COVID-19 and Safety Reports
Summary
Handling of Control of Major Accident Hazards Regulations 2015 (COMAH) safety report submission requirements during the Covid-19 pandemic.
The regulation relating to onsite threshold quantities of stored / used dangerous substances are the Control of Major Accident Hazards Regulations 2015 (COMAH), which are enforced by the Health and Safety Executive (HSE) and the Environment Agency (EA) in England (in Wales it is Natural Resources Wales (NRW); and in Scotland it is the Scottish Environment Protection Agency (SEPA)).
Producers holding above 5000 t of material would become a lower tier COMAH operator, and if a lower tier operator wanted to hold more than 50,000 t they would become an upper tier operator. HSE is facilitating any chemical plants needing to go beyond these limits on a case by case basis, as described in the attachment.
Enabling operators into the COMAH regime is the best approach for competent chemical operations to be able to repurpose their plants to achieve this change in use. There are many chemical plants in the UK that could up their output to produce this material if needed, and if this needs changes in COMAH status HSE will work with operators as needed.
50 l is a limit for storage of flammable liquids in a workplace for operational use, HSE has guidance on storage and use of flammable liquids, with a full suite of guidance. If anyone intending to work in this area is unfamiliar it would be better for sites not to start on this type of work, they will need different equipment and operational procedures and we don’t want to encourage people in to hazardous operations.
A site would have to have hazardous substance consent for flammable liquids to be onsite, this is administered by local authorities with HSE input. This protects neighbouring sites form the hazards of large quantities of materials onsite. As for the flammable liquid guidance, if an operator does not have hazardous substance consent then it would unwise for them to try and start processing these materials.