Comment by: John Isherwood
Focus area: Chemicals
Regulator concerned: Environment Agency,Health and Safety Executive (HSE)
Apologies for the last minute submission and the potential randomness of these comments;
HSE / EA inspectors continuously changing – Site familiarisation requirements to bring the inspector upto speed with each site. No feeling of continuity across the board at any of the 5 company COMAH sites.
Intervention Plans for sites – suggesting multiple days to inspect items that once the inspector arrives only takes a matter of hours – somewhat related to the comments above.
HSE / SEPA – Road tanker reviews of the Grangemouth site. The intended application of storage requirements on “transit” items. The feeling here that the CCA review of these road barrels at the site during the Safety Case review was overly strenous.
SEPA – the requirement of the Scottish Upper Tier site to re-review its Environmental assessment against a document not even in the public domain, nor indeed even complete against its ongoing review by third parties.
The change of distance involved in the Environmental assessment from 1km to 10km during the process, incurring additional costs.
Again, apologies for the breifness of these comments. This information has been completed at the 11th hour. Should you wish to obtain more information please feel to contact me via the email address supplied.