What is MHHHRA?
MHHHRA stands for Major Hazard Human Harm Risk Assessment and has been developed as a comprehensive guidance document by CDOIF the Chemical and Downstream Oil Industries Forum for COMAH sites.
This guidance is expected to be formally published soon, but the Health and Safety Executive are setting expectations within industry forums and in COMAH Safety Report pre-receipt meetings that the approach set out in MHHHRA guidance should be followed to demonstrate sufficient MAH risk assessment in safety reports. Essentially this is likely to become for Safety Report Predictive assessment what CDOIF ‘Environmental Risk Tolerability for COMAH Establishments’ is for Safety report Environmental MATTE assessment.
Who are CDOIF?
CDOIF are the Chemical and Downstream Oil Industries Forum. It is a collaborative venture in the UK made up of industry leaders, trade unions, and regulators (such as the HSEx and EA / SEPA). The forum’s primary goal is to improve health, safety, and environmental standards across hazardous sectors.
The forum is best known in the process safety sector for developing guidelines to manage and assess major environmental hazards.
What does MHHHRA Require?
At OTECSA we are currently working with clients to develop their MHHHRA compliant risk assessments. We are therefore in a great place to be able to help advise what MHHHRA guidance will mean for you if you operate a CoMAH regulated site.
Some key elements of the MHHHRA include:
- IDENTIFICATION Compiling a screening table showing your full set of MAHs, grouped together for ‘intuitive areas’ and, where applicable, collated under representative scenarios
- ANALYSIS – Developing detailed considerations for each representative scenario that sets out MAH and analyses consequences in detail (e.g. consequence modelling), set out basis of safety, develop fault and event tree combinations for initiating causes and consequence outcomes, identify relevant good practice for equipment/process featured in these scenarios, explore control measures and develop scenario likelihoods and identifying individual scenario risk gaps and/or further measures required.
- ASSESSMENT – Considering overall cumulative risk for ALL individual MAH top event scenarios across all equipment and considering these cumulative risk exposure for different job functions and on site/ off-site groups of people.
- FURTHER MEASURES, ALARP – On the basis of these cumulative individual and societal risks then assessment of risk tolerability, judgements of whether risk ALARP and identification of further measures is made.
How to unpick the MHHHRA puzzle
There are a lot of elements to think about in CoMAH already, but when a new guidance document like this is released it’s even harder to know how to stay compliant. The best way to unpick a new guidance is with support from experts that have already gone through the learning.
That is why at OTECSA we are working with clients on how to best develop, organise and present this information.
Through our broad range of process safety services and experience we can help fill in the gaps that may present themselves whilst pulling together the many different elements of your MHHRA.
Some supplementary guidance on MHHHRA is available here.