Is the Canvey COMAH Goose Cooked? Or is somebody poking around?

There appears to be a small flurry of activity where concerns of safety and Hazardous sites are concerned.

“Prepared in Essex” (?) have today tweeted:

Prepared In Essex@PreparedInEssex 22m22 minutes ago

We’ve uploaded a new page on our website about regulations and what emergency planning work is required.

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Hopefully Castle Point Council will be seeking to be actively committed and involved in being informative towards the residents of Canvey Island, as with 2 Top Tier COMAH sites sited close together on the Island, little information and education has been forth coming to date!

COMAH

The Control of Major Accident Hazards (COMAH) Regulations 2015 are in place to ensure that businesses in the UK which fall within the established criteria under those regulations make sure that if they store or handle dangerous and hazardous substances they take all necessary measures to prevent major accidents and limit their potential consequences.

History of COMAH Regulations

The COMAH Regulations 2015 are the enforcing regulations within the United Kingdom of the Seveso III Directive. The original Seveso Directive was introduced by the European Parliament in 1982 following the Seveso disaster in Italy in 1976. The Seveso Directive has since undergone a number of changes over time and is currently in its 3rd version.

The first set of UK regulations following the introduction of the Seveso Directive was the Control of Industrial Major Accident Hazards (CIMAH) Regulations 1984. The CIMAH Regulations were in place until 1999 when the COMAH Regulations 1999 superseded the previous regulations following the introduction of the Seveso II Directive.

The COMAH regulations were reissued again in 2015 following the introduction of the Seveso III Directive. Each reincarnation of the Seveso Directive and the COMAH regulations has helped improve safety and emergency planning procedures for businesses, local authorities and the emergency services.

Emergency Plans

The COMAH Regulations 2015 place a duty on county or unitary local authorities to lead on the preparation and maintenance of an External Emergency Plan for Top-Tier COMAH sites within the authority’s boundaries. The External Emergency Plan focuses on how emergency services, all local authorities and other agencies will respond to a major incident at a Top-Tier COMAH site that has the potential to affect locations outside of the site’s boundary. In Essex, the External Emergency Plans are owned and maintained by ECPEM on behalf of Essex County Council.

The site operators are also required to produce an Internal Emergency Plan which details their own procedures for dealing with an emergency alongside the relevant emergency services.

Both of the plans are designed to dovetail with other emergency plans which provide more detail around specific elements of the emergency response.

Both the Internal and External Emergency Plans are formerly reviewed every three years, which is a requirement established in the regulations.

Exercising Emergency Plans

Not only do emergency plans need to be written, but they also need to be tested and validated to ensure that they are fit for purpose. To make sure that the External Emergency Plans are suitable and their actions achievable the site operator, emergency services, local authorities and other relevant agencies organise and conduct an emergency exercise at least once every three years. This is in accordance with the COMAH Regulations 2015.

The exercise can be conducted in a number of different ways:

  • Table-top Exercise – this allows partners to look at the plan holistically and identify areas which may need improving or updating.

  • Command Post Exercise – this allows partners to test communication systems and operation locations that are identified in the plan.

  • Live Exercise – this allows partners to simulate the response to a specific scenario and look at individual parts of the plan in great detail.

Local emergency services will often carry out more regular training, exercising and familiarisation activities on the sites to ensure that they are well versed in their responsibilities when responding to an emergency involving a top-tier COMAH site.

Warning & Informing the Public

One of the important features of the COMAH Regulations is that there is a requirement upon the Operator of a “Top-Tier” establishment to provided specified information to people liable to be affected by a major accident at that establishment. This includes the potential major hazards and the safety measures that are in place.

It is the duty of the “Competent Authority” to determine the area around a COMAH establishment to which this information (in writing) must be made available.  This area is known as the Public Information Zone (PIZ).

In many cases the Operators of the “Top-Tier” establishments have worked with the ECPEM Team to undertake the task of preparing the appropriate letter to warn and inform the public within the PIZ. Additionally, site operators may provide information wider than the PIZ to reduce ambiguity within the community.

