Updated Apr 27, 2020

HSE publishes guidance for COMAH sites during the COVID-19 outbreak

The Health and Safety Executive (HSE) has published a series of guidance pages for operators of major hazard establishments, COMAH sites, under the Control of Major Accident Regulations SI 2015/483. The guidance covers specific COMAH requirements during the coronavirus outbreak, including:

Managing staffing and fatigue at COMAH sites

The guidance document on Staffing and fatigue at onshore major hazard establishments during the coronavirus (COVID-19) outbreak is important for COMAH establishments that are part of critical national infrastructure. It addresses the overall risk increase that may occur at these sites during the coronavirus outbreak from a reduction or loss of key staff and increased fatigue.

Site operators should assess the risks to ensure continued safe running of the site and determine worst-case scenarios when it may be that some or all operations have to stop.

This particular guidance document is only for use during the coronavirus outbreak and looks at short-term variations to assessing and managing fatigue and staffing at sites.

COMAH safety reports

The HSE guidance page on COMAH safety reports during the coronavirus (COVID-19) outbreak advises on the submission of safety reports and scenarios that may occur during the current outbreak.

Generally there are no exceptions made to an operators' duties under COMAH, and failure to comply with requirements will be considered a breach. However the COMAH competent authority understands the potential impact of the coronavirus outbreak on establishments and is engaging with COMAH businesses to manage this.

Where a COMAH establishment intends to make a change that would trigger a new or revised safety report that is directly related to coronavirus response or impacts, but the current circumstances prevent them from producing such a report, they should speak to their CA COMAH Intervention Manager (CIM) as soon as possible.

It is vital that operators still ensure the risks are being appropriately managed with appropriate control and mitigation measures in place.

Five year reviews of safety reports are also essential to be undertaken, and where an operator believes a revision is necessary, but circumstances prevent this, they should speak to their COMAH Intervention Manager about timings as soon as practical.

Planned external emergency plan tests

The HSE guidance page on Planned external emergency plan tests under COMAH during the coronavirus (COVID-19) outbreak sets out the COMAH Competent Authority position on requests to postpone or cancel external emergency plan tests for COMAH upper tier establishments during the coronavirus outbreak.

The COMAH Competent Authority recognises that emergency resources normally involved in testing external emergency plans are likely to have been diverted elsewhere due to the outbreak and will be unable to participate in tests.

Emergency planners may still need to check the resilience and continuing operability of their plans and explore alternative ways to do this. Full testing of external emergency plans should resume once circumstances permit.

COMAH notification requirements for businesses supporting the coronavirus response

The HSE has also published a guidance page on COMAH notification requirements for businesses supporting the coronavirus (COVID-19) response.

It contains advice on:

  • businesses normally out of scope entering COMAH through coronavirus;
  • renotification requirements for existing COMAH sites;
  • COMAH notifications for nuclear licensed sites;
  • enforcement considerations;
  • safety reports for COMAH upper tier establishments; and
  • hazardous substances consent.