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nic168  
#1 Posted : 23 January 2015 09:05:17(UTC)
Rank: Super forum user
nic168

Good morning, I am hoping that there is some one out there who works on a site with COMAH requirements that we can visit. Some of my collegues are currently working on a couple of reports of this type and are having difficulty in determining exactly what is required for the report- keeps getting kicked back by the regulator. I think that it would be useful to compare notes with others who have similar responsibilities, is there anyone who could let us visit for a couple of hours, preferably in the South west? Many thanks,
imwaldra  
#2 Posted : 23 January 2015 10:50:07(UTC)
Rank: Super forum user
imwaldra

I don't think you'll learn that much about how to compile a suitable COMAH Report in a couple of hours on a site visit. Have your colleagues carefully studied all the guidance available on HSE's COMAH website, including links and references?
Ian Bell  
#3 Posted : 23 January 2015 11:46:46(UTC)
Rank: Super forum user
Ian Bell

Agree. A COMAH safety case report is not a 5 minute report. Sure site visits help you to understand the scope of the activities etc. If you are just going to visit a COMAH site by invitation, how does this match the COMAH report you are trying to write - if you are writing a report for a different site? COMAH sites vary. There is often lots of background research and assessments. As previous, read the relevant HSE guidance and technical documents relevant to the processes/COMAH activities. Have you not done this? Scary....
stevedm  
#4 Posted : 25 January 2015 10:49:00(UTC)
Rank: Super forum user
stevedm

Have you checked that your report meets every section required of the SRAM? My spidey sense is tingling...competency?
nic168  
#5 Posted : 26 January 2015 11:02:00(UTC)
Rank: Super forum user
nic168

Good morning, thank you for your considered responses. My earlier comments on this seem to have vanished into the ether so I will try again. Steve, your spidey senses are way of in this instance- the guys who are doing these assessments are well trained and experienced in Environmental protection as well as Safety matters. We work for a government department which has it's own variation on COMAH as well as internal regulators for COMAH type matters. The reports in question are comprehensive and detailed, the result of several site visists as well as scrutiny of plans and documenttaion and discussion with site personnel, they are not lightweight, 5 minute jobs! In fact part of the concern relates to the ever increasing size of the reports, which apparently have to be hard copy- If it gets any bigger I may have concerns over MH. The problem is that there seems to be some variance between our regulators interpretation of legislation and guidance and the understanding of the requirements the team preparing the reports have based on the available guidance. Hence we thought it would be useful to see how other industries tackle this, none of use are under the illusion that a site visit is a quick fix for any of our reports. We thought there might be some benefit in stepping back and looking at an external organisations approach. Annic
stevedm  
#6 Posted : 26 January 2015 12:19:27(UTC)
Rank: Super forum user
stevedm

well it woudn't have tingled if you had stated this in the first place...the implication was that they guys didn't know what they are doing wrong.. Having worked in both environments MOD safety cases and COMAH......I would get someone to carry out a review based on the SRAM v JSP 00-56..needs to be as independant as you can get it as the interpretation of requirements could just be as simple as one guys view against yours. If you push back a little as a result of the review you may find they accept it..? Spidey sense intact... :) Cheers
jay  
#7 Posted : 26 January 2015 12:21:36(UTC)
Rank: Super forum user
jay

If the site organisation is a member of the Chemical Inductries Association (CIA) , there is good networking in the CIA Responsible Care Cells Network to potentially share such infomation
jumponthebandwagon  
#8 Posted : 26 January 2015 13:49:24(UTC)
Rank: Forum user
jumponthebandwagon

HSE labs in Buxton provide a few good COMAH courses, a colleague recently attended this one and thought it very worthwhile http://www.hsl.gov.uk/he...of-comah-safety-reports. Your bible should be the SRAM document
nic168  
#9 Posted : 27 January 2015 14:25:03(UTC)
Rank: Super forum user
nic168

thanks Jay, sadly none of our sites are members of the CIA, although I might see the afflicted collegues can log into the CIA webpages. Steve, I have PM you seperately. Jump- I will look into the courses for my benefit, as I am begining to get interested in this myself, Annic
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