Developing appropriate environmental performance standards
Article published in the Regulator | Issue 4: 2013
When preparing an environment plan (EP) for submission, operators often ask NOPSEMA for guidance about what constitutes an ‘appropriate’ environmental performance standard.
An environmental performance standard is a specified level of performance required of a control, such as a system, piece of equipment, person or procedure, used to manage the environmental features of an offshore petroleum activity. Under Regulation 13(4) of the Offshore Petroleum and Greenhouse Gas (Environment) Regulations 2009, an EP must include standards that address controls. Regulation 11(1) requires NOPSEMA to assess the appropriateness of the standard when deciding whether to accept an EP.
Questions that may assist operators in determining whether their standards may be considered appropriate to meet the acceptance criteria for an EP include:
Does the control actually address the risks and impacts it is intended to manage?
Is there a clearly stated level of performance for the control to manage the risks and impacts captured in the standard?
Are there standards that relate to each control which have been identified as necessary to reduce impacts and risks to as low as reasonably practicable and acceptable levels?
Are the standards measurable and auditable?
Operators should be aware of common shortcomings in seeking to set appropriate standards. For example, the prospects of meeting acceptance criteria are limited where weak or no links are drawn between the standard, the environmental features of the activity, the risks and impacts that need to be managed, and the controls proposed for managing those risks and impacts. These factors are used to determine ‘appropriateness’ of the standards for the activity and the EP.
For further information see GN1344 - Environment plan content requirements - Rev 3 - April 2016 (PDF 1.1MB).