COMAH Lower Tier
A site that falls within Lower Tier COMAH must supply basic details to the Competent Authority (full details are given in Schedule 3 of the Regulations).
Normally, if a site is entering Lower Tier COMAH, the rules on when notification must be made to the HSE are quite straightforward. However, in the period from 1st June 2015 to 1st June 2016, different rules apply, including a requirement for existing COMAH sites to re-notify. For more details, see our COMAH notification page.
All COMAH sites must take all measures necessary to prevent major accidents and limit their consequences to people and the environment.
For Lower Tier sites, A MAPP is required (Major Accident Prevention Policy). This is usually a fairly short and simple document that sets out the policy for identifying and preventing major accidents and details how this is to be achieved. It includes further references to the safety management system that will be used to put the policy into action.
Requirements are less stringent for Lower Tier COMAH than for Upper Tier, although many of the basic requirements are the same, e.g. requirement to identify all potential Major Accidents on Site, requirement to produce an on-site Emergency Response Plan, requirement to carry out (but not submit) and Environmental Risk Assessment etc.
Once you are in Lower Tier COMAH, all visits by the Competent Authority, which is made up of the HSE and your local Environment Agency, become chargeable, even for non-COMAH issues. This also applies to off-site work, such as any assessment of your MAPP etc.
Hazardous substance planning consent should be applied for separately via the site’s Hazardous Substance Authority (usually part of your Local Authority). If the site is entering COMAH Lower Tier because of changes made by the Competent Authority, “deemed planning consent” may apply, otherwise the full planning process will have to be gone through.
TT Environmental can provide help with meeting the requirements of Lower Tier COMAH. For more details, contact Janet on 01422 24 22 22 or email Janet.[/fusion_text]