TSA Insight Magazine Issue 7 - Magazine - Page 22
E NVI R O N M E N TA L
COST BENEFIT
A N A LY S I S F O R
COMAH
COMPLIANCE
PURPOSES
to be in place when the risks
are demonstrated to be either
Broadly Acceptable or As Low
As Reasonably Practicable
(ALARP); and that demonstration
has been accepted and verified.
nvironmental
Environmental
cost benefit
analysis (ECBA)
is becoming
an established
tool for
demonstrating
compliance
in relation to
the Control of
Major Accident
(COMAH)
regulations.
cost
E
analysis (ECBA)
is
an
benefit
becoming
established
demonstrating
tool
for
compliance
in relation to the Control of
Major
Accident
(COMAH)
regulations. This follows on
from the publication of the ‘All
Measures Necessary’ guidance
for the Competent Authority
Inspectors and officers, relating
to the prevention and mitigation
of environmental aspects of
major accidents. This guidance
was published in 2016 and
was linked to the Chemicals
and Downstream Oil Industry
Forum (CDOIF) Guidelines for
“Environmental Risk Tolerability
for COMAH Establishments”.
out
a
framework
demonstrating
that
for
“All
Measures Necessary” (AMN)
are in place at a COMAH
establishment in relation to
environmental risk.
The ‘All
Measures Necessary’ guidance
documents that the Competent
Authority (CA) considers AMN
22
I N S I G H T
Region, the CA starts with the
expectation that “good practice”
will be implemented (so far
as is reasonably practicable).
However, in the Intolerable
Region (where there is a higher
risk), the CA would expect
measures to be implemented
to ensure risk is reduced ALARP.
In these situations, expenditure
is required almost regardless of
cost, although often relatively
simple solutions can reduce risk
outside of this region.
For any risks that fall within the
TifALARP region, the Operator
will adopt “good practice” (so far
as is reasonably practicable) and
carry out an ALARP assessment
to determine what more could
be done to reduce risk. These
Together these documents
set
In the Broadly Acceptable
M AG AZ I N E
are based on the key question,
what more can I do to reduce
the risks? And also, why have I
not done it?
These discussions lead onto the
question of whether potential
upgrades
are
practicable
and whether they are grossly
disproportionate. Assuming that
