Safety in design:

An Australian Offshore Petroleum

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

Regulatory functions

A280510

Monitor
and
Enforce

Investigate

Promote

Advise

Improvement

Co-operate

Report

Governance

February 2013

Compliance

NOPSEMAs 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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NOPSEMAs jurisdiction
NOPSEMA

Relevant State/NT
Minister
or
NOPSEMA where
powers conferred
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Legislation administered by NOPSEMA

Commonwealth Offshore Petroleum and
Greenhouse Gas Storage Act 2006
Schedule 3 OHS law
Safety Regulations
Wells Regulations
Environment Regulations
Commonwealth Attorney-Generals website: comlaw.gov.au
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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

Agree
Scope of Validation
(SoV)

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Validation
Statement

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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

Safety Case Decision-making

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

Validation

Scope of
Validation

Agreed by NOPSEMA

Validation

The Safety Case

Safety Case
Submission

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Safety case contents

Facility
Description

Formal Safety
Assessment Description

Safety Management
System Description

Activities and
Operating Parameters

HAZID

Scope (Activities)

General Description

Comprehensive
and Integrated

(the layout of the facility)

Machinery
and Equipment

Description of
Technical Controls
including:

Description of
Procedural Controls
including:
Risk Assessment

Safety Measures
Emergencies

Emergencies (EERA, FERA)

OHS Risk Management

Maintenance
Communication
Safety Measures
Emergencies

Identification of
Control
Measures
of
Identification
(Necessary
reduce the
Measures
Control to

Performance Standards

level of risk to ALARP)

Implemented
& Functional?

Monitor, Audit and Review

Implementation and
Improvement of the SMS

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Corrective &
Preventative action

Implemented
& Functional?

10

Reasonable Practicability

Risk

Cost to avert
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ALARP
High Risk

Construct, Install,
Operate, Modify,
Decommission

Concept
Design

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Low Risk
12

Early engagement
Early
Engagement

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Timing
Window of opportunity

Concept
Selected

Concept
Evaluation
Conceptual
Design

FID

FEED
Detailed
Design

Field
activities

Overseas
Construction

Cost to change

Field Construct
& Install
Production

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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?