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COMAH Charging Review Group

Minutes of the Meeting held on 8 October 2003


Mr Kevin Allars, Chairman, HSE

Industry Members

Mr Tom Fidell - LPGA
Mr Bill Smith - Transco
Mr Nathan Bishop - UKPIA
Mr Nick Berentzen - CIA

Competent Authority Members

Mr Bill Tomkins - HSE
Mr Ron De Cort - HSE
Ms Lesley Stanley - HSE
Ms Paula Moorhouse - HSE
Mr Wil Huntly - EA
Mr Kelvin McFadyen, HSE - Secretary

Welcome and Introductions

1.The Chairman welcomed everyone to the meeting. He explained that a reorganisation in HID had split the former Land Division from 6 October and he was now head of the Chemical Industries Division which covered the inspection, assessment and enforcement of the Chemical Sector, and in particular the COMAH activities. The aim was to give the industry a better focus. Dan Mitchell remained with HID with responsibility for Explosives, Mines and Pipelines. The Chairman gave a brief resume of his experience and a round table of introductions and responsibilities followed.

2.Apologies had been received from Clive Musgrave (Transco), for whom Bill Smith was deputising; Ian McPherson (UKPIA) for whom Nathan Bishop was deputising; from John Burns (SEPA), David Bosworth (HSE), Paul Wesson (BOC Gases) and Andrew Hitchings (EA). Jude Grandison had replaced Mark Platt as the CBI contact. Nigel Bryson had left the GMB and the Secretary would be asking the TUC if they wished to nominate a replacement.

Action: Secretary

3.Members learned with regret than John Sherwood (E&E Ltd) had recently passed away.

Minutes of the Meeting of 9 October 2002

4.The minutes had been circulated and published on the Internet, and were accepted.

Matters Arising

5.Three actions at minute numbers 19, 24 and 26 had all been discharged.

Charging Efficiency Project (CEP)

6.Members were presented with a brief update on the recommendations from this project (CCRG 2003/6). Dr Fullam had made a presentation on his report to industry in May. There were a large number of recommendations, some of which could have a significant impact on costs and others that would have little effect. Prior to receiving this report a wider change process had started in HSE. The CEP recommendations impinged on efficiency across HSE, not only the charging regimes, and fitted in with the change process. Therefore it was decided that the CEP recommendations should be taken forward as part of these overall change processes within a wider Corporate Support Review (the implementation of which the meeting Chairman had headed up for the past 4 months). There will be no immediate impact on costs, although the staffing efficiencies are now starting to be made. It also had to be recognised that some recommendations would have significant start up costs that may feed into charge out rates before benefits can be realised. The HSE-wide nature of the reviews meant that it would be difficult to say categorically whether any savings were solely due to the CEP.

7.Industry expressed its disappointment with the paper as some member organisations had had a further meeting with Dr Fullam where he had indicated percentages and time frames for the savings. The tone of the paper did not now seem so positive. HSE emphasised that this was a major change process for HSE looking at everything it does and where, in the organisation, it is done. HSE's main resource is people and there are a lot of people issues involved in this review, which need to be handled carefully and with due regard for individuals' well being. Individual projects were also interrelated. The cost of HSE's estate is being looked at. Rose Court for example is an expensive building, but moving staff out of London is very emotive and there may not be sufficient accommodation in other buildings for them. Flexible working patterns such as home working and hot desking were also being piloted. The review is being tackled in a very structured way and recommendations from the CEP are being picked up and taken forward with it.

8.The Chairman explained that although the industry had been impressed with Dr Fullam's presentation, the percentages that he had given as targets should not be perceived by the industry as significant savings to be realised in a short timeframe. The Chairman said that he had been unaware that such detailed discussions had happened and insofar as indicative figures or timescales had been given they should be treated with circumspection. The main point to be taken from the discussion was that the HSE Board was fully committed to seeking savings and greater efficiency across the organisation and had clearly signalled this intent across the organisation. This was in large part the result of budget pressures - HSE's is virtually the same for each of the next three years and this is true across government. The Chairman undertook to provide an interim report in approximately 6 months in order to the CCRG to keep them informed of progress.

Action: HSE

Proposed Charge Out Rates for 2004/05


  1. HSE Outturn 2002/03 A breakdown of the 2002/03 costs was circulated at the meeting showing that the rate charged that year was correct.
  2. SEPA Rate Members had previously been sent a paper from SEPA (CCRG 2003/5) outlining their rate for 2004/05 and the reasons for its increase of 28% to £120 per hour. Industry respected SEPA's bluntness about their reasons for this increase, but felt it was outrageous and that SEPA should face commercial realities. It was agreed that the Chairman would write to SEPA conveying industry's feelings and concern that no one from SEPA had come to this meeting to explain the reasons for such a proposed increase. Action: HSE (Secretary's note: Action discharged on 31 October)
  3. EA Rate EA said that they have various measures in place to improve efficiency, that they were suffering the same financial constraints as HSE and that efficiency savings would be passed on in their charges. However their pay bill was up and they had difficulty recruiting staff. EA had various income streams which all had to be looked at. The COMAH rate was still undecided for EA, but it was not expected to rise by more than 2.5%. As soon as it is finalised members would be informed.
  4. HSE Rate HSE was required to propose a rate to the HSC and to Ministers for agreement. They would be proposing that the rate remained the same as for 2003/04 (£113 per hour). As soon as Ministers have agreed this, probably around January, members would be informed. HSE agreed to distribute CCRG members with the list of final charge-out rates for each of HSE, EA and SEPA early in 2005.

Action: HSE

Report to the ICRG

10.A skeleton draft of facts had been circulated prior to the meeting; members were asked to agree what else needed to be added from this meeting. It was agreed that Industry's concern that action on efficiency savings was not fast enough and their serious concerns at the SEPA increase should be added. Industry was content for HSE to do this without reference back to them.

Action: HSE

11.It was reported that the need for the ICRG had been raised at the Offshore CRG meeting. It was originally formed to deal with common concerns across four charging regimes. Now it no longer physically met and in view of the settling down of the charging regimes it was questionable whether it added any value. Industry agreed that the ICRG had been useful in the early days of charging but that it was no longer needed. It was also agreed that the CCRG still had a role to play.

Any Other Business

12.The Chairman said that it would be appreciated if all members responded when asked if they were coming to meetings. It saves the Secretary having to guess at numbers for lunch and unnecessarily over ordering.

Date of Next Meeting

13.The Chairman asked whether meetings could conveniently be held in Bootle. No one objected and it was agreed that the next meeting be held in Bootle on 13 October 2005.

Updated on HSE website 03 December 2003

Updated 2008-12-05