Rank: Forum user 
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Hi all I work as a safety officer for a large pharmaceutical storage and distribution company. We have had a query from a client on storing a product of 'Arsenic Trioxide' CAS number 1327-53-3 in a quantity of 3KG's Upon checking the regulations of COMAH 2015, Schedule 1, Dangerous Substances, Arsenic Trioxide is listed with a blank box under Lower Tier COMAH establishments and a value of 0.1 of a tonne for Upper Tier COMAH establishments.
My understanding is that a blank box with no value would not allow a lower tier establishment to hold this item. Any assistance of understanding or interpretation of the blank boxes on Schedule 1 of the COMAH Regs 2015 would be greatly appreciated. Many thanks in advance Edited by user 14 August 2020 14:37:04(UTC)
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Rank: Super forum user
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Hi Nicole No, COMAH doesn't apply if you are not a "lower tier establishment" or an "upper tier establishment". Regulation 3 defines the application and Reg 2 defines lower and upper tier establishments by cross-reference to the Schedule you refer to. So, if you don't have enough storage to fall into the threshold to be an upper tier establishment for arsenic trioxide, in the absence of any defined value for a lower tier establishment COMAH doesn't apply. Of course, other legislation will still apply. P
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Rank: Super forum user
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