A COMAH gap analysis is often the first step organisations take when preparing for a transition to Upper Tier status under the Control of Major Accident Hazards Regulations. At OTECSA Consulting, we regularly support clients in understanding their current level of compliance and identifying the work required to meet regulatory expectations.
This also aligns with the new CDOIF MHHHRA (Major Hazard Human Harm Risk Assessment) guidance.
A structured COMAH gap analysis provides a high level review of a site’s processes, procedures, and management systems. The aim is to determine how effectively the organisation manages Major Accident Hazards and how this aligns with the requirements set out in the Control of Major Accident Hazards Regulations 2015.
What Does a COMAH Gap Analysis Involve?
Our approach to COMAH gap analysis combines both on site engagement and detailed document review.
Typically, the process involves several days working closely with key personnel from health and safety, engineering, and operational teams. During this time we review site practices, management systems, and documentation that demonstrate how major accident risks are controlled.
This is followed by an extended offline review of documentation. The aim is to evaluate the organisation’s current arrangements against the criteria defined in the HSE Safety Report Assessment Manuals (SRAMs).
By comparing current practices with SRAM expectations, we can determine the organisation’s current status and identify where improvements or additional information may be required. We can also review the clients information against the new CDOIF MHHHRA to understand what additional work might need done.
Identifying Gaps Before Regulatory Inspection
One of the key benefits of a COMAH gap analysis is the ability to identify potential weaknesses before they are identified by the regulator.
Through the review process we provide clear recommendations that help organisations:
- Understand their current compliance status
- Identify gaps in systems and documentation
- Prepare information required for a Safety Report
- Plan the steps needed to achieve Upper Tier compliance
Addressing these areas early can significantly smooth the transition into Upper Tier regulation.
Preparing for an Upper Tier Safety Report
For sites moving into Upper Tier COMAH, the preparation and submission of a Safety Report is a major milestone. This process can take considerable time and coordination across multiple departments.
In many cases, preparing a Safety Report, submitting COMAH notifications, and updating Hazard Substances Consent can take up to a year or longer. Starting with a structured gap analysis helps organisations plan this journey effectively.
Experience Supporting COMAH Sites
Our experience delivering COMAH gap analysis across a range of industries allows us to provide practical guidance based on real regulatory expectations.
Our team has direct experience from both operational and regulatory perspectives, including:
- Working within Upper Tier COMAH environments
- Preparing and defending Safety Reports and Safety Management Systems
- Managing and facilitating COMAH specialist inspections
This experience provides valuable insight into Competent Authority expectations and helps organisations demonstrate compliance in a clear and practical way.
Getting Started with a COMAH Gap Analysis
A gap analysis is considered good practice for any organisation handling hazardous substances. It is particularly important for sites currently operating at Lower Tier or outside COMAH but approaching Upper Tier thresholds.
Starting the process early allows organisations to understand their position, plan improvements, and manage the transition more effectively.
If you would like to learn more about COMAH gap analysis or discuss your current compliance status, contact David Fox or the OTECSA Consulting team.