Comment by: Anonymous
Focus area: Chemicals
Regulator concerned: Health and Safety Executive (HSE)
I am writing as a safety advisor who works for a very large multiple site COMAH company. I am doing this anonymously because I think it would be too difficult to get an agreed statement from my company, and my name would be very easily linked to my company. Besides, companies can be approached directly, whereas I think you want to hear from people at the coalface.
The quantity of inspection and assessment is not efficient. Too much time is spent producing or writing documents for the Competent Authority, in order to justify or substantiate the measures we take. Almost universally these documents do not change anything, they only re-enforce what has been already been concluded and explained. Meanwhile it has not been possible to spend that time getting on with actual safety and environmental improvements.
Safety Reports are a case in point. The common outcome is for the Competent Authority to state that “the safety report does not make the demonstrations”, because of some details which are missing. This puts the CA in a safer place, in case something goes wrong on-site. I do not object to that, because I accept the primary responsibility for safety/environment is ours. However I do object to the great swathes of time spent on this and other documents, knowing that however much detail we include, there is likely to be some other detail alleged to be missing, and the conclusion will be the same. COMAH remodelling hasn’t really changed anything, except perhaps the number of Inspectors taking part in the assessment. The Safety Report still seems to be treated as an end in itself, in which we are expected to invest large amounts of time, instead of it being a stepping stone to the control of safety and environmental risks. The time invested on both sides (and the detail expected) remains disproportionate
On the plus side, Inspectors are generally personable people, generally very interested in improving safety and the environment. Some are jobs-worths or unreasonable, but they are in the minority. It is the regime, especially one where HSE’s income relies so much on the volume of work these COMAH Inspectors generate, which is the problem.