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Understanding COMAH: COMAH Intervention Manager: User manual

1. CA intends to do this Interventions may include a Safety Report SR assessment this will be predominantly desk based with some time spent at the establishment b inspections on identified topics c where applicable inspections aimed at rating the operator s performance against key strategic national topics d ongoing investigation actions e work to follow up and close out issues of non compliance identified from previous interventions 18 The COMAH Intervention Plan will include any agreed in year meetings between the COMAH Operator and the Intervention Manager to discuss progress against the plan 19 The Intervention Manager will lead on the development of the COMAH Intervention Plan Starting in October each year they should a review progress against the current year s plan and determine if any activities will need to be transferred to the plan for the coming year including any outstanding interventions b review the establishment s hazard profile using the CA Inherent Hazard Methodology to reflect any changes at the establishment since the last plan review c review the Operator s performance taking into account any performance assessments generated from the current year s plan d assess whether it is more efficient to develop a COMAH Intervention Plan that will be delivered by only one of the CA partners e for establishments regulated under the Environmental Permitting Regulations in England and W
2. be shared with the establishment at the time of the inspection or shortly after where further consideration needs to be given to the evidence obtained When informing the COMAH Operator about its performance rating the CA inspection report will provide a brief outline of how the rating was determined and highlight actions required to bring about improvement The covering letter to the report will include those matters of serious non compliance uncovered during the inspection that require action from the COMAH Operator Subsequent inspections on the topic will provide an opportunity for the Intervention Manager to review and update performance ratings 52 Performance ratings are a reflection of the Inspector s assessment on compliance based on the evidence reviewed during the inspection This also reflects that the COMAH Operator will not necessarily agree with the CA s assessment and the above offers a timely opportunity for them to input their views Understanding COMAH COMAH Intervention Manager User Manual Page 11 of 16 Health and Safety Executive Dispute Resolution and Challenge Mechanism Tackling issues early 53 A key responsibility of the COMAH Intervention Manager is to mediate and resolve any issues raised by COMAH Operators or other CA regulators specialist arising from interventions at the establishment This will involve gaining a full understanding of the issue from all relevant perspectives and working to address the issu
3. disposed of while avoiding or reducing any impact on the environment c use energy efficiently d take the necessary measures to prevent accidents and limit their consequences e on ceasing activities take the necessary measures to avoid any pollution risk and to return the establishment of the installation or mobile plant to a satisfactory state 7 The Competent Authority will identify EPR or PPCR outcomes and issues that are COMAH relevant They will be those related to either a a measure necessary to prevent major accidents or limit their consequences to persons and the environment Such as a measure necessary under COMAH Regulation 4 or b any other duty placed on the COMAH Operator by the COMAH Regulations Understanding COMAH COMAH Intervention Manager User Manual Page 3 of 16 Health and Safety Executive Roles and Responsibilities of the COMAH Intervention Manager 8 It is important to understand that in many cases the roles and responsibilities of the Intervention Manager as outlined already exist and it is this good practice and effective working relationship that is captured below It is not the intention of the role of Intervention Manager or this guidance to replace existing duties or current good practice 9 In addition to their existing regulatory duties the COMAH Intervention Manager will lead on development of the COMAH Intervention Plan coordinate and maintain an oversight of the CA s COMAH inte
4. not contain planned inspections for one or both CA partners for a particular operational year It should be noted that regulatory oversight may be maintained through other applicable health safety or environmental legislation 15 Timeline for development and communication of planned regulatory activity The Annual Inspection Cycle CAP SRS environmental agencies compliance assessment plan or site regulatory strategy CIP COMAH Intervention Plan ARD Additional Regulatory Discussion CAP SRS amp CIP Site performance feeds in here ARD issued D Pi _ and is visible in this discussion VA gt April May June July August September October November December January February March Dates in Bids for Resource Head of Ops diaries for Specialist allocation CIP review intervention Resource assessed planning Understanding COMAH COMAH Intervention Manager User Manual Page 5 of 16 Health and Safety Executive Developing and Managing the COMAH Intervention Plan 16 Guidance on the development of COMAH Intervention Plans is provided by the CA instruction Reviewing COMAH Intervention Plans 2015 16 which can be found at www hse gov uk foi internalops og og 00039 htm 17 The COMAH Intervention Plan sets out what the CA will inspect at each establishment over a two year rolling period Its main purpose is to inform operators how the CA will examine and test the arrangements for controlling major accident risks and when the
