Reading Family Church planning application approved again contrary to HSE advice

The Health and Safety Executive (HSE), Reading Family Church and Whitley councillor Emmett McKenna addressed the Reading Borough Council (RBC) planning committee on 5 December. The church has applied for a change of use of 448a Basingstoke Road so they can use it as a meeting space and community facility.

HSE advised against approving the application because of the hazard of the five liquefied petroleum gas (LPG) tanks on the adjacent Procter & Gamble site. LPG is used in the Gillette factory as part of the manufacture of aerosol products. Despite this advice, the RBC planning committee had approved the application in September.

HSE indicated that they would ask the Secretary of State for Housing, Communities and Local Government to call in the decision for review if RBC persisted in their approval of the application. Therefore, it was brought back to the committee with a recommendation from RBC planning officers for refusal.

The Gillette factory is a COMAH (control of major accident hazard) zone, and the site the church wants to use is in the centre of the zone most impacted by any disaster.

The HSE website states:

Although the substances used or stored at COMAH establishments can be dangerous, the establishments are strictly regulated under the COMAH Regulations 2015 and have to manage their activities in a way which reduce risks to workers and the public. Operators must take all measures necessary to prevent major accidents and to limit their consequences for people and the environment. This is achieved through appropriate plant design, process control, mitigation measures and emergency procedures.

COMAH sites are classified as lower or upper tier depending on the quantities of dangerous substances that they hold; Gillette is a lower tier site.

HSE representatives came from Liverpool for the five minutes they were allowed to speak and explain their advice. They cited the accident at Buncefield, Hemel Hempstead in 2005 as an example of what could happen when things go wrong. The type of accident associated with LPG tanks was a BLEVE (boiling liquid expanding vapor explosion).

Councillors on the planning committee asked HSE why the change of use represented a greater risk than use as offices which were built in the 1980s. HSE explained that new regulations had come into force after the premises were built, but also that they anticipated people attending the church and community facilities would be more vulnerable and less able to cope with an evacuation than employees of a business. Based on this risk assessment, they advised against the application.

The agent for the applicant and pastor from the church spoke in support of the application, as did Councillor Emmett McKenna. He explained to committee members that as a chemical engineer he understood the risks of the COMAH site in his ward. He said that the risk of an incident could be modelled and for one tank it was 10 incidents in a million years and for five tanks it was one in 20,000 years, adding that he wanted to

… provide some reassurance to residents currently there that although there’s a risk it is vanishingly small, it’s an incredibly well maintained site, it’s well inspected by the HSE who do a very valuable job as well. I don’t diminish it; it’s a safe site.

[at 1:43:30]

Councillor Page said that he thought the committee should stick with their original decision. He said:

The view that somehow one [planning] category is more vulnerable is one that I find hard to accept. There’s an assumption that employees are going to be better drilled in escape procedures, that is something that I would have thought would have been a condition that the HSE would have pressed [for] in the grant of any consent.

[at 1:50:10]

Councillor Ed Hopper had not been at the September planning committee and he said that he could not vote in favour of the application. “I cannot get past the possibility of a major explosion,” he said [at 1:56:55].

Ultima Properties Ltd, current owners of the the freehold of the property, obtained Queen’s Counsel (QC) advice which was available at the meeting. The advice countered HSE’s suggestion that committee members had not:

… fully understood the seriousness of HSE’s advice given the nature of the proposed development and the risks from a major accident at the neighbouring Gillette UK Ltd site.

…and that RBC was entitled to grant planning permission.

The planning committee approved the change of use by a majority of 8 to 3 votes. The item took up about an hour, almost half of the meeting.

  1. Planning application 180698
  2. Procter & Gamble
  3. COMAH page – HSE
  4. COMAH 2015 public information – HSE
  5. Buncefield report
  6. Planning applications committee 5 September 2018 papers & webcast
  7. Planning applications committee 5 December 2018 papers & webcast
  8. Reading Family Church application on Basingtoke Road brought back to planning committee