Truck and Track Autumn 2025 www.truckandtrack.com 54 DANGEROUS GOODS In this issue, our dangerous goods columnist Ali Karim FRSC CChem, provides an insight into supply chain considerations for Managing Risk in the Transport, Warehousing and Handling of Chemicals & Dangerous Goods. Under the Management of Health and Safety at Work Regulations 1999, the bare minimum in terms of statutory requirement in Health and Safety Law is - Identify: what could cause injury or illness in your business (hazards) Decide: how likely it is that someone could be harmed and how seriously (the risk) Take Action: to eliminate the hazard, or if this isn’t possible, control the risk Assessing Risk is just one part of the overall process used to control risks in your workplace, and part of the process we term RAMS. What are RAMS? Risk Assessment Method Statement (RAMS) are documents that integrate the risk assessment(s) to the planned activity into a practically considered (and readily distributable) format. RAMS provides a considered (and concise) plan for carrying out the work instructions (tasks) safely by examining the hazards, associated risks, and control measures (counter measures) to be implemented. RAMS are blueprint(s) for conducting work instructions (activities) while considering the health and safety requirements. RAMS must be written (and approved) by suitably qualified/experienced professional persons. RAMS are rarely written ‘in stone’ as they need to be reviewed periodically as well as when there are changes (see later ‘change control’), and must be approved (or augmented) by suitably qualified/experienced professional persons (other than those who wrote the initial documents). The balance in writing RAMS is to ensure the document is not overly cumbersome, but readable (and understandable) by those people who will be undertaking the work activity defined in the RAMS. In previous Dangerous Goods Columns at Truck and Track, we have featured information related to the regulatory framework that people and organisations in Europe have to comply with when working within the Dangerous Goods Supply chain, including ADR/RID regulations for Road and Rail; IATA/CAA for Air and IMO/IMDG for Sea – in terms of carriage. Storage Considerations Following the Seveso chemical disaster in July 1976, in Italy, strict regulations for the storage of chemicals/dangerous goods came into effect, and are referred to as the “Seveso Directives” in Europe, and are implemented in Great Britain through the Control of Major Accident Hazards (COMAH) Regulations. These directives are in place to regulate the storage, warehousing and associated activities for those involved with Dangerous Goods. The Seveso Directives and COMAH regulations are complex instruments that interface ‘the site’, and its surroundings, linking both authorisations for the quantity, as well as the type of products permitted to be stored, thus managing the risk. They include aggregated quantity by risk class, as well as ‘named substances’ (the more problematical products). COMAH regulations are placed in “tiers” – (a) Sub-COMAH – lower risk sites Where quantities and type of products are below the thresholds outlined under the COMAH regulations, but even in this case, risk management protocols have to be deployed where specific regulations apply, such as the 1974 Health and Safety at Work Act and many others specific to the site and activity (b) Lower Tier COMAH – for medium-high risk sites (c) Higher Tier COMAH – for highest risk sites Like all effective regulations, they are reviewed and updated on a regular basis. New (updated) Control of Major Accident Hazards (COMAH) Regulations came into force in the UK on 1st June 2015. There are some important changes particularly on how dangerous substances are classified and information that has to be made available to the public, so your Dangerous Goods Safety Advisor (DGSA) will keep your operation in compliance. Both top tier (now referred to as upper tier) and lower tier operators need to provide public information electronically and keep it up to date. One (of the many) protocols of the Seveso Directive/COMAH Regulations include having accurate information about the site, and its permitted storage areas for the local authorities and emergency response organisations. As part of this protocol, RAMS and Managing Risk in the DG Supply Chain by Ali Karim Ali Karim TRUCK & TRAILER SOLUTIONS WELCOME TOALLPORTS GROUP allportsgroup.co.uk Argon Tank Cryogenic tank
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