The Control of Major Accidents and Health Hazards (COMAH)
The purpose of this article is to outline certain issues surrounding the impact from COMAH regulations on the lubricants business.
What is COMAH? The UK COMAH regulations ensure that businesses take all necessary measures to prevent major accidents involving dangerous substances and limit the consequences to people and the environment of any major accidents which do occur.
COMAH 2015 regulations which came into force on 1 June 2015, are managed by the competent authority which means the Health and Safety Executive and Environment Agency in England.
COMAH applies mainly to the chemical and petroleum industries, but also to some storage activities, explosives and nuclear sites, and other industries where threshold quantities of dangerous substances identified in the Regulations are kept or used, for example oil refineries or places that are involved with the handling and storage of dangerous substances.
How does COMAH work? Sites managing substances which are classified under COMAH regulations as dangerous need to register with the competent authority. COMAH recognises two tiers, a lower and upper tier, depending on the volume and nature of substances managed and as to is it named, or if not, then a review of their specific properties is needed. An aggregate scheme is in force.
Organisations will have to abide by the regulations, ensure they have sufficient and effective management controls for the prevention and management of accidents relating to dangerous substances, and notify the competent authority of any accidents.
Why is this an issue now? Following the introduction of the new CLP regulation on 1 June 2015, many organisations are revising their Safety Data Sheets (SDS) and including some lubricants allocated for the first time a risk phrase of R51/53 (or greater) or similar hazard rating e.g. E2/H411 relating to aquatic toxicity.
R51/53 or H411: ‘Toxic to aquatic organisms: may cause long term adverse effects in the aquatic environment’
Under COMAH regulations, substances under this category including many engine oil type products or their additives may be as little as 200 tonnes to qualify for the organisation registering under COMAH with the competent authority for lower tier status, and 500 tonnes to qualify for upper tier status.
COMAH may be particularly relevant to organisations involved with metalworking fluids because of their impact on water.
What do organisations need to do? Organisations should review the substances they handle and store against the COMAH regulations. If they qualify for registering they need to notify the competent authority
For more information visit the HSE website or go to
www.hse.gov.uk/comah/guidance/understanding-comah- new-entrants.pdf
20150812 The Control of Major Accidents and Health Hazards
LINK
www.hse.gov.uk
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