COMAH 2015

COMAH 2015: personnel accountability explained

Updated 2026

COMAH 2015 (the Control of Major Accident Hazards Regulations) requires operators of upper- and lower-tier establishments to have emergency plans and a major-accident prevention policy. In practice this means being able to account for everyone on site quickly and accurately during an incident. A live, timestamped muster record — such as the one The Salvus Network produces automatically — is the clearest way to evidence this.

~1,0001
COMAH establishments in Great Britain
2 tiers2
lower and upper tier, set by dangerous-substance thresholds
Reg 73
requires adequate emergency plans
  1. 1. HSE, COMAH statistics
  2. 2. COMAH 2015, Schedule 1
  3. 3. COMAH 2015

What COMAH 2015 actually requires

COMAH 2015 implements the EU Seveso III Directive in Great Britain. It applies to establishments holding dangerous substances above defined thresholds and classifies them as lower or upper tier.

Regulation 5 requires a major-accident prevention policy (MAPP). Regulation 7 requires operators to prepare adequate internal emergency plans. Both depend on knowing, at any moment, who is on site and where — because you cannot evacuate or account for people you cannot see.

Why manual roll-call falls short

The traditional approach — assembly points and a paper register or wardens with clipboards — is slow, error-prone and hard to audit. During a real incident, people take unexpected routes, help colleagues, or are simply missed.

Regulators increasingly expect operators to demonstrate their accountability process works, not just that a plan exists on paper. A head count that takes fifteen minutes and cannot be reconstructed afterwards is a weakness.

How real-time accountability evidences compliance

Anchors placed across your site read every worker's Tag at gates, muster points and zone thresholds. The moment an alarm sounds, the system produces a live head count and a timestamped record of who is accounted for, who is still inside, and where they were last seen.

That record is auditable after the event — it shows exactly when each person reached safety. For a COMAH emergency plan, this turns accountability from a hopeful process into demonstrable evidence.

The Salvus Safety Desk

HSE research & compliance team

The Salvus Safety Desk is our in-house health, safety and compliance team, drawing on frontline experience across COMAH, DSEAR and CDM sites to translate regulation into practical, real-time controls.

Frequently asked questions

Does COMAH require an electronic mustering system?+

COMAH does not mandate a specific technology, but it requires adequate emergency plans and the ability to account for people. An electronic, timestamped muster record is the most robust way to evidence that your process works.

What is the difference between lower and upper tier?+

Tier is determined by the quantity of dangerous substances held, set against thresholds in Schedule 1 of COMAH 2015. Upper-tier sites have additional duties including a safety report.

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