Remodelling COMAH \\ Changing the way we regulate major hazards Sarah Shore Programme Manager the Competent Authority

Today’s aims \\ Provide you with an understanding of the changes you can expect to see in how the COMAH Competent Authority will operate the COMAH regime from April 2010 onwards.

The Control of Major Accident Hazards Competent Authority \\ protecting people and the environment from, and limiting the consequences of, major accidents occurring within the onshore chemical manufacturing and process industries.

Failure

Objectives Provide an insight into: \\ Why the COMAH regime has been reviewed and remodelled \\ The remodelled arrangements for the assessment of safety reports \\ The relationship between the assessment and inspection processes \\ The arrangements and procedures for carrying out inspections on COMAH sites

Objectives (cont.) \\ The new risk ranking and performance rating systems \\ The new model for investigation \\ The new CA Enforcement Policy and procedures \\ How operational intelligence will be used to inform CA intervention strategy

Why Remodelling? \\ COMAH was 10 years old in 2009 – a review is timely \\ The UK has an excellent track record in implementing COMAH but there are areas of concern \\ There are many examples of HSE, EA and SEPA colleagues working well together but… \\ there is scope to manage the functions of the CA more effectively

The changes \\ Management of the CA \\ Intelligence and Risk Ranking/Performance Rating \\ Assessment \\ Inspection \\ Investigation \\ Enforcement

A remodelled Competent Authority Gordon MacDonald Director Hazardous Installations Purpose statement Priorities Plan of work Operation - Policy - Business Reporting outcomes Intelligence David Jordan Director of Operations Allan Reid Head of Protection and Improvement

Remodelled intelligence, risk ranking and performance rating \\ inform and direct COMAH policy, priorities and delivery at strategic, operational and tactical levels \\ drive performance monitoring, learning, and public assurance \\ identify future and developing trends allowing preventative and early interventions \\ make the best use of limited resources in focussing on areas of concern and poor performance

Remodelled Assessment \\ deliver tighter arrangements for the timing, pace and conclusion of the assessment process \\ rely on an inspection focussed “read through" to identify issues for the first post assessment inspections to verify demonstrations in the safety report \\ rely on inspection to identify specific topics to pursue in subsequent years \\ improve communications within the regulatory programme

Remodelled Inspection \\ increase our capability to compare safety reports against what is happening on the ground \\ deliver more specialist resource for site inspection \\ place a greater emphasis on multidisciplinary team inspections and less on single topic inspections where appropriate \\ provide the ability to deliver cross-cutting programmes of inspection to assess key national topics \\ Result in better targeted, prioritised and leaner intervention plans

Remodelled Investigation \\ ensure early engagement and exchange of information within the CA following an incident \\ introduce a new protocol to assess information and ensure that appropriate CA oversight is put in place \\ introduce a structured approach to the investigation of Major Accidents \\ ensure the early dissemination of information and learning points via Safety Alerts and other means

Remodelled Enforcement \\ There are no fundamental changes to the way we conduct enforcement \\ There are some important changes designed to improve our working within the CA \\ Remodelled enforcement is consistent with HSE, EA and SEPA existing enforcement policies \\ Remodelled enforcement will ensure that regulatory decisions are more consistent, transparent and timely

Our shared aims \\ protecting people and the environment from, and limiting the consequences of, major accidents occurring within the onshore chemical manufacturing and process industries.

Questions ? Thank you