The following Safety Information Note is being issued to PSS members by the Ports regulator, The Health & Safety Executive. It details resources available for certain Ports who manage hazardous goods and face a foreseeable risk of stockpiling or movement slow-down in the No Deal Eu Exit scenario. Ports that will be affected include those with COMAH sites, those handling dangerous goods and those handling explosives.
The Health and Safety Executive (HSE) is working closely with other Government departments to prepare for an orderly exit if we leave the EU with No Deal. Work-related health and safety issues that could arise in the run up to, and during, this period include the stockpiling of hazardous goods (such as chemicals and explosives) and delays to the movement of these items through harbour areas.
HSE has shared information with local resilience forums to assist with their planning and have copied this information below. If you have any specific issues or requests for advice with your own planning and preparations, contacts are included below.
- The requirements of the Control of Major Accident Hazards Regulations 2015 (COMAH), the Dangerous Substances (Notification and Marking of Sites) Regulations 1990 (NAMOS), the Dangerous Goods in Harbour Areas Regulations 2016 (DGHAR) and the Explosives Regulations 2014 (ER 2014) will continue to apply before, during and after EU Exit
- At ports, a potential slowdown in the movement of goods through harbour areas, and the impact on movement of dangerous goods within this, will require effective emergency plans to be in place (as is legally required now).
- The transport of dangerous substances and directly related intermediate temporary storage is exempted from the scope of COMAH. Such activities are in scope of other specific regulatory regimes such as Carriage of Dangerous Goods (CDG) and general health and safety requirements under the Health and Safety at Work etc. Act 1974 (HSWA).
- In the event of a slowdown in the movement of goods through harbour areas and the surrounding areas, consideration should be given to the recommendations for the separation or segregation of different classes of dangerous substances found in Table 2 of HSG71 Chemical Warehouses – the storage of packaged dangerous substances – in considering how to mitigate any increase in risk.
- Storage of dangerous substances requires Hazardous Substances Consent (HSC). Operators should speak to their local Hazardous Substances Authority if they require new or amended consent. HSE is not responsible for HSC.
If you wish to discuss any of these areas further as part of preparatory work, or in response to specific issues, please contact:
- For general HSE enquiries -
- For COMAH specific enquiries –
- For explosives or DGHAR licensing requirements -