All European health, safety and environmental legislation requires a risk assessment to be undertaken. The output of the risk assessment is decision based – are we doing enough, or do we need to do something more?
In lots of cases, adherence to the requirements of accepted good practice guidance (AGP) is sufficient to make this decision – in a sense the risk assessment has already been undertaken by others by determining what risk reduction measures are necessary and including them in the guidance. However, for some situations, particularly where the hazard or risk is significant, further measures above and beyond those stipulated in AGP are necessary.
The UK’s primary process safety legislation is the Control of Major Accident Hazards (COMAH) Regulations. They place a general duty on operators to take all measures necessary to prevent major accidents and limit their consequences to people and the environment. The Regulations recognise that risks cannot be eliminated, and so prevention should be based on the principle of reducing risks to levels that are as low as reasonably practicable (ALARP) for human risks and use of best available techniques (BAT) for environmental risks.
The Dangerous Substances and Explosive Atmospheres Regulations (DSEAR) place similar duties on employers to assess potential risks to employees and others whose safety may be affected by the use or presence of dangerous substances in the workplace.
Demonstrating that risks are ALARP requires answers to three questions:
- What can go wrong?
- What systems are present to prevent, control and mitigate the things that can go wrong?
- How do we know that these systems are effective?
Question (1) can be answered through a robust and proportionate hazard identification (HAZID) study followed by consequence and frequency assessment to determine the attendant risks. This will often require other risk assessment studies such as task analysis and human reliability assessments (HRAs), occupied buildings risk assessment (OBRA), layers of protection analysis (LOPA), gap analysis against accepted good practice, environmental risk assessments, and cost benefit analysis.
Question (2) relates to the procedural systems employed to manage the hazards and risks throughout the process safety lifecycle. This requires adherence to relevant codes, standards and good practice guidance for design, operation and maintenance.
Question (3) is concerned with how the organisation learns and continually improves, and so includes accident and near-miss investigation, performance indicators, benchmarking, audits and management review.
Our understanding of current regulations, codes, standards and accepted good practice guidance across a range of industries, coupled with our risk assessment methodologies and experience in developing and implementing management systems means we can help you to maintain compliance at every stage, through design, installation, commissioning, operation, inspection, maintenance, modification, decommissioning and demolition.
We have worked with more than 25% of the UK’s highest hazard sites and have written COMAH safety reports for more companies than anyone else. From Government owned facilities to large multinational corporations across all process sectors, we are trusted to provide essential guidance and support.