The Seveso III Directive and Revisions to COMAH Regulations

In June 2015, the existing EU Seveso II Directive shall be replaced by the newly revised Seveso III Directive (Seveso III). This will result in changes to the scope and implementation of the COMAH Regulations within the U.K, in addition to the applicability of COMAH Regulations across a range of sites/industry sectors.

The most significant changes associated with Seveso III are:

• the adoption of the new Globally Harmonised System (GHS) for classifying chemical substances, which shall also result in changes to the method currently used to assess the COMAH status of your site’s chemical inventory.
• the introduction of additional ‘named substances’, which at certain quantities shall bring sites into the scope of the COMAH regulations, and new categories for dangerous substances.
• the adjustment of the qualifying quantities for a selection of named substances.

As a result of these changes, there is now potential for previously non-COMAH sites (particularly those in the chemical and industrial sectors) to fall within the scope of the COMAH Regulations (lower or upper tier), or for their status to move between lower tier and upper tier status.

Consequently, in the time which exists between now and the commencement of the new Directive, industrial operators across the U.K. shall require to re-assess their chemical inventory to determine their status against the revised COMAH regulations, and the activities likely to be involved in ensuring compliance. This is required to allow successful re-notification to the competent authorities (i.e. HSE, SEPA).

For further information on the Seveso III directive, the associated impacts on COMAH in the U.K and how these might affect your business, please visit the HSE website.

How Mabbett can support your organsiation

Mabbett can assist your organisation with all aspects of COMAH, to include:

• assistance with chemical substance classification, and COMAH aggregate scoring.
• verification of your organisation’s COMAH status (i.e. not-in-scope, lower tier or upper tier).
• assistance with on-going lower tier and upper tier compliance to include development of safety reports, major accident prevention policy (MAPP) reports and emergency response procedures.

For further details on how Mabbett can help, please contact Paul Young, Senior Environmental Engineer on: 0141 227 2311 or via email young@mabbett.eu