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COMAH cost recovery: Information on queries and disputes

The Health & Safety Executive, Environment Agency, and Scottish Environment Protection Agency recover the costs of the regulatory activities of the Competent Authority (CA)1 under the Control of Major Accident Hazards Regulations 1999 (as amended) – ‘COMAH’. The COMAH cost recovery scheme covers the CA’s work in carrying out its COMAH functions, enforcing COMAH regulations, and (at ‘Top Tier’ sites only) work associated with securing compliance with other health and safety regulations COMAH sites.

Invoice queries and disputes

The CA has in place arrangements to offer help and advice for COMAH operators wishing to clarify routine issues such as how and when to make the necessary payments. There are also occasions when operators consider they have been inappropriately charged, or their invoice might be wrong. Where operators raise this type of query, the CA aims is to resolve it promptly and fairly. However, sometimes it may not be possible to reach agreement, and then operators have the right to dispute formally the charges invoiced by the CA. The table below provides information on the number of invoices issued, the number disputed and where these challenges have led to an adjustment in the disputed invoice. You can find details about the dispute process at 'Procedure for Queries and Disputes for COMAH Cost Recovery'.

Number of invoices and related disputes

Work period Invoice issue date2 Total number invoices issued3 Number of disputed invoices4 Number of invoices adjusted5
April 2012 – June 2012 Jul-12 781 1 1
July 2012 – September 2012 Oct-12 738 3 0
October 2012 – December 2012 Jan-13 990 1 1
January 2013 – March 2013 Apr-13 959 4 1
April 2013 – June 2013 Jul-13 771 1 0
July 2013 – September 2013 Oct-13 720 0 0
October 2013 – December 2013 Jan-14 1045 4 2
January 2014 – March 2014 Apr-14      
Total   6004 13 4
  1. The COMAH Competent Authority comprises HSE and the Environment Agency in England and Wales, and HSE and the Scottish Environment Protection Agency in Scotland. From 1 April 2013 a new Welsh environment agency will be created.
  2. Invoices for work undertaken in the quarter are issued at the start  of the next quarter
  3. The total number of invoices issued in the quarter.
  4. The total number of invoices disputed in the quarter, which may include d invoices issued in previous quarters.
  5. The total number of invoices adjusted in the quarter.
Updated 2014-04-15