Safety cases and validation
A facility cannot be constructed, installed, operated, modified or decommissioned without a safety case in force for that stage in the life of the facility.
The operator of a facility must submit the safety case to NOPSEMA with either a NOPSEMA pro-forma cover sheet or a covering letter stating that it is being submitted for assessment. Since it is the operator that must submit the safety case, registration of the operator must be completed (and a scope of validation for a proposed facility agreed) prior to safety case submission.
The Offshore Petroleum and Greenhouse Gas Storage (Safety), OPGGS(S) Regulations 2009 set out the requirements for the contents of safety cases. These Regulations state that NOPSEMA may, by notice in writing, require the operator of a proposed facility or an existing facility, to provide a validation in respect of the proposed facility or in respect of a proposed significant change to an existing facility.
The first stage in the life cycle of a safety case is to register an operator for a facility or proposed facility (see Operator Nomination and Registration page).
NOPSEMA must agree with the operator on the scope of validation for a proposed facility before a new safety case may be submitted. A revised safety case, depending on the nature of the revision, may also require validation (and therefore the agreement of NOPSEMA on the scope of validation) prior to submission of the revised safety case.
There are several different triggers for safety case revisions, including NOPSEMA request, the expiry of five years and changed circumstances. Construction, installation, operation and decommissioning activities may all be covered by revisions to existing safety cases.
See safety case lifecycle diagram below.
For further information on safety cases and the safety case approach, see FAQ page.
The operator of a facility must submit the safety case to NOPSEMA with either a NOPSEMA ‘Safety case submission cover sheet’ form or a covering letter stating that it is being submitted for assessment.
The OPGGS(s) Regulations 2009 set out the requirements for the contents of safety cases. For further information on required safety case content, see Safety case content and level of detail guidance note.
In general, the regulations impose safety case assessment time frames on NOPSEMA:
- NOPSEMA has 90 days in which provide notification to the operator on acceptance or rejection of a new safety case, or that NOPSEMA is unable to make a decision (and set out a proposed timetable for its consideration of the safety case
- NOSPEMA has 30 days to provide similar notification in relation to a revised safety case.
During the assessment period, NOPSEMA may formally request further written information in relation to any safety case submitted. See the submitting regulatory documents page.
Where validation has been requested, adequate validation forms part of the safety case acceptance criteria and therefore validation will need to be completed and received by NOPSEMA before the end of the assessment period in order for NOPSEMA to accept the safety case.
The OPGGS(S) Regulations state that NOPSEMA may, by notice in writing, require the operator of a proposed facility or an existing facility, to provide a validation in respect of the proposed facility or in respect of a proposed significant change (for example, modification or decommissioning) to an existing facility.
To achieve this, a scope of validation must be agreed with NOPSEMA. The operator of the facility should submit their scope of validation document to NOPSEMA with a NOPSEMA ‘scope of validation cover sheet’ form. See Making submission to NOPSEMA page.
Once a validation is requested by NOPSEMA, an operator may not submit the safety case for a facility before the operator and NOPSEMA have agreed on the scope of validation for the proposed facility or proposed significant change to an existing facility.
Once the scope of validation has been agreed with NOPSEMA, adequate validation will need to be completed and received by NOPSEMA before the associated safety case (or safety case revision) can be accepted.