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HSE/SIESO Workshop Competent Authority Guidance for Inspectors on Emergency Arrangements for COMAH Establishments. Melanie Taylor Hazardous Installations Directorate. MIIB EPRR Report: CA Considerations. COMAH Competent Authority (CA) to consider:
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HSE/SIESO WorkshopCompetent Authority Guidance for Inspectors on Emergency Arrangements for COMAH Establishments Melanie Taylor Hazardous Installations Directorate
MIIB EPRR Report:CA Considerations • COMAH Competent Authority (CA) to consider: • improving its guidance for producing on- and off-site emergency plans, having regard to integration of the requirements under COMAH with those established under the Civil Contingencies Act (CCA); • check that those with legal duties under COMAH are discharging them.
Basic Principles “Effective emergency response depends on clear and concise emergency plans, trained and experienced responders and a well informed community”
MIIB EPRR Report:CA considerations • Legal requirements • Relevant Recommendations • COMAH and CCA interface
COMAH Legal requirements • On-site plans • Off-site plans • Review and testing • Implementing • Information to the public • Information to the CA • Information to other establishments
MIIB EPRR Report: Recommendations • Assessing the potential for a major incident • Managing a major incident on site • Preparing for and responding to a major incident off-site • Recovering from a major incident
COMAH and CCA interface • Risk Assessment • Emergency Planning • Extendibility • Command and Control • Communications with the public
MIIB EPRR Report – CA actions • What does this mean in practice?
COMAH off-site emergency plans Regulation 10(1) • The local authority, in whose area there is an establishment, shall prepare an emergency plan (in these Regulations referred to as an “off-site emergency plan”) in respect of that establishment, and such a plan shall be adequate for securing the objectives specified in Part 1 of Schedule 5 and shall contain the information specified in Part 3 of that Schedule.
CA guidanceCOMAH Regulation 10(1) • Existing • L111 • Annex 5 • Annex 15 • DG7b • New • Annex 8 • Annex 9 • Annex 10 • Annex 11 • Chapter 19 “Emergency Preparedness”
Preparation of off-site emergency plan [Regulation 10(1), Schedule 5 Part 1 and Part 3, Regulation 10(2)] • Further information can be found in Annex 15 and “A guide to the Control of Major Accident Hazards Regulations 1999 (as amended) paragraphs 249 – 258 • There is further information in the following annexes: • Annex 8 Competencies for emergency planners • Annex 9 Working with Resilience and Emergency Division (RED) in England and arrangements in devolved administrations • Annex 10 Extendibility • Annex 11 Command and Control and COMAH off-site Response • Please see Chapter 19 “The Fit with Other Legislation” paragraphs 19.19 – 19.20, 19.21 – 19.22 of “Emergency Preparedness”
CA guidanceCOMAH Regulation 10(3) • An operator shall supply to the local authority in whose area the establishment is situated the information necessary for the purpose of enabling the authority to prepare the off-site emergency plan
CA guidance • Existing • L111 • SRAM Criteria 14.7 • Annex 12 • New • Annex 14 • Chapter 19 “Emergency Preparedness
Provision of information Regulation 10(3) • Included at Annex 12 is a template (RCS 8) which may assist emergency planners reviewing the adequacy of operators’ on-site emergency response arrangements. • Further information can be found in the SRAM Criteria 14.7. • mutual aid arrangements can be found in Annex 14. • See also Chapter 19 “The Fit with Other Legislation” paragraphs 19.5 – 19.10 (Risk Assessment) of “Emergency Preparedness”
CA guidance • HSE website • COMAH home page
References • www.buncefieldinvestigation.gov.uk/reports/preparedness.pdf • www.cabinetoffice.gov.uk/resource-library/emergency-preparedness • www.hse.gov.uk/comah/notification/index.htm • www.hse.gov.uk/comah/buncefield/fuel-storage-sites.pdf • www.cabinetoffice.gov.uk/resource-library/emergency-response-and-recovery • www.scotland.gov.uk/Topics/Justice/public-safety/ready-scotland/Government/Preparing • www.hpa.org.uk