Correlation with new and old systems
Implications for COMAH / Seveso facilities
- Very toxic materials (T+): the qualifying quantities for some of these materials will increase (e.g. those that fall within category 2 under GHS), which will allow larger quantities to be stored before the COMAH regulations apply.
- Toxic materials (T): the implications do not appear significant in this case, although some materials currently classed as toxic by ingestion may drop out from the COMAH regime.
- Harmful materials (Xn): it appears that some materials currently classed as harmful (by inhalation or skin contact and therefore non-COMAH) will qualify as COMAH materials once the new system is in place, i.e. those that fall within category 3 under GHS.
The transition to GHS will also prompt some changes to the listing of named substances in the COMAH legislation. The most significant of these appears to be for heavy fuel oil (HFO), which will be included as a named substance under petroleum products. This will have the same qualifying quantities as gasoline, kerosene and diesel / gas oil (i.e. 2,500 tonnes for lower tier and 25,000 tonnes for upper tier). The GHS could therefore result in operators of HFO bulk storage facilities being brought into the COMAH regime.