The letter must contain adequate information on how the population concerned will be warned and kept informed in the event of a major accident and the actions that they should take. Reference should also be made to the External Emergency Plan prepared by the relevant authority in conjunction with the Operator and the Emergency Services. There may also be reference to a contact point where further information could be obtained.

Monitoring & Enforcement

The Health and Safety Executive and the Environment Agency are the ‘Competent Authorities’ and are responsible for monitoring and enforcing the COMAH Regulations 2015. This includes regular inspections of the site and safety documentation, including the emergency plans.

COMAH regulations are only one of many regulations and directives that top-tier premises have to abide by. This includes Health & Safety at Work Act 1974, Control of Substances Hazardous to Health Regulations 2002 and the Explosives Regulations 2014 amongst many others. These are all enforced and monitored by the relevant authorities.

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4 responses to “Is the Canvey COMAH Goose Cooked? Or is somebody poking around?

  1. Steve Sawkins

    The releasing of appropriate emergency planning information with regards to a major industrial accident emanating from one or even both of the Major Hazardous storage sites at Canvey Island has never been forthcoming on the basis of National Security.

    DEALING WITH MATTERS OF NATIONAL SECURITY

    Identified Major Hazard Sites can be sensitive in national security terms. The
    term ‘National Security’ is not defined in UK legislation. However, when
    considering safeguarding national security the Courts have accepted that it is
    proper to take a precautionary approach.

    The issue is that where LPAs rely on information in determining planning policy, this normally needs to be made available to the public for scrutiny.

    The test of whether information could be exempt from the Freedom of
    Information Act is the application of the public interest test. This test requires
    a balancing of competing interests, ie the general public interest in disclosure
    and the public interest in maintaining the exemption. There is a presumption
    that information should be disclosed unless the harm likely to arise from
    disclosure would outweigh the public interest in making the information
    available.

    If this is the case surely that part of the plan that could be compromised could easily be redacted. However the most obvious question is if there is a security risk of such a magnitude why are planning permissions being granted that put more people at risk of the hazard range of hazardous sites.

    The primary factor for disclosure is that it is in the public interest that the public are fully informed about the potential environmental and health and safety issues of major accidents at fuel storage terminals. This will enable the public to make informed decisions about where they choose to live and work.

  2. Steve, your conclusion on the level of information any that “should” be passed on to residents appears to differ with the “authorities”. The responsibilities are apparent yet appear unregulated.
    What is certain is the difficulties agencies have in effective communication streaming. The reach of many agencies border on the pathetic.
    For instance, this latest COMAH information, apparently begrudgingly released, came from a twitter feed set alongside advice to drink water and eat salads during Hot Weather. Unfortunately the agency releasing the COMAH information has only 2,500 twitter followers across the whole of Essex!
    Isn’t this a sign that Castle Point Council should be doing something to address, publicise and inform Castle Point, and in particular Canvey Island residents?
    Editor

  3. Steve Sawkins

    Editor.
    Although CPBC are the Hazardous Substance Authority for the Borough and have control over all developments within the Borough, their responsibility for safety and well being of its community seems very limited.
    They state the following :-

    “Emergency Planning”
    How does the Council deal with Emergencies?
    In line with most local authorities, Castle Point Borough Council maintains the ability to respond to a wide range of civil emergencies. An emergency control centre and other necessary equipment are fully maintained and can be actioned at any time of day or night. The Council has plans to cover many of the “usual” emergency situations such as oil spills but the more general incidents are covered in the Councils Emergency Plan. Unfortunately no organisation could write plans to deal with all potential incidents and like every responding agency we have to maintain a high degree of response flexibility

    • Steve, I follow your comment and appreciate CPBC’s seeking to fulfil their minimum obligation, however it should be remembered that the local authority represent us the residents; that is residents who have put themselves forward proclaiming their abilities to lead and work “tirelessly”for the community, in the community’s interests.
      This body of representatives should be leading in the pursuit of means of protecting this community from the hazards that Canvey is exposed to.
      It appears that there is a fear of the unknown that should not be made public for whatever reasoning.
      It is this reasoning that may make matters worse should some “accident” occur.

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