The Control of Major Accident Hazards Regulations 2015 (COMAH) are the enforcing

regulations within the United Kingdom of the Seveso II Directive devised in Brussels following
the Seveso disaster. The principal aim of the regulations is to reduce the risks of potential major
accidents, such as the Flixborough disaster, that are associated with the handling of hazardous
substances. The regulations operate on two levels depending on the establishment's status which
is divided into two categories,'Lower Tier' and 'Upper Tier', determined by inventory. CIMAH
refers to the Occupational Safety and Health (Control of Industrial Major Accident Hazards)
Regulations 1996 and it came into force on 1 February 1996. Directive 82/501/EC or SEVESO
Directive I was a European Union law aimed at improving the safety of sites containing large
quantities of dangerous substances. It gets its name from the Seveso disaster. However, it was
superseded by the Seveso II Directive and then Seveso III directive. Seveso III replaces the
previous Seveso I (Directive 82/501/EC) and Seveso II (Directive 96/82/EC) directives, updating
the laws due to for example changes in chemical classification regulations. Table below shows
the similarities and differences between COMAH, CIMAH, and SEVESO Directives.

Similarities Differences

All of them are not applied for industrial CIMAH and COMAH state that items of
activities related to nuclear or radiating information to be communicated to the public
substances. include name of manufacturer and address of
industry, explanation about the industrial
activities, classification of danger and hazard,
and further relevant information. On the other
hand, there are changes made in Seveso III
that make it differ from previous directives.
The changes include enhanced public
participation compared to previous Seveso
Directives. Governments are obliged to
actively inform the public on a permanent
basis about upper-tier Seveso establishments
and guidelines in the event of an accident. In

COMAH UK 2015: Part 1, No 3(2)(c)
CIMAH 1996: Part 1, Regulation 2(a)
SEVESO Directive I: Article 2(1)
SEVESO Directive II: Article 4(b)
SEVESO III: Article 2(2)(b)
All of the regulation are used to control major
accident and the regulation are apply to all
industrial activities except for military
establishments.
CIMAH: Part 1, Regulation 2(b)
SEVESO Directive I: Article 2(2)
SEVESO Directive II: Article 4(a)
addition, public participation in the planning
of new Seveso establishments, changes to
existing establishments and developments in
the proximity of such establishments is
encouraged and increased.
COMAH UK 2015: Part 5, No. 17(1)
CIMAH 1996: Part 4, No. 22
SEVESO III: Article 14(2)
In SEVESO III and COMAH UK 2015,
operator’s obligation is to take all measures
necessary to prevent major accidents and to
limit their consequences for human health and
the environment. For example, every operator
must demonstrate to the competent authority
that it has taken all measures necessary. While
in CIMAH 1996, the operator or the
manufacturer have to submit to the Director
General the Notification of Industrial Activity
Form within three months after the
commencement of these Regulations in
respect of an existing installation or an
installation which is under construction or in
respect of a new installation after the
commencement of these Regulations,
within a month before the construction
thereof.
COMAH: Part 2, No. 5(2)
CIMAH: Part 2, No. 7
SEVESO III: Article 2(2)(a) SEVESO III: Article 5

Among the regimes, there are requirements From these regimes, each has its own
for emergency plans. requirements. In CIMAH 1996, it states how
on-site and off-site emergency plans should be
prepared in case there is a major accident
happen during the industrial activity. Whilst,
in COMAH UK 2015, it lists the objectives of
the emergency plan and explains how internal
and external emergency plans are prepared,
reviewed, tested, and implemented. It also
clarifies how a local authority may or may not
be exempted from preparing an external
emergency plan. On the other hand, in
SEVESO Directive I, it states what to be
included (safety equipment, alarm systems,
and resources), what information to be known,
and who to be involved to prepare for
emergency plans. Till then, in SEVESO
Directive II, it explains how emergency plans
are established and practiced in order to
achieve its objectives. Yet, this is also
explained in SEVESO Directive III.

CIMAH 1996: Part IV, Regulation 18, 19, 20, CIMAH 1996: Part IV, Regulation 18, 19, 20,
21 21
COMAH UK 2015: Part 4 COMAH UK 2015: Part 4
SEVESO Directive I: Article 5:1(c) SEVESO Directive I: Article 5:1(c)
SEVESO Directive II: Article 11 SEVESO Directive II: Article 11
SEVESO Directive III: Article 12 SEVESO Directive III: Article 12
All these regulation are used to control or
prevent major accident involving hazardous
material.
COMAH: No 483, Health and Safety
CIMAH: Part 1, Regulation 3 (a)
SEVESO III: Directives, 2
Among the regimes, there are requirements
for safety reports.
COMAH UK 2015: Part 3
SEVESO Directive II: Article 9
SEVESO Directive III: Article 10
Following a major accident, regulations in In COMAH and all three SEVESO Directives,
COMAH, CIMAH and SEVESO Directives the regulations do not apply to exploitation
SEVESO Directive III and COMAH UK 2015
categorize the hazardous or dangerous
chemical qualifying quantity and substances
based on upper and lower tier requirement
while CIMAH 1996 categorize it based on the
threshold quantity.
COMAH: Schedule 1, Part 2
CIMAH: Schedule 2, regulation 2
SEVESO III: ANNEX I, Part 2
From these regimes, they have different
clarity in the purpose and content of safety
reports. For example, in both COMAH UK
2015 and SEVESO Directive III, the safety
report is produced by the operator of an
upper-tier establishment. But, in SEVESO
Directive II, the operator required by the
Member States produces the safety report.
Moreover, from the aspect of reviewing the
safety report, both SEVESO Directive II and
III have the same content, but in COMAH UK
2015, it has the same content with extra
conditions.
COMAH UK 2015: Part 3: 8, 10
SEVESO Directive II: Article 9: 5
SEVESO Directive III: Article 10: 5
require the operator of the establishment activities including exploration, extraction and
where the accident occurred must, as soon as processing of minerals in mines and quarries.
practicable do the following actions: However, these activities are not excluded in
(a) inform the competent authority of the CIMAH.
occurrence of the accident
(b) provide the competent authority with the
following information as soon as it becomes
available
(i) the circumstances of the accident
(ii) the dangerous substances involved
(iii) the data available for assessing the
consequences of the accident on human health
the environment and property
(iv) the emergency measures taken
(c) inform the competent authority of the steps
it is envisaged are required in order to—
(i) mitigate the medium term and long term
consequences of the accident
(ii) prevent any recurrence of such an accident
(d) update the information provided under
sub-paragraphs (b) and (c), if further
investigation
reveals additional facts which alter that
information or the conclusions drawn.

COMAH UK 2015: Part 7, No 26(1)() COMAH UK 2015: Part 1, No 3(2)(d)

CIMAH 1996: Part 5, Regulation 23 CIMAH 1996: Part 1, Regulation 2
SEVESO Directive I: Article 10(1) SEVESO Directive I: Article 2(4)
SEVESO Directive II: Article 14(1) SEVESO Directive II: Article 4(e)
SEVESO III: Article 16 SEVESO III: Article 2(2)(e)