Safety Alert to operators of COMAH oil/fuel storage sites
The following Safety Alert is primarily for the attention of those
companies operating similar oil/fuel storage facilities.
The Buncefield incident on 11th December 2005 has demonstrated the
capability of a very large hydrocarbon leak to create a massive explosion
with a destructive power beyond the typical ‘worst case’ normally used
for on- and off-site emergency planning purposes, and as the basis for
advice to planning authorities on off-site development options. The
incident is a reminder of the need for operators to maintain the highest
levels of plant integrity and operational capability. There are nearly
100 sites around Great Britain with consent to store quantities of oil or
other fuels that make them subject to the Control of Major Accident Hazards
(COMAH) Regulations 1999.
Whilst the precise causes of the incident at Buncefield have not yet been
fully identified, HSE advises that operators of similar installations:
- review the safety of their operations and plant to ensure that major
accident hazards are being well managed,
- ensure that staff are adequately trained and competent to manage these
- ensure that management systems are robust, and subject to effective
- ensure that relevant good practice precautions are in place and fully
- ensure that there are appropriate measures in place for responding to,
and dealing with, emergencies involving loss of containment.
In order to ensure that this happens HSE has formed an inspection team
charged with developing a staged programme comprising:
Meeting with key trade associations, UKPIA, TSA, CIA, BCDTA and
others as appropriate, to identify a set of issues that operators should
review, so as to ensure relevant good practice precautions are in place.
Also to continue to encourage the trade associations to work with their
members to promote sharing of, and learning from information from major
accident precursor events.
Developing a targeted and nationally consistent action plan.
Writing to all operators requesting they review their operations,
informing them of the forthcoming inspection programme, and asking them to
report the outcomes of their reviews to HSE by Easter 2006.
Step 4: Inspections at all sites covered by this alert, to:
- Confirm the pattern of storage of flammable substances in the tanks on
- Encourage operators to review storage tank utilisation so as to
minimise the potential for off-site risks, whilst also maintaining high
standards of on-site safety.
- Review preventive and mitigation measures in place, including
appropriate safety management systems, to ensure they represent good
- Review the adequacy of maintenance arrangements for storage tanks and
bunds, and their associated safety critical equipment such as level
measuring and alarm systems.
- Check that operators have revisited their assumptions for provision of
equipment for detecting and dealing with loss of containment and
- Continue to encourage operators to review and to promote sharing of,
and learning from information from precursor events, so as to ensure
continued learning of lessons applicable to major accident prevention.
Visits to ALL oil/fuel storage sites that fall under the COMAH
Regulations will be undertaken without delay, and, if
practicable, before the operators complete their further assessment (Step 3
above).When HSE Inspectors visit the sites, or speak
to the operators, they will expect the operators to have made progress with
reviewing their arrangements in line with the Easter completion, and will
discuss any reasonably practicable improvements that should be made at that
time. If necessary, HSE will use its enforcement powers to ensure that
timely site-based improvements are made.
When more precise information on the cause of incident is determined,
further advice will be issued to the industry, together with a plan for HSE
and, if appropriate, the relevant environment agency staff (either EA or
SEPA) to follow up on key issues aimed at preventing a re-occurrence of a
similar incident to that which occurred at Buncefield.
Head of HSE’s Chemical Industries Division
21st February 2006
This SAFETY ALERT has been copied to ALL COMAH operators, together with
UKPIA, TSA, CIA and BCDTA trade association headquarters. It has also
been copied to members of the Chemical and Downstream Oil Industry Forum (CDOIF),
and to COMAH Inspectors in HSE, EA and SEPA.