5. A resource is not available to undertake a planned inspection In this instance the Intervention Manager should first discuss this with CA partners and Line Managers If it is agreed that there is no other option than to defer the planned inspection the COMAH Operator should be contacted to discuss an alternative solution b Where the COMAH Operator has requested a change to the COMAH Intervention Plan In this instance the Intervention Manager will discuss this with CA partners and Line Managers The CA will take a pragmatic view and where possible take account of the Operator s difficulties in engaging with the inspection However the importance of the intervention or CA alignment of resources may be such that deferring the inspection is not possible Understanding COMAH COMAH Intervention Manager User Manual Page 8 of 16 Health and Safety Executive 37 In all cases the Intervention Manager must alert all relevant parties to any adjustments to planned COMAH interventions outlined in the COMAH Intervention Plan Record Keeping 38 Records for COMAH related matters should be updated onto HSE s COIN system The Intervention Manager must have access to COIN either directly or through allocated HSE admin team members As a minimum the COMAH Intervention Plan and associated covering letter should be saved on COIN 39 EA NRW SEPA compliance assessment reports do not need to be saved on COIN in addition to the appropriate agencies o
6. COMAH Control of Major Accident Hazards Understanding COMAH COMAH Intervention Manager User Manual the Competent Authority bode Naturiol omu Oizo SE pap 9 Natural Resources Wa Health and Safety Executive Contents Objective 3 Introduction 3 Roles and Responsibilities of the COMAH Intervention Manager 4 How the CA will engage with COMAH Operators 5 Developing and managing the COMAH Intervention Plan 6 Internal CA Intervention Plan review meeting 7 Option for COMAH Operators to discuss the draft COMAH Intervention Plan 7 Using the Performance and Recognition Framework 38 Delivering Inspections and Managing Change 8 Record Keeping 9 Communication 9 Communication with Multi Site Operators 9 Communicating progress against Planned Inspections 10 Communicating performance ratings 10 Dispute Resolution and Challenge Mechanism 11 Tackling issues early 11 The Challenge Mechanism 11 Stage 1 Challenge Quick Second Opinion Sought 11 Stage 2 Challenge Independent Input 12 Stage 3 Challenge Final Stage 12 Intervention Managers Strategic Forums and Other Initiatives 12 CA Industry Initiatives 12 New and Revised Standards 13 Appendix 1 Dealing with duplication in CA Plans 14 Appendix 2 Terms Explained 15 Understanding COMAH COMAH Intervention Manager User Manual Page 2 of 16 Health and Safety Executive Objective 1 This manual outlines for both the COMAH Control of Major Accident Hazards
7. Competent Authority CA and COMAH Operators the arrangements for the introduction and role of COMAH Intervention Managers Guidance is provided on how the COMAH Intervention Manager CIM and COMAH Operators can work together to ensure risks are managed appropriately It complements current CA work instructions and guidance on the delivery of inspection and assessment Introduction 2 The CA and COMAH Operators have a shared interest in making sure regulatory responsibilities are delivered in the most efficient and effective way 3 For the CA this means targeting appropriate resources to a ensure that Major Accident Hazard MAH risks are properly controlled b ensure they remain compliant with the law and c tackle issues of poor performance 4 COMAH Operators can assist the CA to ensure that its interventions focus on the right areas and are based on an accurate and shared view of the establishment s arrangements to control risk 5 This guidance also aims to assist the Intervention Manager to avoid unnecessary duplication and overlap between health safety and environmental regulatory regimes 6 For the environmental agencies the principles for the regulation of non COMAH Environmental Permitting EPR or PPCR issues are that relevant operations also a take all the appropriate preventative measures against pollution and cause no significant pollution b avoid the production of waste and where it is produced or recovered it is
8. about current industry practice in the topic which is subject to challenge and this information may be submitted for consideration by the reviewing manager Stage 3 Challenge Final Stage The HSE s Independent Regulatory Challenge Panel IRCP will take COMAH regulatory decision challenges and give recommendations to the CA for their consideration The CA is not obliged to amend its regulatory decision following recommendations provided by the IRCP Understanding COMAH COMAH Intervention Manager User Manual Page 13 of 16 Health and Safety Executive Intervention Managers Strategic Forums and Other Initiatives 63 The CA adopts a collaborative approach to working with industry to promote the sharing of knowledge and where appropriate suggest solutions to issues or emerging concerns To facilitate this approach various forums exist within industry sectors cross industry sectors and with the CA A COMAH Intervention Manager should be aware of these groups what their role and function is and any relevant outputs for example guidance which play a part in helping businesses take a consistent approach to a specific issue across industry and help to achieve a consistent approach to its regulation Intervention Managers are encouraged to share intelligence with these existing regulatory groups and forums CA Industry Initiatives 64 There are several groups which exist to promote dialogue between industry and the CA and unions where
