COMAH

COMAH
I have taken the points from the COMAH report that I found relevant to
each element as a direct quote.
UNIT 7
Element 12: management of change
-
Management of change system ensures that only competent personnel approves any
change
The Management of Change forms covers the following details: - Location of the work;
- Description of the work;
- Hazardous Substances;
- Risk Assessment completion;
- Equipment;
- General comments; and
- Approvals
The Company operates a Management of Change Form system for all minor changes
that do not warrant full-scale drafting or design work.

Major changes are controlled by assigned personnel under the control of the
Terminal Manager.
For minor changes, qualified competent staff assess the impact the change would
have by either forming a team, carrying out a Risk Assessment, conducting a site
audit or a combination of all three.
Element 15: inspection and maintenance

-
Designated areas are provided for vehicles held for inspection and documentation
production before and after loading and discharging operations.

No petrol driven vehicles are permitted within the site boundary.
Storage tanks and pipelines are designed to industry standards and subject to
planned inspections
All equipment is subjected to regular inspection within time periods that are in
accordance with known, historically established low corrosion rates for petroleum
products.
The storage tanks are visually inspected at a frequency of once in six months, 5
yearly internal inspection and subjected to a non-destructive test (NDT) at least
every 10 years to monitor the corrosion rate and the expected life of the tank (see
Appendix 4). This is consistent with industry practice and the known low corrosion
rates.
Visual inspection is carried out at every ship discharge (walk on import procedure).
Mechanical failure can be caused by fatigue (the effect of vibrations weakening the
equipment over sustained period) or inadequate welding. The pump is the only
source of vibration but the vibration level is low. If any fatigue were present or
inadequate welds the regular condition monitoring inspections are designed to
-
detect this.
Corrosion of a storage tank could lead to a release of its contents into the bund. If
a source of ignition is present then a fire could develop. The storage tanks are
designed to BS 2654 or API 650 and the periodic inspection procedures are
consistent with industry best practice.

Inadequate design of the tanks could lead to premature failure in a number of ways
depending upon the exact nature of the inadequacy. However, such inadequacy
should have been identified over the years that the site has been in operation
during the regular checks, inspections, audits and maintenance activities.
Element 16: Safety Critical Devices

-
Pressure gauges
Levels sensors
Shut off valves for emergencies
Fire alarms
Emergency lighting
Emergency response system to alert emergency services
Element 19: Incident Reporting and Investigation

-
All injuries are reported, even if it is minor, and logged in the Accident Book
All incidents and near misses are reported, investigated and recorded via the
OilCompany Loss Prevention System
UNIT 8
The energy institutes high level framework for process safety management states that
element 20 is; Audit, assurance, management review & intervention
Regular review and audit of compliance with the EI PSM framework is important to ensure
that HS&E and process safety performance continue to meet the defined targets.
This can be addressed by analysing the given COMAH report.
-
All the systems in place are regularly audited including third party
reviews by an accredited body such as HS&E.

Site management and operation staff are required to conduct formal
inspections that enhance formal audits.

External audits are used to verify internal audits while also adding
another layer of safety from a different perspective

All employees and site users are encouraged to participate in safety
committee meetings to make suggestions

All meetings have minutes taken and any suggested action is given a
deadline and prioritised so that any safety actions can be improved

Site budget allows for improvement to safety measures, provision of PPE
and maintenance/inspection and to avoid any accidents

Any urgent safety modifications approved by the terminal manager has
immediate authority to spend additional funds as for any top-tier COMAH
site, an incident can be catastrophic
Unit 10
Permits to work are important to make sure the qualified people undertake the work and
by doing this, major accidents are avoided:
-
The different colours corresponding to different types of work are good

for distinguishing at a glance
- Yellow general work permit low risk work
- Pink hot work form gas test required before issue
- Green confined space entry issued as authority to enter and
-
requires a prior gas test

Brown excavation used to ensure safety of workers and
facilities
Isolation isolating machinery or equipment from energy or toxic
substances
Height work prevent falls and injuries
Submitting a request for a permit to work takes time and the intention of this is to give
the site staff time to prepare the area destined for maintenance. The request necessitates
an accompanying method statement and risk assessment to ensure safety to the highest
degree.
Issuing authority (site staff, project managers etc.) will visit the site that needs
maintenance with the contractor to check that all safety precautions and risks are
correctly addressed after this permit is agreed.
During and after the work is complete, the issuing authority will check that the work has
been done to industry standards and once it has been approved, the work will be signed
off by both parties.
UNIT 11
-
Wide range of chemical, physical and toxicological properties determines the

environmental impact of spills of ecotoxic substances into a water body. These
include:
- Toxicity to aquatic organisms, which has an acute, direct impact on living
-
species;
If insoluble in water and less dense the rate of transfer of gases between
the air and the water reduced directly affecting fauna (lack of oxygen)
and photosynthesising flora (lack of carbon dioxide and oxygen);

If soluble and dispersing with an adverse effect such as a high BOD or pH
change;
If insoluble in water and with a higher density than water so that it can
interact with benthic species and persist; and

- Bioaccumulation potential causing chronic effects.
It stores a variety of hazardous substances however the risk to local populations is
small and can arise as a result of fire or spill of a significant quantity of certain
substances. Analysis shows that the maximum distance which dangerous levels of
thermal radiation or a dangerous toxic load of hazardous combustion could be
experienced, following an on-site incident, is less than 100m. All the major
accident hazards were identified and the environmental effects on the air, aquatic
environment and land were assessed.

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COMAH

that do not warrant full-scale drafting or design work.

Element 15: inspection and maintenance

production before and after loading and discharging operations.

consistent with industry best practice.

Element 16: Safety Critical Devices

Element 19: Incident Reporting and Investigation

reviews by an accredited body such as HS&E.

inspections that enhance formal audits.

another layer of safety from a different perspective

committee meetings to make suggestions

deadline and prioritised so that any safety actions can be improved

and maintenance/inspection and to avoid any accidents

The different colours corresponding to different types of work are good

requires a prior gas test

Wide range of chemical, physical and toxicological properties determines the

and photosynthesising flora (lack of carbon dioxide and oxygen);

interact with benthic species and persist; and

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