Reporting environmental incidents can drive continuous improvement

Article published in the Regulator | Issue 4: 2012 

The direct link between environmental performance objectives and standards, and recordable incidents has the potential to lead operators to set ‘easy’ environmental performance objectives and standards for fear of needing to report an incident and the potential negative perceptions of this. The recording, reporting and close-out of environmental incidents, however, plays an important role in the continuous improvement of environmental performance.

The setting of appropriate environmental performance objectives in an environment plan is fundamental to an operator meeting the requirements of the Offshore Petroleum and Greenhouse Gas Storage (Environment) Regulations 2009. Environmental performance objectives should be meaningful goals related to protection of the environment that are set within the context of ecologically-sustainable development. Environmental performance objectives, performance standards and their associated measurement criteria should be:

  • specific

  • measurable

  • achievable

  • relevant

  • time-bound.

There may be circumstances where an incident occurs that is a breach of an environmental performance objective or standard. Under the Environment Regulations, this constitutes a recordable incident.

Reporting and reviewing incidents represent a learning opportunity for operators and the regulator. A number of minor recordable incidents, which have been detected by fit-for-purpose performance monitoring, would demonstrate the effectiveness of an operator’s implementation strategy. It would provide opportunities for continuous improvement through investigation and implementation of corrective and preventative actions. Incident identification and appropriate follow-up also provides operators with the opportunity to take account of lessons learned in future environmental management and consider this information in ALARP evaluation and demonstration for other petroleum activities.