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Recent natural disasters in the US, including Hurricane Irma in Florida and mass flooding in Texas caused by Hurricane Harvey, may serve as a wake-up call for operators of COMAH sites here in the UK. Impacts were more widespread than originally thought due to a lack of preparedness in some quarters. Arkema SA, a Houston based French owned speciality chemicals company, saw chemicals degrade and combust causing explosions and fire following failure of refrigeration systems as a result of flooding. The situation worsened when emergency services were not given the correct information. As a consequence, 15 emergency workers who were exposed to fumes were admitted to hospital and  Arkema is now facing a lawsuit for failing to take adequate steps to secure dangerous chemicals ahead of Hurricane Harvey.

So, could the same happen here?

Flooding is the most common and widespread natural disaster in the UK, and a number of major hazard sites have been badly affected over the years. It’s not surprising then that the COMAH Competent Authority expects plans to be in place at sites located in areas where the potential for flooding exists.


COMAH sites vulnerable to flooding will need to:

  • Carry out topographical surveys to assess flood potential
  • Assess the impact of flood water submerging process plant and equipment
  • Assess the impact on utilities and safety critical equipment, including DCS and SCADA systems
  • Complete flood Hazard and Operability (HAZOP) Studies
  • Specify appropriate and proportionate risk reduction measures
  • Develop flood response strategies and plans to deal with specific scenarios
  • Develop post flood recovery plans (PFRPs)
  • Allocate roles and responsibilities and put plans in place to build competence of staff

At HFL Consulting, we provide COMAH support to more companies than anyone else in the UK. Our team of engineers and process safety professionals can help you to understand the risks and target resources to comply with good practice guidance and deliver plans aligned to corporate, site and regulatory goals. Learn more about how HFL Consulting can help you and your business here.

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