Risk Assessment and COMAH

Stuart Holmes
Unit: Safety
 Risk assessment

A risk assessment is simply a careful

examination of what, in your work, could
cause harm to people, so that you can
weigh up whether you have taken enough
precautions or should do more to prevent
harm. Workers and others have a right to
be protected from harm caused by a
failure to take reasonable control
measures
 Risk assessment (5 steps)

Step 1: Identify the hazards

• Walk around your workplace and look at what
could reasonably be expected to cause harm.
• Ask your employees or their representatives
what they think. They may have noticed things
that are not immediately obvious to you.
• If you are a member of a trade association,
contact them. Many produce very helpful
guidance.
 Risk assessment (5 steps)

Step 1: Identify the hazards (cont)

• Check manufacturers’ instructions or data
sheets for chemicals and equipment.
• Have a look back at your accident and ill-
health records – these often help to identify the
less obvious hazards.
• Remember to think about long-term hazards
to health (eg high levels of noise or exposure to
harmful substances) as well as safety hazards.
 Risk assessment (5 steps)
Step 2: Decide who might be harmed and how
• For each hazard you need to be clear about who
might be harmed; it will help you identify the best
way of managing the risk.
• In each case, identify how they might be
harmed, i.e. what type of injury or ill health might
occur.
• N.B. cleaners, visitors, contractors, maintenance
workers etc, who may not be in the workplace all
the time
 Risk assessment (5 steps)
Step 3: Evaluate the risks and decide on
precautions
• Can I get rid of the hazard altogether?
• If not, how can I control the risks so that harm is
unlikely?
 Risk assessment (5 steps)
• If not, how can I control the risks so that harm is
unlikely?
When controlling risks, apply the principles below, if possible in the
following order:
 try a less risky option (eg switch to using a less hazardous
chemical);
 prevent access to the hazard (eg by guarding);
 organise work to reduce exposure to the hazard (eg put barriers
between pedestrians and traffic);
 issue personal protective equipment (eg clothing, footwear,
goggles etc); and
 provide welfare facilities (eg first aid and washing facilities for
removal of contamination).
 Risk assessment (5 steps)
Step 4: Record your findings and implement
them
You need to be able to show that:
• a proper check was made;
• you asked who might be affected;
• you dealt with all the obvious significant hazards, taking
into account the number of people who could be
involved;
• the precautions are reasonable, and the remaining risk is
low. ALARP.
• you involved your staff or their representatives in the
process.
 As Low As Reasonably Possible (ALARP)

• The definition set out by the Court of Appeal (in

its judgment in Edwards v. National Coal Board,
[1949] 1 All ER 743) is:
“‘Reasonably practicable’ is a narrower term than
‘physically possible’ … a computation must be made by
the owner in which the quantum of risk is placed on one
scale and the sacrifice involved in the measures
necessary for averting the risk (whether in money, time
or trouble) is placed in the other, and that, if it be shown
that there is a gross disproportion between them – the
risk being insignificant in relation to the sacrifice – the
defendants discharge the onus on them.”
 Risk assessment (5 steps)
Step 5: Review your risk assessment and
update if necessary
• Few workplaces stay the same. Sooner or later,
you will bring in new equipment, substances and
procedures that could lead to new hazards.
• Look at your risk assessment again. Have there
been any changes? Are there improvements you
still need to make? Have your workers spotted a
problem? Have you learnt anything from
accidents or near misses? Make sure your risk
assessment stays up to date.
http://intranet.ceas.manchester.ac.uk/OPRAdemo/OPRAHome.asp

Example Risk Assessment

RISK ASSESSMENT
for Management of Health and Safety at Work Regulations
1999

Status: Approved by SSA.

Printed on: 24 August 2010 at 09:58

TITLE OF EXPERIMENT/PROCEDURE
Measurement of Heat Flow using Differential Scanning
Calorimeter

Assessor

Supervisor

PERSONS AFFECTED
Technical and academic staff, CRA and post graduate student

SITE OF EXPERIMENT
ML/C1a

HAZARDS IDENTIFIED
1.Radiation -
2.Pressure- .
3.Chemical-
4.Manual -
RISKS ASSOCIATED
1.hot and cold surfaces -90 to 750C
2.nitrogen gas purge facility low bleed required at all times 30 ml/min
3.covered in COSHH
4.crimping of sample pans - crushing injuries

GENERAL RISK ASSESSMENT PRIORITY RANKING

9

CONTROL MEASURES
Cell surface exposed to user so ensure auto lid is closed , allow the software
program to return cell to ambient temperature before handling any sample or
reference pans and use instrument tweezers at all times.

Current use of gas cylinder will change to piped system asap - but for now
ensure no PTFE tape use during cylinder change-over, regulator used is from
reputable supplier, pipework is not crimped or damaged during use.

Chemicals are covered in COSHH safety documentation.

Sample press must be used in conjunction with the attachment in order to

hold aluminium pans safely. Care must be exercised when mounting the dyes
if changing to hermetic from non-hermetic .
EMERGENCY PROCEDURES
Contact
Jim Fearick x64356 Morton Laboratory Safety Advisor and First Aider.
Des Doocey x 64354 School Safety Advisor.
Main Lodge x62444 Emergency Main Lodge.
Liz Davenport x68869 Instrument Manager and First Aider.
Dr Saiani x 68861 Instrument Academic Supervisor.

