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Milestone revisited

Today was one of those days that feel good, as my team and I completed a significant amount of work, and handed it into the regulator responsible. I don’t talk work very often here, but I’m kind of proud of this, so indulge me.

Those of you that know me well, know that while I am an engineer by training I work in health and safety at a high hazard site governed by the Seveso II directive (implemented in the UK as the Control of Major Accident Hazard Regulations 1999, as amended) usually called
COMAH. This is a piece of European legislation, designed to minimise the risks to society from the consequences of major accidents and threats to environment.

It came about from major incidents at
Flixborough in the UK (large fire and explosion) and Seveso in Italy (Toxic release). It’s not “health and safety gone mad”, as David Cameron and his chums are so fond of ranting on about, but a very serious attempt to protect people and the environment from harm. A recent example of this in the UK was the fire and explosion at Buncefield in 2005, estimated as being the largest fire in Europe since the Second World War. The regulations consider flammability, toxicity and eco-toxicity (potential harm to the environment), and are governed by the Competent Authority (HSE and the various versions of Environment Agency across the UK).

Anyway, the site that I work at became a site covered by the higher requirements of COMAH – an 'upper tier' site – back in 2009, due a planned increase in the levels of 'dangerous substances' under the directive. Becoming upper tier requires you to have on and off-site emergency plans, and to produce a safety report that demonstrates that you meet the stringent requirements of the legislation to take 'all measures necessary' to prevent a major incident. This is more demanding than the usual UK requirement from the
Health and Safety at Work, etc. Act 1974 places on an employer. That duty is defined as 'so far as is reasonably practicable', whereas COMAH has the duty of 'as low as is reasonably practicable', a significant advance. But when you are dealing with events that can have a significant affect on society, this makes sense.

Every five years, you have to resubmit the safety report, and that's the milestone we achieved today. Having led the production of the report initially, I can confirm that doing it a second time is no easier. It was a great feeling when we handed it in at the HSE offices in Leeds today, six months, 733 pages and 230,000 words of detailed quantative and qualitative risk assessment later. I was proud of the way that my team had pulled together to make this happen.

Now I guess that it's back to reality!