Contribution by Martyn James

Submitted on: May 30, 2012

Comment by: Martyn James

Focus area: Chemicals

Regulator concerned: Environment Agency,Fire safety (Fire Authority),Health and Safety Executive (HSE),Local Authority or Fire Authority

Comment:
Over the past few years, as a top tier COMAH site, we have received numerous site visits, as you would expect. I have generally found the inspections useful but one of the frustrations has been lack of consistency at times with regards to who is the inspector is. When an inspector changes, we have got to repeat old ground with the new inspector to bring them up to speed with the site and issues. I understand that people move on so I’m not sure how to get round this.

I have also experienced a difference in approach and opinions from inspectors, again, individuals are going to act in their own way using their own pool of knowledge but when one inspector comes to your site and leaves fairly happy, with no/little actions points and then another comes and you end up with a few, then I feel there is not the consistency there amongst inspectors.

I also feel that if notices are going to be issued they should be discussed during the site visit, rather than the inspector leaving site, without the mention of a notice and then receiving a telephone call a day later advising he is thinking about issuing one. On this occasion one wasn’t issued as I managed to convince him the issue would be dealt with very quickly and it was but I don’t feel there was a need to use a threat of a notice for us to get the task done at that point. Because of the situation, we should have been allowed a reasonable amount of time to get it done before the threat of an Improvement Notice was used.

Finally, I also have found a lack of communication at times within the same regulator.

I firmly believe that consistency and openness during inspections is vital. I support the need for inspections and have found some very useful. Being given guidance and advice from the regulator is very helpful and this proactive approach is important.