Management of occupational health

The OHS regulatory regime for offshore petroleum and greenhouse gas storage facilities is a general duties regime using a safety case approach. It is generally a performance-based regime but includes some prescriptive elements.

The key general duty that is set out in the principal legislative instrument [the Commonwealth Offshore Petroleum and Greenhouse Gas Storage Act 2006] falls on the operators of facilities and requires that they take all reasonably practicable steps to ensure that the facility is safe and without risk to the health of any person at or near a facility and that all activities are carried out safely and without risk to health. In addition, there are particular matters the operators must address as set out in the subordinate legislation which includes the following regulations: Offshore Petroleum and Greenhouse Gas Storage (Safety) Regulations 2009 [OPGGS(S)]

  • The OPGGS(S) Regulations include specific provisions regarding exposure to hazardous substances, fatigue management and exposure to noise

  • The legislation does not generally specify OHS rules

  • The safety case is one mechanism by which operators can fulfill their general duties

  • The safety case includes the facility-specific commitments by the operators regarding the arrangements that ensure proper control of risk at the facility

  • It is for the operator to decide, in the context of their general OHS duty of care, on appropriate and practicable risk control measures.

NOPSEMA will be mindful of relevant standards on such topic areas (if available) when assessing the specific standards commitments made by the operator in their safety case. The OPGGS(S) Regulations require the safety case to list the Australian and international standards that are applied at the facility. The operator of a facility must decide which standards are to be applied.

Operator's duty to monitor health and safety of workforce

Operators have a duty to monitor the health and safety of all members of the workforce and to keep records of such monitoring. (Clause 9(2)(g) of Schedule 3 to the Offshore Petroleum and Greenhouse Gas Storage Act 2006). This duty only applies to operators, but requires that operators manage health and safety monitoring programs for all members of the workforce - not just their own employees.

Examples of monitoring and reporting include exposure assessments relating to noise, hazardous substances and heat stress. Monitoring data is a type of health surveillance record, because it documents assessed health and safety risks to members of the workforce.

Health surveillance records should:

  • identify workers or work-groups who are exposed to health hazards at work

  • assess their risk of suffering an adverse health effect from exposure to these hazards

  • evaluate their health to detect early signs and symptoms of adverse health effects

  • verify the effectiveness of workplace controls.

Examples of health surveillance records include:

  • audiograms

  • biological monitoring results

  • exposure monitoring results,

  • functional test results (e.g. lung function testing)

  • demographic data

  • occupational history,

  • medical history

  • whether Personal Protective Equipment is selected, used and maintained correctly at work

  • exposures to contra-indicating substances like ototoxins.

Health surveillance should be provided by competent practitioners including audiologists, audiometrists, and occupational physicians, as applicable.

Operators are responsible for ensuring that health surveillance practitioners are competent.