Sites which were not COMAH sites, will become COMAH sites due to the changes under Seveso III. Alternatively, these sites could now begin planning to identify storage facilities off site which would keep the subject site out of the Seveso III Directive scope. Given that there is only a little over 2 years before the Directive is to be implemented (No later than June 1 2015) many companies are already assessing the impact of Seveso III on their status and beginning to cost and identify possible scenarios to ensure compliance at minimum cost.
 

Costs of becoming a COMAH site include compliance fees, consultancy fees, and changes to on-site facilities such as instrumentation, monitoring equipment, bunds, tanks, surface water control systems, toxic gas protection and detection systems, management structures, head-count (additional personnel may be required), changes in operational activities on site to demonstrate compliance with the requirements of COMAH. Some changes include the following:

• Main impacts of Seveso III are on health hazards (acute toxicity) and aquatic toxicity
• There are new named substances
• New categories of dangerous substances
• Companies need to understand which substances could change scope and impacts on aggregation calculation, there is no easy way to determine impacts on status except by working through the revised classifications and revising the calculations
• GHS classifications are not yet available for every substance
• Operators will have to self classify, MSDSs are not considered sufficiently reliable so the company will have to do research on properties of substances
• Harmonised changes that have been agreed by the EU are on the ECHA website

For more informtion please contact maeve.mckenna@awnconsulting.com