Posted By Richard Beevers A query for anyone with a lot of COMAH experience (or perhaps a HSE inspector on the hazardous industries side?) If the reporting line for nthe H&S manager on a top tier COMAH site were changed from direct into the chief executive to reporting via the production manager - would that have a significant impact on the acceptability of the COMAH report? Any views / Quick answers much appreciated. Al.

Posted By Andy Brazier No reason why your COMAH report should not be acceptable under the new organisation. But it is an organisational change that you will need to risk assess. You then need to demonstrate that both the new organisation is acceptable and you can make the change without causing problems during the transition. Your risk assessment should identify the potential negatives of the change. You can then identify controls necessary to avoid the negatives and also point out any positives (in relation to risk management). Part of your risk assessment should be considering whether it is a significant change. If it is you may need to inform HSE and I guess they could ask you to reissue your safety report. However, I would suspect that it is something for you to include as part of your future requirements for updating and resubmission, which may be some years away.

Posted By Ian D. Hi Richard Have a look at the HSE's Chemical Information Sheet No CHIS7 "Organisational Change and major accident hazards" (should find it using the HSE search engine) it identifies the pit falls, the shortcomings and offers guidance on how to manage change. Will not give you a yes or No answer but will help you go though the correct thought process. The main thing to ask is has the Production Manager got sufficient authority to make the big decisions on the site, who is the controlling mind etc ? Good luck. Ian