Comment by: Julie Griffin
Focus area: Chemicals
Regulator concerned: Environment Agency,Health and Safety Executive (HSE),Local Authority or Fire Authority
The HSE/EA/LA all appear to be willing to work with industry to resolve any issues. This has led to an open relationship with respect on all sides.
However, the CA do appear to be reluctant to share best practice that they may have observed at other sites.
Planning for inspections is usually a joint effort. Inspections involving specialist inspectors are often of more value – it is useful sometimes to get an expert opinion on things.
There does appear to be a duplication of effort for a site that is regulated under the Environmental Permitting Regulations who have EA inspections under EPR and COMAH, in many cases by the same inspector.
The COMAH safety report requires a significant amount of effort to prepare and review. The report is in addition to existing, robust, safety management systems and does not enhance these systems in any way. Industry would benefit from having a template to work with when preparing a less detailed version of the report
The largest regulatory burden to our site is hazardous substances consent. The Local Authority handle such applications in a professional, timely manner, however, they rely of the HSE as a consultee in the process. The HSE can take many months to respond to a request from the LA, leading to the potential for lost business. It is imperative that the industry is in a position to move quickly should opportunities for expansion arise.
There is also little guidance available on the hazardous substances consent application process which can lead to protracted discussions with the regulators following the submission of an application.