9. ales or Pollution Prevention and Control Regulations in Scotland review and where possible reduce any unnecessary overlap or duplication on COMAH topics between the two types of plan This may require co ordination by the Intervention Manager and other inspectors acting as a review team to complete this work 20 The Intervention Manager should work with the HSE and environmental agencies to complete this review It is the responsibility of the environmental agencies to develop the CAP SRS and as such the COMAH Intervention Manager should identify the Lead Inspector from the environmental agency responsible for these Where environment inspections have COMAH relevancy they should be highlighted Understanding COMAH COMAH Intervention Manager User Manual Page 6 of 16 Health and Safety Executive Internal CA Intervention Plan Review Meeting 21 Depending on the complexity of the COMAH Intervention Plan and the CA s previous engagement the Intervention Manager may need to organise a more detailed review of the plan involving all relevant CA partners 22 The review should also ensure that proposed interventions align with resourcing priorities outlined in Reviewing COMAH Intervention Plans 2015 16 Specialist Inspectors may also identify potential third party information relevant to an inspection 23 An essential part of the review team s work is to coordinate all activities in the COMAH Intervention Plan ensuring that COMAH regu
10. appropriate Two key examples are as follows a COMAH Strategic Forum SF Provides industry and the CA with a means for strategic discussion on how regulators and industry are working together to provide leadership and management of COMAH major accident control and mitigation across industry For further information refer to http www hse gov uk comah bre review index htm b Chemical and Downstream Oil Industries Forum CDOIF A collaborative venture formed to agree strategic areas for joint industry trade union regulator action aimed at delivering health safety and environmental improvements with cross sector benefits Start and finish task groups are commissioned to develop guidance where necessary for further information refer to http Avww hse gov uk aboutus meetings committees cif 65 Several industry Trade Associations TA have their own process safety improvement strategies and in many cases this includes dedicated sector forums with the CA It is important for the CIM to be aware of the TA with which the COMAH Operator is affiliated and to understand their involvement with it This will also be important in providing the context for discussion with COMAH Operators on earned recognition factors which the Operator may table as evidence on how this has improved their control of major hazard risk For further information refer to paragraph 16 Developing and managing the intervention plan 66 TAs also work collaboratively acr
11. e in a constructive and balanced way The aim is to clarify and resolve where possible any issues that may otherwise progress to Stage 1 of the formal challenge mechanism 54 The Intervention Manager will be expected to facilitate discussions between the COMAH Operator and CA regulators and work to achieve a common understanding of issues raised avoiding wherever possible detailed technical analysis and standards quoting The Intervention Manager should work to formulate a clear and defined analysis the outcome from these discussions will be an agreed approach to resolve the issue The Intervention Manager should be prepared to challenge CA regulators and the COMAH Operator as appropriate 55 As part of this early resolution process the Intervention Manager should document and agree with all parties a common understanding of the issue as this may be used to support the escalation process see dispute resolution below The Challenge Mechanism 56 Full details of the mechanism that allows COMAH Operators to challenge COMAH regulatory decisions please refer to Understanding COMAH How COMAH Operators can challenge regulatory decisions made by the Competent Authority which can be found at www hse gov uk comah ca guides htm 57 As described above the Intervention Manager will be involved in the clarification phase which takes place prior to a challenge being formally considered via the mechanism If a resolution cannot be reach
12. ed the COMAH Operator can then formally enter stage 1 by putting the challenge in writing via the Intervention Manager to the CA Inspector s Line Manager In some cases the timescales required to correct the problems identified by CA Inspectors may be adjusted to facilitate the COMAH Operator proceeding through the challenge mechanism Stage 1 Challenge Quick Second Opinion Sought 58 The Line Manager of the COMAH establishment s CA inspector will review the CA inspector s regulatory decision this will include checking the COMAH Operator s understanding of the action the legal basis for the action the standards for compliance and the evidence collected that details the COMAH Operator s non compliance 20958 59 As soon as the challenge is received by the Line Manager the Intervention Manager should provide any documentation resulting from the initial discussions held to agree a common understanding of the issue Understanding COMAH COMAH Intervention Manager User Manual Page 12 of 16 Health and Safety Executive Stage 2 Challenge Independent Input 60 The challenge will be reviewed by a CA Area or Operational Manager from a different region 61 Before entering Stage 2 If the COMAH Operator is a member of a Trade Association they can contact them or other industry bodies to ask for advice and support Industry bodies will use their normal network and communication routes to gather and collate information
