MOVING FORWARD FROM ASSESSMENT TO INSPECTION - HOW GOOD IS COMAH?

摘要

The COMAH Regulations 1999 set dates by which operators of Top-Tier' sites have to produce safety reports, and the key one of February 2001 having passed means that the majority of UK operators have now completed their first reports. Only those that were not designated new major accident hazard sites prior to COMAH need not yet have done so, and these have until February 2002. So what has been the experience so far of the standard of reports and the likely effectiveness of them in preventing major accidents? Certainly the first two years has not been trouble free, as the two parts of the Competent Authority (CA) have begun to work together, operators have struggled with the requirement for demonstration of safe operation, and both operators and regulators alike have met the challenge of the workload involved in COMAH. The paper will review the outcome of the first round of safety reports, and the CA's priorities for dealing with initial assessments. Most importantly, the paper will look forward to the next phase, as the CA begins to move from assessment of reports to inspection of COMAH establishments. Using case studies of two actual incidents that occurred at top tier sites before submission of the safety reports, the question of how likely it was that the incidents might have been prevented if the safely reports had been available and assessed will be examined. Finally the paper will outline some of the particular challenges for the future, for both the CA and industry, as COMAH develops and the public become more aware of the changes it introduces to control of major accidents.