COMAH Strategic Forum – building on success

The COMAH Strategic Forum (CSF) now has ten demonstrably successful years under its belt, and this is due to strong leadership and the willingness, enthusiasm and dedication of its ever-widening membership.

Back in 2013, the idea was to bring the Competent Authorities and ‘chemicals sector’ together to discuss matters of strategic importance in the management of major hazards. Since then, however, the remit of CSF has grown from a place of discussion to a place of decision and action, where strategic topics are decided and follow up action agreed. The forum provides a platform and framework within which the various bodies involved in managing major hazards in the UK can openly discuss, debate and agree objectives and prioritize action plans.

Key to its success has been the open and frank debate and discussions and the mature relationship that has developed over the years between Regulators and the regulated in managing major hazards. The sharing of different experiences, insights and perspectives has undeniably led to better outcomes as well as mutual credibility and trust built up through delivery on promised action.

As the forum’s influence has grown, so has its membership. The original Competent Authorities comprising, HSE, EA, SEPA and NRW, have now been joined by the Office for Nuclear Regulation (ONR). The major Trade Associations, in the sector, CIA, UKPIA, CBA and, of course, TSA, were joined by Liquid Gas UK and BCGA. The Unite union added a further dimension to the forum.

The scope has also widened beyond the ‘chemicals sector’ to embrace all onshore COMAH operators. At the present time, the forum‘s reach through the trade associations extends to about half of all UK onshore COMAH sites.

A key underpinning achievement was agreeing a vision for success that was shared by both the Competent Authorities and industry. This common vision provides clarity on what CSF aims to achieve and enables the forum to focus action on delivering those outcomes.

The “vision” was published in July 2015 and re-endorsed in 2018. The main points are:

  • Thriving safe and sustainable sector with a regulatory regime that supports business growth, high standards and strong compliance
  • Good COMAH performance is seen as good business
  • Principles of Process Safety Leadership and lessons of Buncefield are embedded in way business manages major hazard risks
  • Confidence is underpinned by greater transparency in public reporting and sharing learning
  • Consistent good performance and evidence of continuous improvement results in earned recognition and proportionate regulatory scrutiny
  • Standards and expectations are clear giving business certainty. Business holds itself to account
  • Regulators operate in a joinedup way and adopt a consistent, risk based and proportionate approach
What and where next 

After seven years as the extremely successful and highly respected Chair of the CSF, Ken Rivers stood down and Gus Carroll was appointed as the new Chair in 2021. Quickly realising that CSF had been incredibly successful, the big question, recognising the comprehensive scope and magnitude of the work being conducted by the various CSF working groups, was what and where next.

A strategy workshop involving all CSF members was held in 2022 to discuss, debate and agree what was going well and where perhaps there were areas that could be further enhanced. A comprehensive SWOT analysis was produced, leading to an agreement to conduct an independent strategic review of CSF.

CSF strategic review 

The scope of the independent strategic review was agreed. This would need to include, among others, a review of the governance and vision of the CSF taking due regard for the tripartite nature of the forum and the relationship between the forum and its working groups. It was also agreed for the review to contain recommendations focused on the robustness of decision-making and actions, including the composition of working groups and how work is delivered. In addition, the review would have to identify whether the CSF has the capacity to deliver on its commitments, primarily through the working group structure, and to ensure that its work plans are suitably prioritised. Finally, it was agreed for the review to place particular emphasis on ensuring the CSF maintains its original purpose, as set out in the CSF vision statement.

I was asked to undertake the independent strategic review and met with the CSF Steering Group in early 2023 to discuss and agree how to conduct it. A list of crosssectional organisations, both from the CSF membership and from those organisations supporting and assisting CSF, was agreed as a representative sample for me to discuss the scope of the review with and a defined question set, so as to provide structure to the ensuing discussions with each organisation. Following my discussions with selected organisations, I presented my final report to the CSF in May, which detailed my key findings, common themes and recommendations.

Key findings and common themes 

When interviewing the selected CSF member (and affiliated) organisations, it was clear that there were a number of common themes and views, as well as individual views, that members were keen to express.

For one, it is clear that the CSF is well liked and respected and is seen as an extremely valuable, ‘safe’ and collaborative forum for round table open discussion on COMAH related issues with Regulators and relevant stakeholders, where the relevant parties can be ‘aligned but not joined’. And there is pride that the forum exists and that it has been running for some 10 years with demonstrable success achieved. There is also pride that this type of collaborative approach may not exist in other countries, while a particular benefit is seen in that the forum enables difficult issues to be discussed, even if the result is an agreement to disagree in certain areas. Members have also a good understanding of the objectives of CSF i.e. to provide assurance that the objectives of the COMAH regulations are met, Major Accident Hazards are managed such that public relations, reputations, assets and people are protected, with continuous improvement in personal and process safety performance. And, in doing so, that regulation is proportionate and prioritised and industry is sustained, with priorities jointly agreed by Regulators and the regulated to achieve this.