13. egulation will be guided by the principle that COMAH relates to the prevention and mitigation of major accidents see Section 10 of the Offence Response Options and also OI 229_03 COMAH enforcement 70 There could be three possible outcomes a An issue will be regulated under COMAH Regulation of the issue will not occur under EPR PPCR this year but the environmental agency inspector needs to be sighted on the outcome of the COMAH work to inform future EPR PPCR work on the matter This COMAH activity should then also be identified in the Intervention Plan for the Intervention Manager to lead on The environmental agencies COMAH inspector will need to keep the EPR PPCR Inspector fully informed on this aspect b An issue will be regulated under EPR PPCR Regulation will not occur under COMAH but the COMAH Intervention Manager will need to be sighted on the outcome of the EPR PPCR work to inform future COMAH work on the matter This only needs to be identified in CAP SRS c An issue will be regulated under both COMAH and EPR PPCR In such cases a discussion will be required between the Intervention Manager environmental agency s inspector s or HSE Inspector as appropriate and steps taken to minimise the regulatory burden i e by carrying out a joint inspection on the issue rather than two separate visits for COMAH and EPR PPCR This then needs to be identified in the Intervention Plan and CAP SRS 71 Itis anticipated in most cases
14. f discuss and agree the timing of any in year engagement to review progress against the plan 26 Following the discussion the Intervention Manager should make a formal note of any agreements or amendments and revise the plan accordingly 27 The revised COMAH Intervention Plan should be shared with all CA partners and the COMAH Operator to ensure that it reflects the agreed outcome from the discussion 28 The Intervention Manager should discuss the draft COMAH Intervention Plan in line with the planning schedule described in Reviewing COMAH Intervention Plans 2015 16 Understanding COMAH COMAH Intervention Manager User Manual Page 7 of 16 Health and Safety Executive Using the Performance and Recognition Framework 29 The framework is available at www hse gov uk comah ca guides htm 30 The Intervention Manager should use the framework when considering the initial intervention priorities and to support discussions on the draft plan with the COMAH Operator The framework describes how COMAH Operator s performance using both the performance information that the CA holds and that provided by the COMAH Operator can influence planned regulatory activities at the site It is unlikely that decisions based solely on the framework will lead to a cancellation of a planned intervention 31 Where it can be demonstrated that the COMAH Operator has improved its performance in managing risk this should be taken into account when reviewing cur
15. lation is efficient and transparent At this point the CA should also agree its arrangements for ongoing communication between the Intervention Manager and other CA partners over the period covered by the COMAH Intervention Plan It will also be important to ensure the review team is sighted on any arrangements to meet with the COMAH Operator to discuss the COMAH Intervention Plan prior to issue Option for COMAH Operators to discuss the draft COMAH Intervention Plan 24 The Intervention Manager should contact the COMAH Operator and offer to discuss the proposed COMAH Intervention Plan The CIM and COMAH Operator should agree in advance on the appropriate format for the engagement The COMAH Operator should be advised that the time spent will be cost recoverable 25 The purpose of discussing the COMAH Intervention Plan with the COMAH Operator should include a clarifying the priority and focus of the plan b explaining what the CA intends to do in the coming year c explaining how the COMAH Operator s performance has influenced the COMAH Intervention Plan d discussing how the plan may need to be revised due to any on site activities that may compromise effective delivery of the plan for example major works e discuss what performance information from third parties or otherwise the COMAH Operator can provide that is directly relevant to the planned interventions for the coming year see CA Performance and Recognition Framework
