Health
Healthand
andSafety
Safety
Executive
Executive
HSE/SIESO Workshop
Competent Authority Guidance for
Inspectors on Emergency Arrangements
for COMAH Establishments
Melanie Taylor
Hazardous Installations Directorate
MIIB EPRR Report:
CA Considerations
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COMAH Competent Authority (CA) to
consider:
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improving its guidance for producing onand off-site emergency plans, having
regard to integration of the requirements
under COMAH with those established
under the Civil Contingencies Act (CCA);
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check that those with legal duties under
COMAH are discharging them.
Basic Principles
“Effective emergency
response depends on clear
and concise emergency
plans, trained and
experienced responders and
a well informed community”
MIIB EPRR Report:
CA considerations
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Legal requirements
Relevant Recommendations
COMAH and CCA interface
COMAH Legal requirements
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On-site plans
Off-site plans
Review and testing
Implementing
Information to the public
Information to the CA
Information to other establishments
MIIB EPRR Report:
Recommendations
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Assessing the potential for a major
incident
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Managing a major incident on site
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Recovering from a major incident
Preparing for and responding to a
major incident off-site
COMAH and CCA interface
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Risk Assessment
Emergency Planning
– Extendibility
– Command and Control
– Communications with the public
MIIB EPRR Report – CA actions
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What does this mean in practice?
COMAH off-site emergency plans
Regulation 10(1)
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The local authority, in whose area there is
an establishment, shall prepare an
emergency plan (in these Regulations
referred to as an “off-site emergency
plan”) in respect of that establishment,
and such a plan shall be adequate for
securing the objectives specified in Part 1
of Schedule 5 and shall contain the
information specified in Part 3 of that
Schedule.
CA guidance
COMAH Regulation 10(1)
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Existing
– L111
– Annex 5
– Annex 15
– DG7b
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New
– Annex 8
– Annex 9
– Annex 10
– Annex 11
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Chapter 19 “Emergency Preparedness”
Preparation of off-site emergency plan [Regulation
10(1), Schedule 5 Part 1 and Part 3, Regulation 10(2)]
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Further information can be found in Annex 15 and “A
guide to the Control of Major Accident Hazards
Regulations 1999 (as amended) paragraphs 249 – 258
There is further information in the following annexes:
Annex 8 Competencies for emergency planners
Annex 9 Working with Resilience and Emergency
Division (RED) in England and arrangements in devolved
administrations
Annex 10 Extendibility
Annex 11 Command and Control and COMAH off-site
Response
Please see Chapter 19 “The Fit with Other Legislation”
paragraphs 19.19 – 19.20, 19.21 – 19.22 of “Emergency
Preparedness”
CA guidance
COMAH Regulation 10(3)
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An operator shall supply to the local
authority in whose area the establishment
is situated the information necessary for
the purpose of enabling the authority to
prepare the off-site emergency plan
CA guidance
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Existing
– L111
– SRAM Criteria 14.7
– Annex 12
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New
– Annex 14
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Chapter 19 “Emergency Preparedness
Provision of information Regulation 10(3)
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Included at Annex 12 is a template (RCS 8)
which may assist emergency planners
reviewing the adequacy of operators’ on-site
emergency response arrangements.
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Further information can be found in the SRAM
Criteria 14.7.
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mutual aid arrangements can be found in
Annex 14.
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See also Chapter 19 “The Fit with Other
Legislation” paragraphs 19.5 – 19.10 (Risk
Assessment) of “Emergency Preparedness”
CA guidance
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HSE website
– COMAH home page
References
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www.buncefieldinvestigation.gov.uk/reports/prep
aredness.pdf
www.cabinetoffice.gov.uk/resourcelibrary/emergency-preparedness
www.hse.gov.uk/comah/notification/index.htm
www.hse.gov.uk/comah/buncefield/fuel-storagesites.pdf
www.cabinetoffice.gov.uk/resourcelibrary/emergency-response-and-recovery
www.scotland.gov.uk/Topics/Justice/publicsafety/ready-scotland/Government/Preparing
www.hpa.org.uk