Safety Transformation & Regulatory Compliance
Summary
Under imminent HSE pressure for COMAH Lower Tier non‑conformance, our client engaged Kingfisher in mid‑2024 to lead a comprehensive compliance turnaround. Over six months, we deployed a dedicated Consultant with COMAH competency, conducted targeted Audits and Risk Assessment Services, produced a fully compliant Major Accident Prevention Policy via our Documentation team, and provided ongoing Advice in all regulator interactions.
By December 2024, the HSE formally signed off on Lower Tier compliance – averting enforcement action, strengthening internal procedures, and embedding a sustainable Compliance framework.
The Challenges
In mid‑2024, the site came under close scrutiny from both the HSE and the COMAH Competent Authority, who flagged significant gaps in the client’s Major Accident Prevention Policy (MAPP), emergency response protocols, and recordkeeping. Without an on‑site COMAH‑competent lead or structured processes, the operator risked enforcement notices, financial penalties, and reputational damage.
The absence of defined audit trails and up‑to‑date system documentation further compounded the challenge, threatening operational continuity and eroding regulator confidence as the compliance deadline approached.
Our Approach
Kingfisher was appointed in June 2024 and immediately assigned a senior COMAH‑competent Consultant to spearhead the turnaround. We began with a deep‑dive site assessment, using our Audits and Risk Assessment Services to map every non‑conformance and safety control gap. Our Documentation specialists then drafted a fit‑for‑purpose MAPP and overhauled the client’s procedures – covering hazard identification, maintenance scheduling, and emergency response – to align precisely with Lower Tier requirements. Throughout the project, we maintained regular site visits and structured compliance‑planning meetings, supplemented by our Advice team’s strategic guidance on regulator engagement.
Kingfisher led all interactions with the HSE, presenting evidence of progress, supplying comprehensive documentation packs, and fostering transparent, solution‑focused communications. This proactive, hands‑on approach ensured that every corrective action was documented, tracked, and executed to the highest Compliance standard.
The Results
By December 2024, the HSE and COMAH Competent Authority formally endorsed the client’s Lower Tier compliance, confirming that the revised MAPP, strengthened procedures, and enhanced recordkeeping practices met all regulatory criteria. The operator avoided any enforcement notices or penalties, preserved uninterrupted operations, and restored a constructive relationship with the regulator.
Internally, staff now follow an auditable, COMAH‑aligned process for hazard management, and management teams retain full confidence in their ongoing Compliance obligations. Kingfisher’s strategic intervention not only secured immediate regulatory relief but also equipped the client with a robust, sustainable safety management framework.