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Safety in design: An Australian Offshore Petroleum regulatory perspective
Jeremy Dunster GM Investigations & Strategic Services AOG Conference & Exhibition February 2013
Regulatory functions
A280510 February 2013
Compliance Monitor
and Enforce
Investigate
Improvement Promote Advise
Governance Co-operate Report
2
NOPSEMA’s coverage
• Operations – Offshore petroleum operations – Offshore greenhouse gas storage operations
• Scope – Occupational health and safety at facilities – Structural integrity of facilities and wells – Environmental management of petroleum activities
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NOPSEMA’s jurisdiction
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NOPSEMA
Relevant State/NT Minister
or NOPSEMA where powers conferred
Legislation administered by NOPSEMA
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Commonwealth Attorney-General’s website: comlaw.gov.au
Safety Regulations
Commonwealth Offshore Petroleum and Greenhouse Gas Storage Act 2006
Schedule 3 – OHS law
Wells Regulations
Environment Regulations
February 2013
Legal framework (OHS)
• A ‘General Duties’ regime
• Performance-based, but with prescriptive elements
• An independent Regulator (NOPSEMA)
• A facility operators safety case is used as a permissioning document, i.e. must be accepted in order to undertake activities.
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Safety case life-cycle
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Agree Scope of Validation
(SoV) Validation Statement
Validation
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Scope of Validation
• Overview of facility/ modification & process for Safety Critical Element (SCE) selection
• Codes & standards for each SCE
• Validator selection process
• Appropriateness of codes and standards
• Deliverables
Validation Statement
• Codes and standards are appropriate
• If codes and standards are applied the facility will incorporate measures to protect Health & Safety
• Consistency with Formal Safety Assessment Ag
reed
by
NO
PSEM
A
Safe
ty C
ase
Deci
sion
-mak
ing
Valid
atio
n
The Safety Case
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Safety Case Submission
Safety case contents
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Safety ManagementSystem Description
Formal SafetyAssessment Description
FacilityDescription
Monitor, Audit and Review
Description ofTechnical Controls
including:
Emergencies
Activities andOperating Parameters
General Description (the layout of the facility)
Machineryand Equipment
Safety Measures
HAZID
Risk Assessment
Emergencies (EERA, FERA)
Performance Standards
Description ofProcedural Controls
including:
Identification ofControl Measures
Implementation and Improvement of the SMS
Scope (Activities)
OHS Risk Management
Maintenance
Communication
Emergencies
Safety Measures
Corrective & Preventative action
Implemented& Functional?
Implemented& Functional?
Comprehensiveand Integrated
HAZID
Risk Assessment
Emergencies (EERA, FERA)
Identification ofControl Measures
Identification ofControl Measures
(Necessary to reduce thelevel of risk to ALARP)
Reasonable Practicability
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Cost to avert Risk
ALARP
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High Risk
Low Risk
Concept
Design
Construct, Install, Operate, Modify, Decommission
Early engagement
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Early Engagement
Timing
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FID
Concept Selected
Concept Evaluation
Conceptual Design
FEED
Detailed Design
Overseas Construction
Field Construct & Install
Production
Cost to change
Field activities
Window of opportunity
Future directions
• Design notification style scheme: – Focus on concept selection & design – Required for production facilities – Basis for ongoing dialog, transitioning into submission of a
safety case
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Industry leadership challenge
• Shaping and supporting an organisational culture which embraces and values inherent safety to effectively manage risk, by: – Early application; – Minimising hazards at their source; – Designing out hazards in preference to designing in
control measure complexity; – Ensuring systems fail safe when things go wrong.
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NOPSEMA OHS web resources
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Questions?
