When
- On coming into scope — and, as a rule, before operations start.
- When substances change — a quantity rising enough to affect scope, a new substance arriving, or a substance's classification changing.
- When the tier changes — moving from lower to upper tier changes the whole obligation list.
- When the operator changes — transfer, merger, change of trading name.
- On closure — closing down is notified as well.
What the notification contains
The operator's identity, the address and activity of the establishment, the nature, physical form and quantity of the dangerous substances held, and information about the surroundings. In other words the notification is the summary of the scope calculation, in a form that can be checked from outside.
Why it is the first obligation
Every other obligation hangs off it: policy, management system, scenarios, plans and inspection all follow from the establishment being known to be in scope. Where no notification exists, then even if everything else was done on time, from outside the establishment is not in scope at all.
The quiet trigger
The most frequently missed trigger is a change not in quantity but in classification. The substance in use stays the same, the supplier updates the safety data sheet, the substance falls into a different hazard class — and the establishment has changed tier without doing anything.