Taken from the CFOA regulators guidance on the RRFSO page 129 which I'm sure you'll have:
"This article (16) requires responsible persons to assess the likelihood and scale or magnitude of the effects that may result from any foreseeable accident, incident, emergency or other event involving dangerous substances present at the workplace. On the basis of this assessment, responsible persons should put in place appropriate emergency arrangements to safeguard people on their premises, mitigate the effects of any such event and restore the situation to normal.
The precautions to deal with accidents, incidents and emergencies are without prejudice to the precautions to be taken to eliminate and reduce risk as required by article 12. The possibility of such events is minimised by good plant design and layout, sound engineering and good operating practice, and proper instruction and training of personnel. However, despite these measures, accidents, incidents and emergencies can still occur and therefore appropriate procedures are required.
It is not expected that responsible persons will necessarily be able to achieve full mitigation of all foreseeable accidents, incidents and emergencies solely by their own means. Rather, it will typically be a combination of the workplace emergency arrangements and those of the emergency services that will provide overall, the safety of relevant persons. The fire service will in any case assume responsibility for tackling any fire upon their arrival, but they may also be able to assist in dealing with other non-fire emergencies such as released or spilled dangerous substances. The primary requirement for protecting relevant persons is to ensure that they are able to evacuate or be evacuated to a place of safety. The requirement to mitigate the effects of the accident, incident or emergency should have regard to this objective and to the need not to expose people to any unnecessary risks."
So in answer what I am suggesting is that from what you say the matters that would satisfy Articles 12 and 16 have been met by the application of general health and safety legislation. I don’t see the need to regurgitate all this in your FRA? I once dealt with a large 44 acre site with 22 separate buildings dealing with all manner of chemicals. To state, record and provide full details on all the substances on the site would have been a non-starter. We listed the basics and stated the control measures in place that were effectively controlled by the COMHA Regs with the Company following all the correct procedures. I think I would make more of an issue if there was evidence to suggest that the substance(s) were not being effectively managed and therefore presented a risk to relevant persons.
Long answer but hope it helped in some way??
Will
r