialists as they do have an industry wide role and can add value on visits but this did not outweigh the costs imposed by the regulations.