Comment by: Anonymous
Focus area: Chemicals
Regulator concerned: Environment Agency,Health and Safety Executive (HSE)
In common with a previous anonymous contributor, I too am a Health and Safety representative for a multi site organisation with numerous COMAH sites.
I cannot agree more with the sentiments of the previous contributor. I spend the majority of my time writing, updating and conversing with the Competent Authority in order to keep them appeased when my time would be much better spent on general improvements, training and implementing safety programmes which would take our company forward.
COMAH reports are a time consuming and very costly exercise with much of the work focusing on expensive modelling of what the outcome of a major accident would be. This information is constantly criticised by the “specialist inspectors”, as since it cannot, by definition, be proven. These discussions and resubmissions result in more academic exercises (and more consultancy fees as there is by definition no right answer), instead of focusing on the measures, equipment and procedures in place to prevent the event in the first place.
I doubt there has ever been such a thing as a perfect COMAH submission, particularly when these reports are reviewed by 10+ ‘Specialist inspectors’, this leads to more and more time and money being spent supplying the CA with paperwork and being threatened with enforcement action.
We have experienced a significant lack of consistency particularly with specialist inspectors. I have experience of different specialists in the same field coming up with completely different conclusions after looking at exactly the same thing at our sites
COMAH remodelling seems to have only achieved a massive increase in ‘intervention’ visits where numerous inspectors arrive on site together, even when several of them have no contribution what so ever to make the inspection or discussion – but are all chargeable at c. £150/hour.
I have seen a significant increase in COMAH charging in my company over the last few years – an average of 20K/y was normal, however, since the financial crisis and the reduction in the number of HSE /EA inspectors, COMAH sites have had a significant increase in inspections! Couple this with the COMAH remodelling; the charges are now an average of 120K/y. This expenditure of course does not include the management time and consultants employed to provide the information.
I am not suggesting that the HSE do not have a role in ensuring the COMAH regulations are implemented by industry, but I do suggest there must be a better and more consistent way of achieving this end. In my opinion for multi site companies, these interventions could be carried out on one of the company facilities (or one picked at random for each topic/aspect) and then the company could provide evidence that the other facilities in the group were also complying to a similar standard. The CA could then perform random spot checks to confirm (preferably by the same inspectors for consistency) rather than every inspection being carried out at every facility and the company having to have the same discussion several times (and be charged for it several times).