There is a new “plain English” guidance on “getting the basics right: how to comply with your Environmental Permit”, which is free to download from the Environment Agency website at http://www.environment-agency.gov.uk/commondata/acrobat/basics_2002267.pdf.
This interesting document includes a statement on p9 “for the larger or more complex activities in Schedule 1 of the Environmental Permitting Regulations you would normally be expected to carry out a HAZOP study and for COMAH activities you should follow the COMAH guidance.”
We think this means that if you are Low Impact, you are probably not required to go to full HAZOP standard (although you will need an Accident Management Plan); but if you are “full” PPC/ Environmental Permit, then a HAZOP (or sequence of HAZOPs) will be expected from you.
n.b. If you are also regulated under COMAH, HAZOP will be required to meet COMAH standards anyway.
News article 2nd June 2008