HFL Consulting (now part of SLR)

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In 2014, CIRIA (the Construction Industry Research and Information Association) in conjunction with SLR Consulting and a wider Project Steering Group released new guidance: ‘Containment systems for the systems for the prevention of pollution: Secondary, tertiary and other measures for industrial and commercial premises’ (C736). The document replaced earlier R164 guidance (1997) and widened the scope beyond design principles. The inclusion of the lifecycle of containment systems, such as ongoing inspection and maintenance, as well as the placement of greater emphasis on the use of risk assessment to identify containment requirements, developed the guidance for broader industry application.

The guidance – made freely available via the CIRIA.org website – is now entering its 6th year of circulation. Since inception, it has quickly become an important source for the design and maintenance of containment systems throughout much of industry and is referred to as a Control of Major Accident Hazards (COMAH) benchmark within the Safety Report Assessment Manual (SRAM), as utilised to assess COMAH Safety Reports (CSR) by Competent Authority assessors against the COMAH Regulations 2015.

As a process safety consultancy, HFL Consulting Limited (now part of the SLR Group) have been working with a number of COMAH establishments around the UK in the review of existing secondary and tertiary containment systems. As well as using the guidance to infer advice provided to clients developing new containment systems, we have also been extensively utilising the document as a benchmark to perform gap analyses and identify potential further measures or upgrades, with the ultimate aim of demonstrating that the risks are ‘ALARP’ (as low as reasonably practicable).

The guidance assists with such matters since it covers all realistically implementable containment options, from simple concrete bunding or sacrificial areas to more complicated remote transfer and containment systems, as well as the requirements for ongoing inspection, maintenance and upgrade. Recommendations in the report also factor in a three-tiered system for containment depending on the materials stored and the risk that these could breach containment, causing significant harm to people and the environment in the process. Since many COMAH establishments are likely to be automatically in the highest tier, which requires a much greater level of control, the document provides a comprehensive benchmark to support such work.

However, any published document is rarely without critique and thus only through use of the guidance can we identify and implement changes to improve effectiveness of use. In addition, the C736 guidance brought in a lot of learnings from large-scale incidents, which unfortunately still occur on the global stage. Only through regular review of guidance can the offering be improved and capture new understanding, best practice or technology.

CIRIA have recently announced plans to begin the process of reviewing and updating the guidance, starting with an industry consultation. The first stage of this is a survey, which is available via this link and has been part sponsored by SLR Consulting.

The survey will be available until July 20th after which we are informed there will be a workshop. This is a great opportunity for COMAH establishments to have their say on the guidance and the challenges it presents.