Safety in design: An Australian Offshore Petroleum regulatory perspective

Jeremy Dunster GM Investigations & Strategic Services AOG Conference & Exhibition February 2013

Regulatory functions

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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?