16. m the CA and if relevant a CAP from the Environment Agency EA Natural Resources Wales NRW or SRS from Scottish Environment Protection Agency SEPA These detail planned activities over a defined period typically two years for the COMAH Intervention Plan and SRS and one year for the CAP 11 COMAH establishments are inspected in accordance to the risks they present to people and the environment In some instances the risks to the environment may be relatively very low compared to that for safety and vice versa these factors are used to determine which CA Inspector will undertake the role of Intervention Manager at an establishment 12 The CA may consider it more efficient to develop a COMAH Intervention Plan that will be delivered by only one of the CA partners This may include instances where the risk to the environment presented by an establishment is relatively very low in comparison to that for safety or vice versa i e where there is currently no potential for a Major Accident to the Environment MATTE to occur or the safety risk is well managed on a site with low inherent hazard 13 The criteria for the CA to consider single regulatory partner inspections at an establishment are a hazard groupings of C or D for both safety and environmental aspects i e DD DC CD or CC and b no significant performance issues as set out in the performance and recognition framework 14 Depending on priorities a COMAH Intervention Plan may
17. options a and b above will provide the most efficient route and the information gathered by the Intervention Manager or environmental agencies inspector s will be shared with the other regulatory partners to inform future regulatory activity 72 The Intervention Manager will be responsible for facilitating these decisions to include discussion with COMAH Operator and subsequent monitoring of regulatory outcomes 73 If the Intervention Manager EA NRW SEPA inspector and the HSE Inspector cannot agree a way forward then the Intervention Manager should take this to their Line Manager for review Understanding COMAH COMAH Intervention Manager User Manual Page 15 of 16 Health and Safety Executive Appendix 2 Terms explained Environmental agencies This means SEPA NRW and EA Intervention Manager This refers in all cases to the COMAH Intervention Manager CIM This refers in all cases to the COMAH Intervention Manager Intervention plan This means COMAH Intervention plan not to be confused with the CAP or SRS plans developed by the environmental agencies Single point of contact This means that the nominated Intervention Manager should act as the focal point for all communications between the CA and COMAH Operator on issues relating to COMAH Published by the Health and Safety Executive on behalf of the COMAH Competent Authority CCA3 11 14 Understanding COMAH COMAH Intervention Manager User Manual Page 16 of 16
18. oss sectors most notably through the Process Safety Forum The forum was established to provide a platform whereby initiatives best practice lessons from incidents and process safety strategy can be distilled and shared across sectors to drive the process safety management performance agenda For further information refer to htto www p s f org uk New and Revised Standards 67 It is important for the Intervention Manager and COMAH Operator to be aware of new and revised standards and guidance that may be relevant to a COMAH establishment this may include but not be limited to European Norms EN IEC and API publications CDOIF has been tasked with maintaining a high level overview and where appropriate will commission a review to determine the impact on industry Conversely should the Intervention Manager or specialist inspection teams become aware of new guidance or standards that may have an impact this should be reported to CDOIF to allow them to take appropriate action across a sector or sectors Understanding COMAH COMAH Intervention Manager User Manual Page 14 of 16 Health and Safety Executive Appendix 1 Dealing with duplication in CA Plans 68 If duplication has been identified then the EPR PPCR Inspector COMAH Inspector and HSE will need to agree how to proceed regulate under COMAH i e identified in Intervention Plans and CAPs SRS regulate under EPR or PPCR regulate under both 69 For EPR the choice of r
19. personnel or provision of information 48 The Intervention Manager should advise the COMAH Operator of early notice of any changes in planned visits current issues and concerns with achieving the plan outstanding information from the COMAH Operator and CA and vice versa emerging or changing regulatory approaches i e following safety alerts or new strategic priorities although it is unlikely that these will appear in the current year plan 20958 49 The arrangements above will ensure that the plan reflects the current position on the establishment and will improve efficiency in the CA s work during the annual review of plan Communicating Performance Ratings 50 Performance ratings are an important factor in determining a COMAH Operator s overall performance in controlling risk see CA Performance and Recognition Framework The ratings are made against the requirements set out in the relevant COMAH CA strategic topic delivery guides and are based on corresponding evidence sampled at the time of the inspection While CA inspectors will routinely review outcomes from previous inspections interventions and improvement notices the rating will reflect the performance of the establishment at the time of rating against the strategic topic taking into account any improvements following any earlier poor performance rating 51 Any areas of perceived weakness against the requirements of the strategic topic delivery guide should
