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Health and Safety Executive Health and Safety Executive HSE/SIESO Workshop Competent Authority Guidance for Inspectors on Emergency Arrangements for COMAH Establishments Melanie Taylor Hazardous Installations Directorate
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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.
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Basic Principles “Effective emergency response depends on clear and concise emergency plans, trained and experienced responders and a well informed community”
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MIIB EPRR Report: CA considerations Legal requirements Relevant Recommendations COMAH and CCA interface
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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
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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
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COMAH and CCA interface Risk Assessment Emergency Planning –Extendibility –Command and Control –Communications with the public
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MIIB EPRR Report – CA actions What does this mean in practice?
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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.
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CA guidance COMAH Regulation 10(1) Existing –L111 –Annex 5 –Annex 15 –DG7b New –Annex 8 –Annex 9 –Annex 10 –Annex 11 Chapter 19 “Emergency Preparedness”
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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 – 258Annex 15 There is further information in the following annexes: Annex 8 Competencies for emergency planners Annex 8 Annex 9 Working with Resilience and Emergency Division (RED) in England and arrangements in devolved administrations Annex 9 Annex 10 Extendibility Annex 10 Annex 11 Command and Control and COMAH off-site Response Annex 11 Please see Chapter 19 “The Fit with Other Legislation” paragraphs 19.19 – 19.20, 19.21 – 19.22 of “Emergency Preparedness”Chapter 19 “The Fit with Other Legislation”
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CA guidance COMAH 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
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CA guidance Existing –L111 –SRAM Criteria 14.7 –Annex 12 New –Annex 14 Chapter 19 “Emergency Preparedness
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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.Annex 12 Further information can be found in the SRAM Criteria 14.7. mutual aid arrangements can be found in Annex 14. Annex 14 See also Chapter 19 “The Fit with Other Legislation” paragraphs 19.5 – 19.10 (Risk Assessment) of “Emergency Preparedness”Chapter 19 “The Fit with Other Legislation”
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CA guidance HSE website –COMAH home page
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References www.buncefieldinvestigation.gov.uk/reports/prep aredness.pdf www.buncefieldinvestigation.gov.uk/reports/prep aredness.pdf www.cabinetoffice.gov.uk/resource- library/emergency-preparedness 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.hse.gov.uk/comah/buncefield/fuel-storage- sites.pdf www.cabinetoffice.gov.uk/resource- library/emergency-response-and-recovery www.cabinetoffice.gov.uk/resource- library/emergency-response-and-recovery www.scotland.gov.uk/Topics/Justice/public- safety/ready-scotland/Government/Preparing www.scotland.gov.uk/Topics/Justice/public- safety/ready-scotland/Government/Preparing www.hpa.org.uk
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