Criterion 3.2 "The safety report should demonstrate that the Operator has used information and data that are suitable and sufficient for risk analysis."
A key requirement of the regulations is that information provided about the installation and its hazardous substances is suitable and sufficient for a risk assessment. When considering this part of the safety report, the Assessors should ask whether it provides answers to the following questions:
The site Operator should specify the types and quantities of explosives that could be present at each location at the installation. This information will determine whether the installation falls within the remit of COMAH and, if so, whether the installation is to be classed as a lower-tier or top tier site. Further guidance on this matter is given in Appendix 1.
The safety report should describe the site and site operations so that accidents having severe consequences can be identified. The detail provided needs to be sufficient to enable Assessors to determine whether the accident analysis is thorough and complete.
The Operator should identify all the buildings and other facilities on site where explosives might be present - these building and facilities are conveniently referred to as potential explosion sites (PES) - and list the types of processes undertaken at these locations along with the types and quantities of explosives present. This information can quickly be determined by reference to the explosives licences issued by the Health and Safety Executive. These licences specify the maximum quantity of explosives that can be present in buildings such as workshops, magazines, transit bays, etc. The Operators of the installation should list all PES and the associated licence limits for each type of explosives. It is not necessary to provide copies of the licences with the safety report but these should be referred by the licence numbers or reference numbers, e.g. Licence Number 0999 or X1/4111/999/9, noting if they have been subsequently amended.
Failure to identify all PES and provide clear descriptions of the activities undertaken, or failure to list the types and quantities of explosives present at PES would preclude independent evaluation of the likelihood and consequences of explosives events and should be viewed as a major shortcoming.
Where danger buildings in a factory or magazine are sited in accordance with the licence to conform to the internal and external distances in published Quantity-distance (QD) tables, little further information needs to be supplied regarding the prevention of communication of explosion effects from one building to another. However, where the licence incorporates arrangements that allows for larger quantities to be treated as a unit risk, e.g. by segregation into compartments, the safety report should identify how this is achieved and the basis for the design used. Similarly, where QD tables have not been applied and reduced separation distances have been accepted in a licence, a description of the mitigating circumstances behind these reduced distances and demonstration of how they are maintained should be included in the safety report.
The safety report should contain brief descriptions of the operations undertaken in the danger buildings. Brief descriptions should also be given of the arrangements for bringing explosives onto the site, taking explosives off the site, and moving explosives between buildings on the site.
A suitable and sufficient risk analysis can only be achieved if all relevant information required at Schedule 4, part 2, paragraph 3 is supplied and the quality of that information is consistent with the need for proportionate risk analysis. This information required is largely specified in the SRAM’s Descriptive Criteria; the information requirement outlined below is that necessary to enable Assessors to check the background data for the risk analysis.
The safety report should contain a map of the installation to a scale large enough to show any features that may be significant to the assessment of the hazard or risk from the operations undertaken (an Ordnance Survey map of scale 1 to 10,000 should provide the necessary detail). The map should show the location of the installation and its relationship to local features such as: -
The most up-to-date map available should be used and any recent changes of significance should be marked. In those cases where there are many features in the vicinity of the installation for which information is required, the use of a tabular form referring to points marked on the map may be appropriate.
A plan of the installation to a scale of 1 to 2,500 or better should also be provided. Again, the plan should be the most up-to-date available and any recent changes of significance should be accurately marked. The plan should be large enough to cover the entire area of the installation and show:
Information relating to the PES could be conveniently summarized in tabular form as shown in Table 3 [57.9KB].
A full description of each ES should also be given, and this should include:
Again, this type of information could be summarised in tabular form, as shown in Table 4 [57.9KB].
The safety report should clearly describe any measures in place to limit the extent of explosives involvement in the event of an accident and to contain the effects of explosions and fires. Fire-extinguishing systems and any engineered measures for breaking detonation waves should be described and the design of those measures justified by reference to established standards, trials, etc. Operations which are claimed to be "remote" should be truly remote, and the means by which protection is afforded to personnel in control rooms and other areas should be clearly set out and again justified by reference to standards, trials, etc.
A safety report should present the entire chemical, physical, toxicological and eco-toxicological information that is needed to calculate risk to people and the environment. Toxicity data should also be provided for any toxic substances produced by combustion.
Public Register of COMAH Establishments
