Comment by: Ian Kidd
Focus area: Chemicals
Regulator concerned: Health and Safety Executive (HSE)
As can be seen from the table below one of our COMAH Sites [Text Deleted] incurred 239 chargeable hours from HSE to assess the Safety Report, yet during the same year there was not a single visit. In fact, over the period 2007 – 2010 at [Text Deleted] there were no inspections at all; yet 255.25 hours have been charged. We know from discussions with HSE that consultants were involved in the Safety Report assessment in Liverpool in 2008, and we believe that this has contributed to the extra hours charged during that year.
A noticeable increase in charged hours has been due to the Change of Inspectors, and now there is a trend to bring in additional specialists.
The number of HSE inspections has steadily increased going from 3 in 2007/2008 to 10 in 2011/2012.
Through the worst recession since the 30s HSE have charged COMAH sites at a considerably high rate and continues to do so!
COMAH SITE CHARGE SUMMARY:
A major factor to consider commercially is the length of time it takes to gain formal consent through the local authority. The time can be considerable and from experience the period can extend well beyond 6 months, and has taken over 12 months or more in some cases. This is a considerable burden to industry and the supply chain as a whole.
3 or 4 years ago there appeared to be no consistency of approach in the inspection regime and now this has improved over the last few years. We are now not jumping from one theme to another. At one stage Human Factors was being pushed by HSE at the same time as Process Safety Performance Indicators.
HSE have been helpful in recent years providing guidance when asked for it, however, I would like to see HSE across the board being supportive of industry and not just simply acting in regulatory mode. We need to all have the GB label approach to help industry compete with a Global market.
The recent change by HSE of visiting the site 6 months before the Safety Report is due is seen as a positive move by HSE and will save Industry and HSE costs as a result.
HSE Newcastle were especially helpful in explaining how to set Leading and Lagging indicators for our Process Safety Performance Indicators which now have been implemented across the Group, and this includes non COMAH sites.
A cause of frustration for us as a Company with 3 COMAH sites is the frequency that the site Inspector changes, some have changed at below the 2 year point, just when we have been building up the relationship with the Inspector! We would request that HSE aims to have greater stability in their Inspector terms of office in all regional areas.
Potter Group Logistics
13 June 12