Planned external emergency plan tests under COMAH during the coronavirus (COVID-19) outbreak
This page sets out the COMAH Competent Authority (CA) position on requests to postpone or cancel external emergency plan tests for COMAH upper tier establishments during the coronavirus outbreak.
Following the Prime Minister’s statement on 23 March 2020, the CA has been considering the implications this might have on planned external emergency plan tests under COMAH.
In light of the current situation the CA will take a pragmatic approach and acknowledges that due to the outbreak, emergency resources normally involved in testing external emergency plans are likely to have been diverted elsewhere and will be unable to participate in tests. Operators and emergency planners will already be using their time to plan for response to the virus, including prevention, control and mitigation of potential major incidents.
Emergency planners may still need to check the resilience and continuing operability of their plans and, where circumstances permit, should explore alternative ways to do this, for example a limited desktop exercise or other virtual communication between involved parties, including operators. Full testing of external emergency plans should resume once circumstances permit.
As the emergency plan test is for the local authorities (LAs) to organise, the intention is not to ask LAs to cancel tests but to agree to any requests for tests to be postponed. Although cancellation of a planned test may constitute a breach of COMAH if the 3-year interval is missed, the CA has sufficient flexibility within its enforcement framework to ensure that any decisions made in such circumstances are pragmatic.
On behalf of the CA, the agencies will inform local/regional resilience partnerships of this position.