man in high-vis and hard had on site

Operating a COMAH establishment during a global pandemic

Julian Hought Director UK Process Industries Sector
Julian Hought

Julian  is a chartered engineer with over 28 years’ experience in the chemical industry. He has an established track record covering research and management of engineering and regulatory compliance functions on high hazard manufacturing sites. Much of his experience spans safety in design, construction, commissioning, operation, maintenance, modification and decommissioning of process plant within the chemicals, pharmaceuticals, oil & gas, energy and general manufacturing industries.

2020 has been a turbulent year and many of us have had to adapt to new ways of working. As an operator, you will have likely been following the guidance and introducing new safety measures including route signs, hand sanitiser stations and providing appropriate PPE etc. We recently spoke about the safety critical procedures that operators should be considering when returning to work, including ensuring assessments are made on any organisational changes that have been adopted on site, for example with staff working from home or operating with different shift patterns.

In this article we discuss some important issues facing COMAH sites right now.


  1. COMAH Regulations

Whilst adopting changes to work safely during the pandemic, as a COMAH operator there is also the specific duty to take all necessary measures to prevent major accidents and mitigate the effects of those that do occur to people and the environment. Despite the circumstances that have been created by the current COVID-19 crisis, that requirement still stands. So as operators of high hazard sites, you have a duty to adhere to all the relevant legislation and be able to demonstrate this as requested by the COMAH Competent Authority (CA). Safety critical tasks should still be performed and COMAH Safety Reports are still required to be submitted and/or reviewed within a reasonable time frame. The pandemic has not changed the rules around compliance with the regulations [1].


  1. Staff levels and fatigue

Maintaining business as usual amid a pandemic has proved a challenge for most businesses. However, for COMAH sites, the implications are much more challenging. Safe operation and maintenance of plant will rely upon a core skillset and specific staffing levels to ensure adherence to safety critical procedures. When gaps in competence appear due to absence, or because of limits placed on staffing volumes on site, this presents a significant problem. Equally, as those on site are spread more thinly and begin to suffer fatigue, the problem is compounded. Fatigue in staff can lead to reduced vigilance and attention, and to errors and accidents causing ill health and injury. Assessments should be made as to what can be safely achieved with a reduced capacity of staff in place and then determine whether in a worst-case scenario, some operations may have to be discontinued until they can be safely resumed. The first step would be to refer to your management of change processes, which such risk assessments would fall under [2].


  1. Site inspections and spot checks

The HSE have been continuing with inspections and spot checks throughout the pandemic on all types of businesses in all areas, including those with commercial fleet operations. Checks are being made to ensure that businesses are managing the risk of Coronavirus to their staff and customers. The HSE have been utilising several different ways to gather intelligence and reach out to businesses with a combination of site visits, phone calls and through collecting supporting evidence such as photos and video footage [3]. As well as checking for Coronavirus compliance, the HSE are also still running a site inspection programme across the country for general COMAH compliance. Operators should be aware that these checks could take place at any time, so process safety standards shouldn’t be compromised due to the pandemic. Standard operating procedures (SOPs) are critical in stabilising production, reducing variation and ensuring safe working so it is vital that you have robust procedures in place.

For COMAH operators, keeping up to date with the rules and requirements is crucial to the safe operation of sites and ensuring that you are not at risk of enforcement action from the CA. As leaders in SOP good practice, we are here to help you with all aspects of the COMAH Regulations including risk assessmentsreview of SOPs, and human factors issues. We understand the constraints within socially distanced environments and can provide support to you where necessary.

Now part of SLR, HFL Consulting recently held a webinar on how COMAH sites can safely return to work and perform safety critical tasks in relation to COVID-19. You can register to listen to the webinar here, and as it has already taken place you can listen again at any time.

For more information please don't hesitate to get in touch