Hi there, i've been asked by a customer to have a look and try to explain the basics of what their requirements are for the storage of whisky in their new warehouse. 

I have breifly read through the guidance docs on Safety Report Assessments and also had a flick through the COMAH docs. To clarify, i am not operating as an advisor to this client, my speciality is training and not so much in this area. What I am trying to do is break the information down to them so that they have a better understanding of what they actually have to do. 

From what I have read; an assessment will need to be done on the tasks that will be ongoing in the area highlighting the potential causes of a major accident, what the estimated severity of this will be and what measures are in place to prevent this. 

I'm not sure how much depth this will need as from what i understand; once the whisky is in place, there won't actually be much going on other than the occasional visit. I don't know if there will be bottling going on at this site. 

Any help from anyone with previous experiences or if anyone has some documents of their own that they would be happy to share then it would be grately appreciated. 

Thanks 

Graeme Kilgour 

I will happily do a site visit if you need any help – be a lot less product to assess after that! Especially if it’s a decent malt!

What do you think IOSH Forum outing?

Originally Posted by: peter gotch

Hi Graeme

Somewhat odd question for your client to put to you.

Have you looked at the HSE guidance that is specific to maturation warehouses?

Safety Report Assessment Guide: Whisky Maturation Warehouses - Introduction (hse.gov.uk)

You say "new" warehouse - which probably means that a lot of work has already gone into it design whether or not it meets the threshold to be a lower tier or upper tier COMAH site (or if it forms a new part of an existing COMAH site).

Long, long time ago when I worked for HSE, I dealt with fire precautions at several maturation sites - at the time HSE was the enforcing authority for fire precautions - this was well before the forerunner to COMAH!

Essentially you have summed up the ingredients of a Safety Report Assessment - whether or not bottling happens at the site (doesn't at most) is relatively unimportant as the whisky is substantially diluted (thence with reduced fire risk) to enable it to be bottled.

There are a lot of maturation warehouses which date back a very long time. Sheds with asbestos cement roofs and not much thought about ventilation when constructed. Casks stored on racking that may not have met current design standards and subject to ad hoc mintenance.

Your client's NEW warehouse shouldn't have such problems!

However, people will be going in from time to time for many reasons, including testing to check that people haven't been siphoning off the contents of casks - some whisky naturally escapes - the "Angels' share" - if I remember right about 1.5% loss per annum is typical.

Then there will be movements both in and out, with risk of damage to casks or racking. Major racking collapse has occurred in the past, so there could be a lot of casks falling some breaking some not, but potentially a very large of extremely flammable liquid sloshing around.

...and the Safety Report Assessment is all about looking at the potential events, associated risks and the precautions which are "ALARP", synonymous to what is "reasonably practicable".

If it's a brand new facility on green or brownfield then the offsite potential impacts are probably lower than for many existing COMAH sites. HSE get involved in planning applications for sites within the "Consulations Zones" for such sites, but apply deliberately conservative policies to determine "Advise Against" or "Do not Advise Against".

To be honest, your client should know all this!

Thanks for this Peter, it is a strange request and one I would usually turn down as it's not an area i'm too familair with. But whisky is something of a hobby of mine and i think my client has seen my enthusiasm and taken full advantage! 

To clear a couple of things up; it is a 'new' location for them but it is in a building that has been about since the 70's and is having some changes made to it so it can facilitate the storage of the whisky casks. 

Thankfully there will be no racking systems but the casks will be stored on top of each other in a more traditional fashion. I've had a read through the document that you have suggested and was just feeling a bit lost at the exact scale that is required to be assessed and put into the report. I'm assuming that this site might fall into an 'upper teir' building as it is in an area where there are other businesses operating within the vacinity. 

When reading the document it spoke about quantified and non-quantified risk assessments - my plan was to assist by training the client and some of his staff on the risk assessing process and making it slightly more specific to their environment and the differecnes in what they are required to do with this project. I don't know what the HSE would deem as an acceptible level of competency for this report to be but as I have mentioned, the risk assessing process and requirements for standard warehousing operations is something I would be quite comfortable with, but i'm unsure about this side of things. So would like to dig into it a bit more to help create some form of training i can help them out with. 

Thanks 

Graeme 

Hi Graeme

What other establishments are in the vicinity are completely irrelevant in terms of the application of COMAH which is simply about working out the maximum potential storage of dangerous materials - in this case flammable liquids.

So you count how many tonnes of overproof whisky there could be and then use Schedule 1 of COMAH to determine whether the site meets the threshold for being a lower or upper tier esablishment.

The Control of Major Accident Hazards Regulations 2015. Guidance on Regulations L111 (hse.gov.uk)

Of course the neighbours do become relevant when it comes to the Safety Assessment Report.

If your client's staff don't know this, then I doubt that getting you to do a training course for them is suddenly going to make them competent to do a Safety Assessment Report. Somebody needs to be able to work out things like what would happen in a flash fire and many other incident scenarios.

So, for some perspective I would know some of the QQ to ask, but not the right answers to those QQ.

 Well looking at the summary of COMAH and based on absolute  ethanol  with a flash point of  13 °C then I would suggest that the limit before you reach Tier 1 of COMAH is 5000 tonnes since it is not kept at a temperature above its boiling point. The total amount of vapour or aerosol would be minimal  as you are not decanting or anything like that.

Assuming the number of zeroes is correct 1 litre = 785g (before it is diluted to 40° proof)   

5000 tonnes is  6,369,426 litres of whisky

Between 250,000,000  and 280,000,000 litres are produced per year

Well i have just looked at Taliska production, my favourite malt after a diving trip round Skye back in my uni days - they produced 3.5 Million litres a year - and i think it has to be stored for at least 10 years to be called Malt - so yes i guess somewhere there are huge warehouses - Not sure they could store that much on site but been nearly 40 years since i was there.

Chears everyone (or should that be Slàinte mhath which is pronounced slan-ge-var) everyday is a learning day.

guys...even at 40% a 200L barrel holds 80L Ethanol...most would exceed the lower tier limit on that basis...escpecially as in some cases it has to be held for 10 years+...