Executive summary
Date(s) of inspection:
July 2025
Aim of inspection
The aim of the inspection if to verify the basis for screening out chemo-toxic scenarios on a frequency basis within the COMAH safety report
Subject(s) of inspection
- COMAH - Control of Major Accident Hazards Regulations 2015 - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
I conducted a Control of Major Accident Hazards regulations 2015 (COMAH) inspection at Springfields Fuels Ltd. (SFL). The inspection sought to examine the dutyholder's arrangements for identifying, quantifying and screening out major accident hazards. This inspection was completed by ONR specialist inspectors, assessing compliance against the Control of Major Accident Hazard Regulations 2015.
The intervention centred on the identification/quantification of major accident hazards primarily in relation to ammonia, nitric acid and Nox (Nitirc Oxide and Nitrogen Dioxide)
The areas sampled included:
- definition of a major hazard
- Screening out of major accident scenarios
- Work through of scenarios,and the application of MAH criteria relating to ammonia, nitric acid and NOx.
- Strategy for mitigating hazards of scenarios that had been screened out
- Walk-down of the areas relating to the scenarios discussed.
Regulatory judgement was based on determining compliance with COMAH 2015 and the associated guidance in L111.
Conclusion
Based on the site intervention, I judge the deficiencies in the identification and categorisation of major accident hazards for the site were significant. SFL used the nuclear safety case (chemo-toxic assessments) as a starting point which identified a level of harm but then attempted to use qualitative arguments to discount credible major accident hazard scenarios. SFL provided limited evidence to support these assumptions and in my view did not justify screening out nitric acid, Nox or intermixing scenarios.
Consequently, as a result of the methodology, there were several potential major accident scenarios that had not been identified and characterised and had been discounted without supporting evidence. This is a shortfall of Regulation 5 and 7(8) of COMAH 2015, Schedule 2 which specifies the requirements of an effective safety management system, including the identification of all major accident hazards.
I have assigned an amber rating with respect to COMAH compliance.
To bring the organisation back into compliance, I have raised a Level 3 regulatory issue (RI-12703)
The EDR record that supports this decision is attached to CM9 (2025/37791).