Process Safety and Performance Standards Jeremy Dunster – Technical Services Manager IChemE Hazards Australasia Conference Perth 26 – 27 November 2013
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)
• 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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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