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Safety and environmental standards for fuel storage sites

Final report

91

reputation risk or business financial risk but much of this report will be of assistance in carrying

out such evaluations.

37 Regulation 4 of the COMAH Regulations requires dutyholders to ‘take all measures necessary

(AMN) to prevent major accidents’. This is equivalent to reducing risks to ALARP. HSE’s semi-

permanent circular

Guidance on ALARP decisions in COMAH

61

states that:

‘The demonstration that AMN have been taken to reduce risks ALARP for top-tier COMAH

sites should form part of the safety report as required by regulations 7 and 8 of the COMAH

Regulations… For high-hazard sites, Societal Risks/Concerns are normally much more relevant

than Individual Risks, but Individual Risk must still be addressed’.

38 See also paragraphs 108 and 109 of

A Guide to the COMAH Regulations

L111.

62

39 For each ‘in scope’ tank with the potential of an explosion following an overflow, the

tolerability of risk of the major accident hazard scenario must be assessed. A risk assessment

should address the categories described in paragraph 25.

Scenario-based safety risk assessment

40 LOPA, like most risk assessment tools, is suitable for this type of risk assessment, using the

following approach:

determine the realistic potential consequence due to the hazardous scenario (in this case the

number of fatalities due to an explosion following an overflow from a specific tank);

estimate the likelihood of the scenario; and

locate the consequence and likelihood on the following (or similar) risk matrix (Table 8).

Table 8

Risk matrix for scenario-based safety assessments

Likelihood of ‘n’ fatalities

from a single scenario

Risk tolerability

10

-4

/yr – 10

-5

/yr

Tolerable if ALARP Tolerable if ALARP Tolerable if ALARP

10

-5

/yr – 10

-6

/yr

Broadly acceptable

Tolerable if ALARP Tolerable if ALARP

10

-6

/yr – 10

-7

/yr

Broadly acceptable

Broadly acceptable

Tolerable if ALARP

10

-7

/yr – 10

-8

/yr

Broadly acceptable

Broadly acceptable

Broadly acceptable

Fatalities (n)

1

2–10

11–50

41 Table 8 is based on HSE’s

Guidance on ALARP decisions in control of major accident

hazards (COMAH)

SPC/Permissioning/12. Note that a scenario-based risk assessment with a

single fatality is not the same as an Individual Risk calculation.

42 This assessment should be repeated for each ‘in-scope’ tank in turn. Where there is a

large number of in-scope tanks (eg ten or more) the aggregate risk from all of the tanks may be

adequately addressed by the individual and societal assessments detailed below, but may require

a separate assessment.

Individual Risk assessment

43 The tank overflow scenario may contribute to the risks to individuals, either on-site or off-

site. Where the total risk of fatality to any individual (the Individual Risk) from the activities at the

hazardous establishment exceeds a frequency of 10

-6

per year (see

Reducing risks, protecting

people

paragraph 130), additional risk reduction measures should be considered, either at the

tank or elsewhere, to reduce the risk so far as is reasonably practicable. This exercise should form

part of the safety report demonstration for an establishment considering the risk from all major

accident hazards.