Revision and Update of COMAH Safety Report

Our client manufactures a variety of explosives and propellants for use in defence, security and commercial markets. As such the site is regulated under the Explosive Directive and COMAH as an upper tier operator.

Ahead of the 5-yearly submission of their COMAH safety report update to the Competent Authority, the client reached out for help in addressing revision plan items raised on earlier submissions and intervention visits.

Arthian supported the revision and update of the COMAH safety report.

Arthian kicked off the work with a familiarisation visit to site and review of the Competent Authority (CA) feedback against site data. Arthian identified and prioritised tasks which would support the client to provide a response to the CA Request For Information (RFI).

As the site is regulated under the Explosive Directive a key control is the use of Safety Cases to document the assessment of all processes associated with the handling of explosive materials. The CA had raised queries around the completeness of the major accident identification for any processes on site not directly covered by Safety Cases. Arthian supported a major accident hazard identification (MAHAZID) to focus on the handling of any COMAH substances not directly covered by Safety Cases.

Arthian then updated the predictive aspects chapter of the Safety Report to further describe the methodology applied, and to ensure a complete and robust identification and assessment of all COMAH major accidents was documented.

An updated Environmental Tolerability Risk Assessment in accordance with the Chemical Downstream Oil Industries Forum (CDOIF) guideline was required because they hold potentially environmentally hazardous materials, and materials with physical hazards. Arthian applied their multidisciplinary team of process safety engineers, contaminated land experts and ecologists to map the path of the contaminants to the water and soil environments, considering scenarios such as drainage failure and deposition of toxic combustion products from burning of waste materials.

As part of their duties to demonstrate All Measures Necessary and Continuous Improvement, Arthian supported an As Low As Reasonably Practicable (ALARP) demonstration and Cost Benefit Analysis (CBA) of proposed risk reduction measures (RRMs).

Arthian supported the site in updating all other aspects of the COMAH safety report, providing a trusted partner to support the site resources.