Process Safety and Performance Standards

Jeremy Dunster – Technical Services Manager IChemE Hazards Australasia Conference Perth 26 – 27 November 2013

• Introduction

• Safety Cases and Process Safety

• Performance Standards

• Inspection findings

• Lessons for industry

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Agenda

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Background and history

National Offshore Petroleum Safety Authority (NOPSA) established (Jan 2005) Triennial review of NOPSA operational effectiveness (Mar 2008) Productivity Commission review of upstream sector regulatory burden (Apr 2009) Offshore Petroleum Safety Regulation Inquiry and report (Jun 2009) Montara Commission of Inquiry and report (Jun 2010)

Regulation of well integrity commenced (Apr 2011) Australian Government response to Montara Commission of Inquiry (May 2011) Second triennial review of NOPSA operational effectiveness (Nov 2011)

National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA) established (Jan 2012)

Strategic Assessment under the EPBC Act

2010

2012

2013

2014

2011

2009

2008

2005

Vision A safe and environmentally responsible

Australian offshore petroleum and greenhouse gas storage industries.

Mission

To independently and professionally regulate offshore safety, well integrity and

environmental management.

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Vision and Mission

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Regulatory functions

Compliance Monitor

and Enforce

Investigate

Improvement Promote Advise

Governance Co-operate Report

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Jurisdiction

NOPSEMA

Relevant State/NT Minister

or NOPSEMA where

functions conferred

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Legislation administered by NOPSEMA

Commonwealth Attorney-General’s website: comlaw.gov.au

Commonwealth Offshore Petroleum and Greenhouse Gas Storage Act 2006

Schedule 3 – OHS

Safety Regulations

Commonwealth Offshore Petroleum and Greenhouse

Gas Storage (Safety) Regulations 2009

Wells Regulations

Part 5 of the Commonwealth Offshore

Petroleum and Greenhouse Gas Storage (Resources

Management and Administration) Regulations

2011

Environment Regulations

Commonwealth Offshore Petroleum and Greenhouse Gas Storage (Environment)

Regulations 2009

• A ‘general duties’ regime • Performance-based, but with prescriptive

elements • An independent regulator (NOPSEMA) • A facility operator’s safety case is used as a

‘permissioning document’ – must be accepted by NOPSEMA before

commencing activities.

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Legal framework (OHS)

• Assessment – permission to operate

• Inspection – monitor compliance

• Investigation – identify non-compliance

• Enforcement – expedite return to compliance

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Regulatory approach

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Safety Case Facility

DescriptionFormal Safety

Assessment DescriptionSafety ManagementSystem Description

Monitor, Audit and Review

Description ofTechnical Controls

including:

Emergencies

Activities andOperating Parameters

General Description (the layout of the facility)

Machineryand Equipment

Safety Measures

HAZID

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

Risk Assessment

EmergenciesEERA & FERA

• An event connected with a facility, including a natural event, having the potential to cause multiple fatalities of persons at or near the facility.

Source: OPGGS(S) Regulation 1

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Major accident events

• In the Australian Offshore Petroleum legislation a Performance Standard means a standard, established by the operator, of the performance required of a system, item of equipment, person or procedure which is used as a basis for managing the risk of a major accident event

Source: OPGGS(S) Regulation 1

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Performance standards

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Major accident event focus Facility

DescriptionFormal Safety

Assessment DescriptionSafety ManagementSystem Description

Monitor, Audit and Review

Description ofTechnical Controls

including:

Emergencies

Activities andOperating Parameters

General Description (the layout of the facility)

Machineryand Equipment

Safety Measures

Performance Standards(specify the performance

standards that apply)

Description ofProcedural Controls

including:

Identification ofControl Measures

(Necessary to reduce the level of risk to ALARP)

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 (Identifies all hazards having

the potential to cause a MAE)

Risk Assessment (Likelihood and consequence

of each potential MAE)

Emergencies(Evacuation, Escape and

Rescue AnalysisFire and Explosion Analysis)

Performance Standards(specify the performance

standards that apply)

Identification ofControl Measures

(Necessary to reduce the level of risk to ALARP)

HAZID (Identifies all hazards having

the potential to cause a MAE)

Risk Assessment (Likelihood and consequence

of each potential MAE)

Emergencies(Evacuation, Escape and

Rescue AnalysisFire and Explosion Analysis)

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The interface

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Performance standards lifecycle

• Are the control measures implemented?

• Are the control measures functional?

• Are the control measures maintained?

• Are the control measures audited?

• Is the workforce competent?

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NOPSEMA OHS inspections

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Findings – poor definitions

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Findings – missing linkage

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Findings – poor testing

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Findings – failure to follow-up

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Findings – poor change management

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Findings – lacking personnel knowledge

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Preventing MAEs

© PTTEP

© US Coastguard

http://gcaptain.com 9 October 2012

• Visibility of MAE Controls

• Well defined, SMART Performance Standards

• Facility Personnel knowledge and understanding

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Lessons for Industry

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Resources

nopsema.gov.au

Thank you