the Competent Authority

CDOIF Environmental Risk Tolerability

for COMAH establishments

Ian Brocklebank
Technical Support Manager East
SEPA
tel + 44 (0)131 273 7250
e-mail ian.brocklebank@sepa.org.uk

Why was this work needed?

DETR MATTE guidance issued in 1999

Since then:
relevant environmental law and supporting guidance has
moved on and;
we have over a decade of COMAH experience.

HSE have a defined framework for assessing health and

safety risk.

No equivalent agreed framework for the environment.

How do we apply the ALARP framework to the
environment?
How do we value the environment?

CDOIF

The Chemical and Downstream Oil Industries

Forum.

Core aim:
inform regulatory and industry approaches to
issues affecting safety and health of people
sustainability and the environment.

Work published on HSE website.

Objectives and Output

Working Group set up in 2010 to:

Examine existing approaches to assessment of
environmental risk
Develop an environmental risk assessment
framework for COMAH.

Guideline published in 2013:

Screening methodology
Tolerability of risk matrix
Remains open for comment until at least the end
of 2014

Fundamental concepts

Establishment Risk;
tolerability should be based on:
the risk to a receptor from all MATTE
scenarios at a single establishment.

Consequence;
a combination of both the severity and duration
of harm.

MATTE
Major Accident to the Environment

Screening Methodology
1)

Identify Receptors;

2)

Assess unmitigated consequence;

3)

Identify tolerability thresholds;

4)

Assess mitigated establishment risk;

5)

Compare establishment risk to the thresholds;

6)

Determine if further more detailed assessment

required.

Receptors

Based around DETR MATTE guidance (1999);

Assessing consequence

This is done in two parts

Severity of harm;
the extent and degree of the damage caused.
Duration of harm;
the time taken for a receptor to recover
naturally (80% of damage).

Assessing Severity

Thresholds are given for degrees of severity for

each receptor type

Assessing Duration of harm

Thresholds are given for categorisation of

duration for each receptor type

Categorising MATTEs

The severity and duration are then combined to

categorise the level of MATTE

Assessing consequence example

Warehouse fire run-off to local river (unmitigated);

Reduction of WFD classification for approx. 130 km.

Assessing consequence example

Warehouse fire run-off to local river (unmitigated);

Natural recovery approx 15 years.

Consequence bands and the

tolerability matrix

Warehouse fire run-off to local river (unmitigated);

Severity level 3, Harm level 3
Consequence level C

Warehouse fire run-off

Unmitigated consequence level C;

Establishment risk calculated as 10-3

Risk is in intolerable region

consideration of further measures required

What have we achieved

Through the CDOIF project we have achieved;

consensus that environmental risk can be managed in
the established ALARP (and CBA) framework
the production of a screening methodology,
definition of MATTE consequences
definition of MATTE thresholds for differing levels of
MATTE consequences,
greater clarity and consensus.