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smandeir  
#1 Posted : 25 August 2016 16:02:38(UTC)
Rank: Forum user
smandeir

The company I work for need to have a COMAH assessment carried out, to establish whether or not we fall under the COMAH Regs. This is not something I have ever done so wouldn't know where to start.

They are quite happy to commission someone to do this work but we don't have any organisations or individuals lined up to help us out.

Have any of you guys has a Comah assessment carried out? Would you be able to give me the names of a company or individual who might be able to help us out with this work? We are in Tamworth Staffordshire if that is of any relevence.

Thanks in advance.
Ian Bell2  
#2 Posted : 25 August 2016 18:12:38(UTC)
Rank: Super forum user
Ian Bell2

This is something I could do. Sadly I no longer work freelance.

You need to establish what materials (hazard classification - toxic, flammable, highly flammable etc)you have on your site and the quantity/inventory.

Then check the schedules contained within the COMAH regs for the relevant hazard classes and quantities - this will then tell you if you are a Top Tier or Lower Tier COMAH establishment.

If Top Tier you will then need to write a full safety case for the site/MAPP policy etc.
Kate  
#3 Posted : 25 August 2016 18:21:28(UTC)
Rank: Super forum user
Kate

This is quite straightforward to do and can be done by anyone who has access to an inventory of hazardous substances on your site and the ability to follow an algorithm.

As Ian says it is just a case of comparing the quantities of substances of various classes (plus some named substances) with threshold values given in the regulations.

You don't need a specialist to do this.

If you do turn out to be COMAH then it gets a lot more complicated. Best to keep your inventory below those levels if you can :-)
Steve e ashton  
#4 Posted : 25 August 2016 19:05:14(UTC)
Rank: Super forum user
Steve e ashton

I've dealt with several comah (and previously CIMAH) sites over the years. Whilst the initial inventory counting may be straightforward, the consequential decisions can be fairly complex... (Is it worthwhile to knock out some storage capacity to get below COMAH threshholds, for example - which was the approach taken for a large chlorine installation).
Whilst I no longer have much involvement in this end of the safety spectrum, I can recommend a couple of guys I know to be competent if you want to pm me...
PIKEMAN  
#5 Posted : 26 August 2016 13:07:40(UTC)
Rank: Super forum user
PIKEMAN

Note that it is not allowed to keep your inventory under the "COMAH limits" - it depends on "capacity" eg you can't keep tanks half full to avoid being higher tier.
Steve e ashton  
#6 Posted : 26 August 2016 14:24:44(UTC)
Rank: Super forum user
Steve e ashton

Pikeman: by reducing the number of concrete drum cradles in a chlorine storage we reduced the maximum capacity which could be held on site... This during construction of a water treatment plant. Reduced storage reduced reserve capacity and affected resilience calculations but was deemed to be the most cost effective and appropriate way forward at that time. Reduced from top tier to lower tier, so MAPP rather than safety case.... I wrote the MAPP for the facility. Did similar for a flammables inventory store way back when....
smandeir  
#7 Posted : 26 August 2016 15:01:49(UTC)
Rank: Forum user
smandeir

Thanks for all your replies, all very interesting, but what I really need is the name of an organisation or individual who could help us as it is likely to be several weeks work.

Steve, have sent PM, did you see it?

Many thanks again
Ian Bell2  
#8 Posted : 26 August 2016 18:58:32(UTC)
Rank: Super forum user
Ian Bell2

So what do you want? As has been explained, deciding if COMAH applies should only take a short while.

You are right, if you want a full safety case writing, then it will take some time, if you are starting from scratch?

What type of facility are you? What hazardous substance do you hold on site that brings you under CoMAH requirements?
Kate  
#9 Posted : 28 August 2016 08:20:44(UTC)
Rank: Super forum user
Kate

I don't see how this could take weeks. It would take maybe a day assuming you have a list of your hazardous substances, the maximum quantities of each and a safety data sheet for each.

If you don't already have that information, then your problems would seem to be more fundamental than not knowing whether you are COMAH or not.

And anyone could do this for you (or you could do it for yourself), you don't need to headhunt someone with special COMAH superpowers. If you don't want to do it yourself, then any common or garden consultant could do it.
Ian Bell2  
#10 Posted : 28 August 2016 09:40:08(UTC)
Rank: Super forum user
Ian Bell2

DOn't think anybody is disagreeing that to simply decide if COMAH applies is a pretty simple exercise.

What will take weeks/months is writing a full COMAH safety case, if the site is starting from a very low base/low level of compliance.

As you are no doubt aware, COMAH safety case reports can be many hundreds of pages long with lots of background work to justify the report.

In my experience they require the input of many people with experience in different safety/environmental sectors. It does of course, also depend why a site is subject to COMAH.
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