A Guide to Achieving

and Maintaining COMAH

Compliance
For Electrical, Control & Instrumentation
Systems

Introduction
Owning and operating hazardous process plants, particularly those that fall under the COMAH regulations (see link below)
requires compliance with a number of regulations, standards, and associated guidance documents.
Health, Safety, and Environmental (HS&E), Operational and Engineering Managers are responsible for COMAH compliance
and submitting COMAH Safety Reports. COMAH reports require evidence that your systems are compliant, and managed,
tested, and maintained correctly. If you are unable to demonstrate compliance, the Competent Authority (CA) is likely to
increase monitoring and intervene more frequently at your site, increasing the time and cost you spend demonstrating robust
management systems.
The new Electrical, Control and Instrumentation (EC&I) operational delivery guide produced by the Competent Authority (CA)
describes the approach that the CA follows for inspecting EC&I systems at COMAH establishments. This guide specifies the
benchmark standards used to assess the management of risks by the Operators of COMAH sites.
Schedule 4 of the regulations specifically references the need to provide sufficient information to the CA to demonstrate your
compliance with the regulations. This includes design, construction, operation and maintenance of equipment linked to major
accident hazards. Failure to demonstrate compliance can lead to an improvement notice, a prohibition notice, or prosecution.
Three priority topics for EC&I systems are covered:
Functional Safety
Explosive Atmospheres (Hazardous Areas)
Electrical Systems
Further information is available at the following websites.
http://www.hse.gov.uk/eci/index.htm
http://www.legislation.gov.uk/uksi/1999/743/contents/made

What You Need To Know

Functional Safety
Functional Safety covers all elements of design, installation,
operation, maintenance, and management of Instrumented
safety systems. These systems are required to protect life and
minimise the risk of major accidents.
Section 12 of the Safety Report Assessment (SRAM)
produced by the Health and Safety Executive (HSE) defines
the assessment protocol used by the CA to determine
compliance with the technical requirements of the COMAH
report. Section 12 specifically covers Functional Safety. In
conjunction with these criteria, the CA have also produced
a framework and approach for inspecting all EC&I systems
at COMAH establishments. This specifies the benchmark
standards for assessing the management of risk by
Operators.
The Functional Safety standards and guidance documents
are:
BS EN 61511
EEMUA Publication No. 191
These documents relate to the following systems:
Safety Instrumented Systems (SIS)
Basic Process Control Systems (BPCS)
Alarm Systems
Complying with the relevant standards for Functional Safety
(in this case BS EN 61511 and EEMUA publication No.191)
is a fundamental necessity in submitting a compliant Safety
Report. The standards apply to all installations built since
the introduction of the standards. For installations built prior
to these standards, the Operator must produce plans to
migrate to more modern (and inherently reliable) systems
and demonstrate that measures are in place to achieve this
goal.
The systems noted above provide your site with the
necessary risk mitigation against hazardous events. Your
staff and the community and environment in which you
operate are totally reliant on these systems to prevent
hazards.

For Hazardous Areas the regulations and standards

documents are:
DSEAR Regulations 2002
DSEAR ACOP L138
BS EN 60079
These documents relate to:
Risk Assessment
Selection, Design, installation, maintenance, and
periodic inspection of equipment
The management of these systems
Compliance with the relevant standards for Hazardous Areas
(in this case the series of documents from BS EN 60079)
covers a broad range of topics including:
Electrical and instrument equipment
Lightning
Static
RFI and cathodic protection

Hazardous Areas

Gas detection (toxic and flammable)

Hazardous areas covers a number of elements, including

Area Classification documentation, inspection, maintenance,
and competency. The overarching document is the Risk
Assessment, as described in Regulation 5 of the Dangerous
Substances and Explosive Atmospheres Regulations 2002
(DSEAR).

Fire detection

Electrical Systems Safety

Regulation 4 of the Electricity at Work Regulations 1989
(EAWR) covers the general safety of Electrical systems and
includes specific references to construction, maintenance,
and operation.
Compliance with the relevant standards for Electrical Power
Systems requires that you:
Ensure that every aspect of the electrical installations
on your site complies with current legislation, codes
of practice, standards and established best practice.
Assess the competency of personnel working on
your electrical distribution system.
Ensure that the electrical site records accurately
reflect your site installation.
Authorize personnel to carry out HV and LV
switching operations.
Implement properly documented and controlled
procedures to ensure that all personnel working on
or near electrical installations do so in a safe and
controlled manner.

Approach to Compliance
Ensuring that your systems not only guarantee compliance,
but also fulfil the original needs stated in your Safety
Requirements Specification (SRS), requires a continuous
improvement approach. Correct and current documentation
demonstrates that your systems are properly managed,
tested, and maintained. Your SRS should also reflect any

modifications and changes made to the plant on an ongoing

basis.
The continual maintenance of your Risk Assessment
is one of the first steps in ensuring compliance. With
decreasing engineering support staff on many sites and the
increasing burden of legislation to improve safety standards,
maintaining well-documented, secure, and compliant
systems and processes becomes significantly more difficult
and challenging for the HSE manager.
An appropriate first step may be to conduct a systematic
review and assessment, in line with the appropriate
standards, to identify any apparent shortfalls in Functional
Safety, DSEAR Risk Assessments, and Area classification.
This will form a comprehensive analysis of areas needing
improvement and provide tangible recommendations
and practical solutions to rectify shortfalls. The flow chart
(derived from BS EN 61511) at the end of this guide
illustrates the clauses listed in the standard.