Looking ahead, there is a strong desire for the CSF to continue to build on the success it has achieved. The Summer 2022 workshop recognized that a number of improvements should be considered to achieve this, including the CSF review. The 3 Cs (Coherent, Consistent and Capable) were agreed by most members as the correct themes to take the CSF forward for the next 1-5 years. There was, however, a suggestion that a 4th C – ‘Collaboration’ – could be included given the considerable value in the collaborative and collegiate way in which the CSF operates, enabling good professional relationships to be formed and maintained between the people who represent the various organizations that are members of the Forum.

From the review, it is also clear that focus should be on both the ‘here and now’ in terms of COMAH and managing Major Accident Hazards (e.g. ageing assets, skills issues, repurposing of assets to cope with energy transition etc.), whilst also being aware of the impact of emerging technologies that will likely be regulated by COMAH. A targeted and prioritised approach to key initiatives was also seen as beneficial as the CSF look to the future, along with a focus on participation in Working Groups and on timely and targeted deliverables from these. In terms of collaboration and partnership, findings point to the benefit of engaging with other forums with regard to specific topic areas and initiatives. And, the need for renewed emphasis on communications and awareness of the important work of the CSF, both internally and externally, is evident.

Recommendations 

Based on the discussions I held with the 15 selected CSF member (and affiliated) organizations and the views they expressed, summarized above, my recommendations have been set out in four main areas, namely:

  1. Organization, Structure and Governance
  2. ‘Focus and Prioritisation
  3. Visibility
  4. Widening the CSF membership
1. Organization, Structure and Governance 

My recommendations under this key area include the establishment of an executive level steering group to oversee the CSF and provide direction and visible leadership to the Working Groups. The group would also be tasked to draft a Strategic Plan, to be reviewed yearly and to be shared, debated and agreed with input from all CSF members, incorporating a reviewed Vision Statement to cover the next 1-5 years of CSF, recognizing that ‘growth’ within CSF will continue to evolve, particularly in light of the energy transition, decarbonization and Net Zero. Recommendations in this area also include the need to focus on establishing collaborative links with other relevant forums to allow these forums, for example, to take on board non-COMAH (and therefore non-CSF) related issues and allow for useful exchanges on issues and technologies beyond the capability of CSF.

2. Focus and Prioritisation 

My recommendations under this key area include an analysis of the number and effectiveness of all Working Groups, ensuring that they have and are completing targeted, deliverable outputs in a timely and efficient manner. In addition, the implementation of a review mechanism for all Working Groups to measure their effectiveness and success would be beneficial.

3. Visibility 

In terms of visibility, my recommendations in this area focus on how best to communicate about the work of the CSF, both internally and externally, as well as widen outreach through, for example, a dedicated website, a newsletter for members and the CSF annual conference.

4. Widening the CSF membership 

Currently, membership of CSF only covers approximately 50% of COMAH sites. Representation from other upper tier and lower tier COMAH sites would be beneficial to both the CSF and those not currently represented.

The above is the essence of the report I presented to the all-member CSF meeting in May 2023. My recommendations were debated, agreed and endorsed. An order of priority to tackle these recommendations was also agreed.

The CSF and its members will now work through and deliver on these, whilst, of course, continuing with the valuable work of the CSF.

There is no doubt in my mind that the creation, evolution and the future of the CSF has been, and will continue to be, of enormous importance and significance to Regulators, the regulated and all relevant stakeholders – and consequently to society. I wish the CSF and its members every success in both their current and future activities.

About the COMAH Strategic Forum 

Established in 2013, the COMAH Strategic Forum is a high level joint industry and regulator forum working to improve major accident hazard leadership, management and raise standards across the industry. This joint forum provides industry and the Competent Authority (CA) with a means for strategic discussion on how they can work together to provide leadership and encourage continuous improvement in the inspection, management and control (including emergency preparedness and response) of major accident hazards across the onshore industries. The forum’s partners engage collaboratively to identify and share best practice and, where necessary, to commission the development of new guidance.

You can engage with CSF through its annual ‘open meetings’. The aim of the CSF Open Meetings is to “engage the unengaged”. Its target audience is therefore operators of sites with the potential to cause a major hazard accident but who are not affiliated with the current CSF member Trade Associations.

If your organisation is a member of an existing Process Safety Forum (PSF) trade association, you should contact them. A list of participating trade associations is available on the PSF website: www.p-s-f2.org.uk 

The Tank Storage Association (TSA) is a member of the COMAH Strategic Forum.