Demonstrating that risks are ALARP; a key element for safety case acceptance
Article published in the Regulator issue 4:2015
Recently, a number of safety case submissions have failed to demonstrate that the risks to the health and safety of persons at or near the facility have been reduced to a level that is as low as reasonably practicable (ALARP). This failure has resulted in requests for further information and in some cases rejection of the operator’s safety case.
More specifically, operators have failed to demonstrate that risks have been reduced to a level that is ALARP in two ways:
1. Not providing an appropriately detailed description of their formal safety assessment that provides evidence that fundamental technical and other control measures (whether implemented or otherwise) have been identified. For example, NOPSEMA recently rejected a safety case revision in which the operator failed to identify and consider a viable control measure that would significantly reduce risk. In this instance, the operator proposed to repair a pipeline by isolating the section of pipeline using a single isolation device and numerous procedural controls. The operator failed to consider other risk reduction controls, such as replacing the hydrocarbons within the pipeline with water and reducing the pressure to ambient.
2. Not providing an appropriately detailed description of the formal safety assessment that provides evidence as to how the reasonable practicability of risk control measures is evaluated. For example, NOPSEMA recently requested further written information when an operator did not provide sufficient information to support the rejection of a specific control measure associated with construction-related heavy lifting activities, stating only: “…temporary shutdown of the wells during lifting activities, with potential to impact the well bay area has been evaluated and it is concluded that the safety benefits achieved is grossly disproportionate to the cost and practicality (e.g. multiple shutdowns) of implementation.”
In this instance, the operator did not provide sufficient supporting evidence to demonstrate that the gain in risk reduction was grossly disproportionate to the cost, time and resources associated with the controls implementation. This led to a request for further information by NOPSEMA.
It should be noted that in both examples the subject control measures were targeting removing a hazard at source, which is arguably the simplest and most effective means to reduce risk.
To avoid rejection or assessment delay, operators need to ensure their safety case submissions contain an appropriately detailed description of the formal safety assessment that adequately demonstrates how risks have been reduced to a level that is ALARP. Operators should consider a number of factors when identifying control measures necessary to reduce risks to ALARP, these may include:
• control measure hierarchy
• types of control – technical or other
• common mode failures between controls
• layers of protection
• operating circumstances
• focus of control
• effectiveness. For further information, see NOPSEMA’s ‘ALARP’ guidance note on the Safety Case Guidance Notes page at nopsema.gov.au.
Hammelmann Australia Pty Ltd convicted and fined
On 14 December 2015, Hammelmann Australia Pty Ltd was convicted and fined $20,000 in the Magistrates’ Court of Western Australia, for breaching their duty to comply with the duties of care owed by manufacturers of equipment under clause 12 of Schedule 3 of the Offshore Petroleum and Greenhouse Gas Storage Act 2006 (OPGGS Act). The prosecution relates to an accident that occurred in March 2011 at a facility, where a diver was seriously injured whilst using an underwater high pressure spray gun manufactured by Hammelmann.
For more information see NOPSEMA’s ‘Hammelmann Australia Pty Ltd - convicted and fined’ announcement on the News and Media page at nopsema.gov.au.