Functional Safety
To achieve Functional Safety, you should use highly skilled
and Exida-qualified Functional Safety Engineers, who can
tailor an approach based on the complexity and extent of
your systems, and prioritize solutions to create a complete
compliance implementation program. Services could include
a gap analysis of your documentation, a review of proof
testing procedures, a review of your SIL assessments, and
full verification and validation of your Functional Safety
Systems.

DSEAR & Hazardous Areas

For DSEAR and Hazardous Areas, you may need a gap
analysis of your documentation, new Risk Assessments,
or a review of existing Risk Assessments, along with Area
Classification exercises complete with full documentation.
The classifications should be stored within a database that
registers all equipment, plot plans, inspection details, and
fault reports to assist engineers in tracking issues relating to
hazardous areas.

Electrical Systems Safety

For Electrical Safety, needs would include supporting your
site team with all aspects of ongoing enhancements of
electrical engineering, a safety audit of the site, distribution
system analysis, (such as fault level and protection coordination studies), developing safe operating procedures,
assessing competence, and providing training.

Verification and Validation of Functional Safety Systems

To ensure that your systems comply with COMAH regulations, you must verify and validate them. System validation requires
in-depth review of your systems to ensure they achieve the requirements in your Safety Requirement Specification (SRS)
document, while determining whether the right system has been built or modified. Section 15 of the standard defines this
process.
Section 7 of the standard defines verification of the systems and whether the systems are operating as designed for each
part of the safety life cycle. This requires auditing systems design and commissioning, testing documentation to determine
any deficiencies, and recommending documentation improvements.

How GSE Can Help

COMAH requires adherence to a number of regulations, standards, and associated guidance documents. As your workforce
turns over due to retirement and competition, are your systems at risk? As you continuously improve plant operations,
adding automation and improved processes, are you forgetting that your functional safety requirements must be managed,
tested, and maintained, as well?
GSE believes that following a structured process is the key to compliance, and more importantly, to ensuring the safety
of your people, plant, and environment. We would like to discuss all of your COMAH compliance needs, how our staff of
experts can keep your site personnel abreast of new legislation, and how we can help you implement any changes required
to maintain compliance.
We have an excellent track record providing these services in numerous high-hazard environments, including major Oil and
Gas and Chemical Operators, along with smaller manufacturing facilities.
Our approach is to discuss your facilities and operations, and with a full understanding of the extent and roles that your
existing systems play in reducing risk, propose a detailed solution to help you achieve and maintain compliance.

Requirement for New / Modified Plant

Process / Plant Design
Safety Targets Based on R2P2
Details of Operational & Technical Resource

Safety Requirements Specification BS EN 61511 - Clauses 8, 9, 10

Safety Assessment e.g. LOPA, Calibrated Risk Graph
Safety Functions defined and allocated to independent protection layers
Safety Instrumented Systems (SIS) defined and Safety Integrity Level (SIL) requirements allocated

Design BS EN 61511 - Clause 11

Management of
Functional Safety
BS EN 61511 - Clauses 5&7
Policy & Procedure
Responsibilities
Cometpency of Staff
& Contractors
Planning
Verification
Audit & Review

Unique Safety Function / System Reference

Detailed Design Drawings (Schematics, Loops, Power Supply Systems)
Technical Information on all system components including reliability data (manufacturers and/or
proven in use)
Ex. Design Information & Certification (if applicable)
SIL Demonstration Calculations and Proof Test Interval Determination
Life Cycle Procedures Developed (e.g. maintenance, inspection & testing)

Installation, Commissioning & Validation BS EN 61511 - Clauses 13, 14, 15

Factory Acceptance Test (if applicable)
Installation & Commissioning Documentation
Validation documentation demonstrating that systems have been fully tested, checked and
approved against the written safety requirements specification

System Operation & Maintenance BS EN 61511 - Clause 16

Staff / Contractor Competence Training

Written Proof Test Procedures Reviewed Against 428/2002
Systems and Controls for the Management of Override
Evidence that proof tests are periodically inspected (may exclude ex. inspection if applicable)
Periodic System Review by Competent Person (e.g. review of proof testing interval)

System Modification BS EN 61511 - Clause 17

Change Handled Under Site MOC
Procedure
Impact Assessment & Authorisation
Change Fully Verified & Documentation
Updated

System Decommissioning BS EN 61511 Clause 18

Impact Assessment & Authorisation
Deommissioning Procedure
Documentation Advice

About GSE Systems

We provide performance improvement solutions to the energy and process industries by combining expertise in
engineering, operations, visualization, training and simulation to improve both human and plant performance.
We have more than 300 employees and over four decades of experience as well as more than 1,100 installations
and hundreds of customers in over 50 countries spanning the globe.

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