The prospect of a Control of Major Accident Hazard (COMAH) regulatory inspection can be daunting, particularly given all the other day-to-day responsibilities. But adequately preparing is key to minimising the potential for a poor result.
COMAH upper tier sites will have safety reports that should have been regularly updated to reflect relevant changes which have been introduced since the previous submission. These updates in themselves demonstrate the report is live and not simply left on a shelf from one submission to the next.
The COMAH Competent Authority – which comprises the Health and Safety Executive and the Environmental Agency – provides a three-year Intervention plan to the upper tier site management. Using this plan, management can prepare for elements scheduled well in advance of the visits and thereby demonstrate compliance and continuous improvement when the inspection takes place.
The specialist inspectors use the requirements specified within the Safety Report Assessment Manual (SRAM), the relevant content of the previously submitted safety report and any notes available to them from previous inspections and correspondence.
Preparation is key
In preparing for the intervention inspection, site management should set aside enough time to prepare well before the date. Having a clear idea of how to lead the inspection will also help the whole process run more smoothly.
Confirmation should be obtained ahead of time about who will be on inspection team; it may be several specialist inspectors from one or both of the joint authority organisations.
You should provide the inspectors with details of how to locate the site, the site induction process and any PPE they will need to wear that won’t be provided by the company. Ensure that the relevant internal personnel are advised in sufficient time for them to adequately prepare. This may include those at reception, security, production, engineering, maintenance health and safety, and so on.
Where inspectors are visiting for the first time, an introduction to the company would be helpful. This could include: a brief overview of the group (where applicable); the activities, products or services the company provides; and an up-to-date organisation chart.
For returning inspectors, they would benefit from hearing of any significant organisational or process changes since the last intervention inspection. Ideally, a member of senior management should be present at the opening meeting with the inspection team to support site management and demonstrate the commitment of the company’s leadership. If this is not practical, they should be present at the closing meeting at the end of the inspection.
Preparation and presentation by the site management on the relevant inspection topics should include evidence of the operations under inspection, the improvements made since previously inspected and the plan for further improvement and risk reduction going forward. Particular attention should be given to any ‘Actions Legal’ and/or improvement notices that have not been discharged.
The opportunity should also be taken by the site management during the preparation to revisit the SRAM criteria to ensure that any gaps have been identified and measures introduced to close them. Additionally, current HSE/Environment Agency guidance on the topics being inspected should be used to drive improvement, and any previous Improvement Plan should be updated and presented to the COMAH Authority to reflect the current position.
The inspectors are then likely to go into greater depth and seek further assurance by walking the relevant areas of the site to witness changes made and speaking to operators and/or union representatives.
At the end of an inspection, a closing meeting will normally be led by the inspectors visiting the site, providing feedback on what has been observed and outlining the steps that they seek in the future.
This should be taken as opportunity for improvement – indeed, if any issues are raised which you don’t feel are justified, they can be discussed further with the inspectors.
At the end of the process, you should agree a plan with the inspectors for corrective actions with timeframes and responsibilities clearly assigned, and once the inspection is over you should work to progress the plan and keep the inspectors updated on the progress you have made.
While even experienced managers can find the prospect of an inspection challenging, carving out some time to prepare in the right way is essential and is more than worth the investment when it comes to the lasting impact of a positive result.
Cogent Skills has been supporting high hazard industries with their regulatory inspection requirements for more than a decade. For an informal discussion about how we can help your business, contact our team on 01325 740900 or at [email protected].