This website uses non-intrusive cookies to improve your user experience. You can visit our cookie privacy page for more information.

Illustrative examples of charges for a range of COMAH establishments 23

  1. This annex contains examples of the level of activity the Competent Authority anticipates it will devote to examination of safety reports and planned inspection under COMAH. This information has been provided to help operators estimate their individual charge under these proposals. Operators are asked to bear in mind that these examples may not be typical of their own business and the effort expended by the CA will be dependent on the quality of the safety report submitted. As COMAH introduces a new regulatory regime, the amount of time and effort the CA devotes to enforcement of COMAH once operational may differ significantly from these initial examples.

Charge rates

  1. The CA hourly rates for 1999/2000 are:

    • Health and Safety Executive £102 /inspector hour,
    • Environment Agency £102 /inspector hour,
    • Scottish Environment Protection Agency £86/inspector hour.

    The hourly charge out rate will be reviewed annually.

    Examination of safety reports under Regulation 17(a)

  2. As part of its preparations for the introduction of COMAH the CA undertook a pilot exercise with a small number of companies to test out the assessment criteria to be used to judge the adequacy of safety reports. The information provided here was informed by the results of the pilot exercise. In each case the report covered an existing establishment but prepared as if it was the first report for that establishment which would fall due under COMAH.

  3. It is expected that the examination of safety reports will involve the following elements:

    • Pre-planning,
    • Receipt,
    • Preliminary examination,
    • Drawing up an assessment plan,
    • Implementing the assessment plan,
    • Assessment outcome meeting,
    • Assessment follow up.

Example 1

  1. An establishment processing crude oil and gas products with a nominal capacity of 500,000 barrels per day and up to 1.5 million barrels of storage. Around 300 employees and contractors work at the site. The safety report is one volume covering all the installations at the establishment. The examination of this type of report is expected to involve:

    Safety assessment - 44 days (325 hours)

    Environmental assessment - 10 days (74 hours).

[Back to top]

Example 2

  1. An unmanned establishment storing over 140 tonnes of natural gas in high pressure vessels and 65 tonnes in a water sealed gas holder at low pressure, with associated on-site transmission and distribution systems. The safety report is one volume. The examination of this type of report is expected to involve:

    Safety assessment - 22 days (162 hours)

    Environmental assessment - 8 days (59 hours).

    [Back to top]

Example 3

  1. A large petrochemical processing establishment receiving hydrocarbons and natural gas to convert them into liquid and solid chemical products. Over 1600 people may be at work on the site at any one time. The safety report is divided into a single core volume, which contains information relating to the overall aspects of the establishment, and nine further volumes, which relate to specific installations on the establishment. The figures given relate to the assessment of the core volume and one of the installation volumes. The examination of these two reports is expected to involve:

    Safety assessment - 31 days (229 hours)

    Environmental assessment - 10 days (74 hours).

    [Back to top]

Example 4

  1. An establishment manufacturing chemical products using ethylene oxide and propylene oxide primarily, plus a number of other dangerous substances. Up to 150 people may be on site at any one time. The safety report is a single volume covering all activities. The examination of this type of report is expected to involve:

    Safety assessment - 32 days (236 hours)

    Environmental assessment - 6 days (44 hours).

    Inspection of COMAH Establishments under Regulation 19

  2. The following section gives details of the expected planned inspection activity for 2 COMAH Top-Tier and 2 Lower Tier Establishments. Typical inspection elements are likely to involve:

    • pre-planning, considering company documentation, making site arrangements,
    • site inspection - meetings, discussion, examination of plant, checking records,
    • reporting, collating and recording information, and follow up to monitor progress.

    [Back to top]

Example 5 - COMAH Top-Tier

  1. A large chemical works, employing 500 people. There are a range of complex chemical manufacturing processes and associated bulk storage, of both raw materials and finished products, in fixed vessels. Reactions are carried out at elevated temperatures and pressures, and both safety and process parameters are managed by operators using computer-controlled systems and equipment. There are flammable and toxic hazards which have significant potential to cause effects off-site in the event of a major accident, including environmental damage.

Typical inspection programme

  1. A five year planned inspection programme, during which the site can expect to have at least one site inspection visit each year. The programme will involve a range of visits on specific targeted topics related to the major hazard potential of the site will comprise a series of inspections to examine standards of safety and control of storage vessels, process plant, and safety management systems. Advice and input from HSE Specialist inspectors will feature in appropriate cases. In at least one year, the annual inspection in the programme is likely to be an audit of one or more elements of the safety management systems that will involve substantial preparation, site and reporting time (possibly up to 30 inspector days).

    Typical annual planned inspection is likely to involve the following resources:

    Safety inspection - 15 days (111 hours)

    Environmental inspection - 6 days (44 hours).

    [Back to top]

Example 6 - COMAH Top-Tier

Site profile

  1. A liquefied petroleum gas (LPG) storage and cylinder filling plant. 10 people employed at the site, one of a number operated by the company nationally. LPG is delivered by road tanker, and stored in bulk vessels. Typical inventory 300 tonnes in bulk vessels, and a further 50 tonnes at any time in cylinders filled at the filling plant. The road tanker bay, storage vessels and filling shed are protected by a fixed-spray water drench system, but apart from this the site hazards and associated safety systems are not significant.

Typical inspection programme

  1. A five year planned inspection programme, during which the site will be visited each year. Years 1, 3, and 5 will be detailed inspection visits with the intermediate years involving less time. HSE Specialist inspectors will visit perhaps once in the five year programme to discuss mechanical engineering integrity of the storage vessels or the provision of fire prevention measures. In one year out of the five, the annual inspection is likely to be an audit of one or more elements of the safety management systems that will involve preparation, site and reporting time by more than one inspector (possibly up to 8 days).

    Typical annual inspection is likely to involve the following resources:

    Safety Inspection - 5 days (37 hours)

    Environmental Inspection - 1.5 days (11 hours).

    [Back to top]

Example 7 - COMAH Lower-Tier

Site profile

  1. A small chemical works, carrying out batch reaction chemical manufacture employing about 40 people. The site stores a range of toxic and flammable chemicals. COMAH applies by virtue of the aggregate quantity, exceeding 50 tonnes, of dangerous substances with a 'toxic' classification. There is potential for off-site effects in the event of a release of some of the toxic chemicals, or a fire involving flammable solvents which might in turn affect the toxic substances.

Typical inspection programme

  1. A planned inspection programme, involving inspection visits on average every other year. A formal, structured hazard assessment will be carried out of the major hazard elements, and an action plan of matters requiring attention will be identified.

    Inspection is likely to involve the following resources once every 2 years:

    Safety Inspection - 6 days (44 hours)

    Environmental inspection - 2 days (14 hours).

    [Back to top]

Example 8 - COMAH Lower-Tier

Site profile

  1. A storage site, storing ammonium nitrate fertiliser with a range of other agrochemicals. At certain times of the year, up to 2000 tonnes of different fertilisers may be stored on site in sacks and in semi-bulk bags. Some storage is in a large warehouse, some outside in the open air. There is no bagging of fertiliser, and no other processes on site apart from loading and unloading of lorries.

Typical inspection programme

  1. The inspection programme will be centred around the completion of a formal, structured Hazard Assessment and is likely to involve an inspection visit every 3 years. Physical conditions on site (control of flammable material, stack sizes, fire fighting provision etc.) as well as records, training and safety procedures will probably be examined.

    Inspection is likely to involve the following resources once every 3 years:

    Safety inspection - 3 days (22 hours)

    Environmental inspection - 1.5 days (11 hours).

2010-03-23