20. rent interventions and how these will be delivered over the period of the COMAH Intervention Plan The aim is to ensure that interventions are proportionate to the risk Delivering Inspections and Managing Change 32 The Intervention Manager should oversee the delivery of the COMAH Intervention Plan and remain sighted on timing of regulatory activities identified on the COMAH Intervention Plan understanding what the planned intervention is for understanding the result of the intervention understanding the required follow up actions by the COMAH Operator and CA and the timescales that apply any disputed unexpected or inconsistent outcomes and be prepared to discuss or challenge where necessary 2052 2 33 Successful inspection will depend on proactive communications between the Intervention Manager the COMAH Operator and other CA Inspectors and Specialists 34 The Intervention Manager should be the single point of contact for any issues actions investigations audits or inspections relevant to the COMAH Intervention Plan This means that CA Inspectors and environmental agencies should feedback COMAH related issues to the Intervention Manager 35 The CIM should maintain a dialogue with other CA partners delivering the CAP SRS to ensure that relevant issues that may affect these plans are discussed 36 Unforeseen events arising in year may mean that aspects of COMAH Intervention Plan should be amended for example a If C
21. rvention activity act as a single point of contact for COMAH Operators ensure that the identified activities in the COMAH Intervention Plan reflect the establishment s risk profile and duty holder s performance in controlling major hazard risks ensure the effective development delivery and implementation of the COMAH Intervention Plan work with CA partners to reduce unnecessary overlap and duplication between the COMAH Intervention Plan and the Environmental Compliance Assessment Plan CAP in England and Wales and between the COMAH Intervention Plan and Site Regulatory Strategy SRS in Scotland coordinate any COMAH inspection work in relation to safety and the environment maintain awareness on the timing of important inspection activities set out in the COMAH Intervention Plan and CAP SRS where appropriate inform relevant CA partners of any incidents or significant events at the establishment clarify any requirements or expectations from the CA Partners or the COMAH Operator co ordinate and communicate any changes to the priorities or timescales within the COMAH Intervention Plan wherever possible resolve any disputes that may arise between the COMAH Operator and CA partners Refer to Section 8 Understanding COMAH COMAH Intervention Manager User Manual Page 4 of 16 Health and Safety Executive How the CA will Engage with COMAH Operators 10 Every establishment will have a COMAH Intervention Plan fro
22. rvention Managers assigned to establishments operated by the same Duty Holder should maintain an active dialogue with their counterparts to ensure that they deliver a more consistent approach to COMAH regulation This will also help to avoid unnecessary duplication of intervention activities and ensure the CA is sharing intelligence on performance across the group of establishments especially where these may share a common safety management system 45 Communications between Intervention Managers during intervention planning will be key to ensuring activities are aligned to provide the CA with a better overview of risk control across all of the establishments This approach will also ensure that the CA removes any unnecessary duplication and avoids unnecessary costs i e Intervention Managers might agree to target a detailed review at one establishment and identify complimentary activities at other establishments adopting targeted sampling in line with the HID Regulatory Model Understanding COMAH COMAH Intervention Manager User Manual Page 10 of 16 Health and Safety Executive Communicating progress against Planned Inspections 46 The Intervention Manager and COMAH Operator should ensure that progress against the agreed plan is monitored updated and shared 47 COMAH Operators should advise the Intervention Manager of a any business activities that may affect the plan b any changes to agreed timings for responses availability of
23. wn systems e g Environment Agency s NCAD but COMAH relevant aspects should be brought to the attention of partner organisations HSE ONR Understanding COMAH COMAH Intervention Manager User Manual Page 9 of 16 Health and Safety Executive Communication 40 One of the Intervention Manager s key responsibilities is to act as a Single Point of Contact for the COMAH Operator on all COMAH matters They are expected to understand the issues at hand and be able to coordinate any response seeking additional input from other CA regulators as required 41 COMAH Operators should address all COMAH correspondence to their Intervention Manager or copy them into direct communications to specialist or other CA partner inspectors COMAH Operators should consider whether they should appoint a similar single point of contact who would assist the CA s interaction with the Operator s establishment s 42 These arrangements will ensure consistent communication between the CA and COMAH Operator Communication with Multi Site Operators 43 Where a Lead Unit is established to cover a number of COMAH sites the existing arrangements will be maintained with the Lead Unit acting as the overarching contact for multi site COMAH Operators This means that Lead Unit contacts will continue to act and therefore fulfil the responsibilities of the Intervention Manager for multi site operators 44 Where Lead Unit arrangements do not exist COMAH Inte

Understanding COMAH: COMAH Intervention Manager: User manual

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