Shut down procedure -

Terminate run via software STOP or Stop key on touch screen , switch off
refrigerated cooling system and lower pressure to 0.5

LONE WORKING
Not advisable after office hours
REVIEW DATE
01 April 2011
REVIEW PERIOD AFTER FIRST REVIEW
6 Months
FINISH DATE
09 November 2012
1 Associated COSHH Form(s):
CO#686 Investigate the behaviour under thermal conditions of the following
components: Amcat3, Laminate, C50 Part A, C50 Part B.
 General Risk Assessment Priority Ranking

Likelihood 1 Improbable 2 Remote 3 Possible 4 Probable 5 Certainty

Severity 1 None 2 Negligible 3 Minor 4 Major 5 Fatality

Multiply the Likelihood of risk by the Severity in the risk matrix below to obtain
the Priority Ranking.

Severity
1 2 3 4 5
5 5 10 15 20 25
4 4 8 12 16 20
Likelihood 3 3 6 9 12 15
2 2 4 6 8 10
1 1 2 3 4 5

Total Likelihood x Severity = Priority Ranking:

16 – 25 = P1 Requires immediate attention
9 - 15 = P2 Action within one month
5-8 = P3 Action within six months
1–4 = P4 Review at next assessment
 Control of Major Accident Hazards
(COMAH)
• The Competent Authority’s role is to
oversee and coordinate the regulation of
major hazards in the UK and ensure that
the regime operates effectively.
• Health and Safety Executive (HSE) and
Environment Agency (EA) in England and
Wales, and the HSE and Scottish
Environment Protection Agency (SEPA) in
Scotland.
 Control of Major Accident Hazards
(COMAH)
• Emergency Planning Authorities: Operators and
the local authorities have a duty to ensure that
the appropriate plans are prepared and are
adequate for the purpose. The operator is
responsible for the on-site plan, and the local
authority has responsibility for the off-site plan.
• The Competent Authority regulates activities
subject to COMAH by: assessing safety reports
submitted by site operators; inspecting sites and
investigating incidents.
 Who COMAH applies to!

• The COMAH Regulations apply mainly to

the chemical and petrochemical industries.
They may also apply to businesses that
store fuels, including gas, have large
warehouses or distribution facilities or
manufacture and store explosives and aim
to ensure that businesses
 Who COMAH applies to!

• The COMAH Regulations

http://www.opsi.gov.uk/si/si1999/19990743.htm
http://www.opsi.gov.uk/si/si2005/20051088.htm
• If you have enough dangerous substances
present to take you over the lower
threshold then the lower-tier duties apply
and if you have enough to exceed the
higher threshold then the top-tier duties
apply.
 Who COMAH applies to!

• Exceptions:
 Ministry of Defence
 Visiting Forces
 Ionising radiation
 Extractive industry (mining/quarrying)
 Landfill sites
 Tier 1 or Tier 2
Example

Column 1 Column 2 Column 3

Dangerous substances Quantity in tonnes
Ammonium nitrate (as described in Note 1 of this Part) 350 2,500
Ammonium nitrate (as described in Note 2 of this Part) 1,250 5,000
Arsenic pentoxide, arsenic (V) acid and/or salts 1 2
Arsenic trioxide, arsenious (III) acid and/or salts 0.1 0.1
Bromine 20 100
 Tier 1

• Operators of all establishments subject to the

Regulations must notify certain basic details to the CA.
The key points which have to be included in the
notification are given below but full details are given in
Schedule 3 to the Regulations.
 name and address of operator
 address of establishment
 name or position of person in charge
 details of dangerous substances on site (a breakdown is
required for petroleum products)
 site activities
 environmental details
 Tier 1
Take all measures necessary to prevent major accidents
and limit their consequences to people and the
environment
 Prevention should be based on the principle of reducing risk to a level
as low as is reasonably practicable (ALARP) for human risks and using
the best available technology not entailing excessive cost (BATNEEC)
for environmental risks
Prepare a major accident prevention policy
 Regulation 5 requires lower-tier operators to prepare a document setting
out their policy for preventing major accidents (a major accident
prevention policy or MAPP).
 The MAPP will usually be a short and simple document setting down
what is to be achieved but it should also include a summary and further
references to the safety management system that will be used to put the
policy into action. The detail will be contained in other documentation
relating to the establishment e.g. plant operating procedures, training
records, job descriptions, audit reports, to which the MAPP can refer.
 Tier 2

• As Tier 1 plus prepare a safety report:

A safety report is a document prepared by the
site operator and provides information to
demonstrate to the CA that all measures
necessary for the prevention and mitigation of
major accidents have been taken.
 Safety Report
• a policy on how to prevent and mitigate major accidents;
• a management system for implementing that policy;
• an effective method for identifying any major accidents
that might occur;
• measures (such as safe plant and safe operating
procedures) to prevent and mitigate major accidents;
• information on the safety precautions built into the plant
and equipment when it was designed and constructed;
• details of measures (such as fire-fighting, relief systems
and filters) to limit the consequences of any major
accident that might occur; and
• information about the emergency plan for the site, which
is also used by the local authority in drawing up an off-
site emergency plan.