Experience of the Application of Goal Setting Regulations

Trish Sentance, Health & Safety Manager Oil & Gas UK

HSWA

Safety Case Regulations

P

F

E

E

R

DCR

PSR

MAR

ACOP, Industry Guidance etc.

Company standards/guidelines/procedures etc.

3

ALARP Triangle

Negligible Risk

Intolerable

Risk Region

Broadly Tolerable

Risk Region

ALARP Region -

Tolerable Risk only if

ALARP is

demonstrated

RISK

IRPA

ALARP is:- “the point, objectively assessed, at which the time, trouble, difficulty and cost of further reduction measures become unreasonably disproportionate to the additional risk reduction obtained”

IRPA : 1 x 10 -3 /year

IRPA : 1 x 10 -6 /year

Original OGUK Decision Making Framework

4

How do you demonstrate ALARP?

■ Adherence to Codes &

Standards

■ Good Practice in Design

■ Risk-based Analysis against Criteria (not always quantitative)

■ Evaluation of Risk Reduction Options

5

ALARP Triangle

Negligible Risk

Intolerable

Risk Region

Broadly Tolerable

Risk Region

ALARP Region -

Tolerable Risk only if

ALARP is

demonstrated

RISK

IRPA

ALARP is:- “the point, objectively assessed, at which the time, trouble, difficulty and cost of further reduction measures become unreasonably disproportionate to the additional risk reduction obtained”

IRPA : 1 x 10 -3 /year

IRPA : 1 x 10 -6 /year

Updated OGUK

Thoughts

7

A Goal setting regime is not easy to regulate in or operate in it is meant to make both sides think about what needs to be done and why.

Requires knowledgeable, experienced and confident personnel

– both on the Industry side and in the regulator.

Need people who are good communicators,

– including listening skills & an ability to present an argument in a non confrontational way and not feel threatened by an alternative view

Need challenge from both sides

Need an understanding of risk and an acceptance that there will always be residual risk you cannot completely remove it

Thoughts

8

Needs a change in focus away from Occupational Safety- slips, trips and falls type safety to process safety by senior management & operations personnel

– This is a major challenge.

Prescriptive parameters will still be set Goal Setting doesn’t mean there are no limits

– Now set by the Duty Holder rather than the regulator, what is set is appropriate to your installation and your process and is based on understanding your hazards

Verification Schemes

9

From the risk assessment of the installation Safety & Environmental Critical Elements (SECEs) will be identified appropriate to the installation.

Each SECE will have a performance standard, (PS) which should describe it’s role, required functionality, any survivability requirements, and any availability requirements.

This is then supported by a written scheme of examination, (WSE) which has been developed to ensure that the standard is being delivered,

– Includes reference to maintenance requirements, testing requirements and preferably action/alarm points so that issues can be addressed not wait until the PS is no longer being met and then decide what to do about it.

Verification Schemes

10

The Verifier is involved in ensuring and checking that what the Duty Holder, (DH) has said will be done is being done and delivers what the DH said it would.

This is an ongoing & much more regular involvement.

Changes to the PS and WSE must be reviewed and agreed with the verifier.

Duty Holder & Regulator Interface

11

Every Duty Holder has a focal point inspector assigned to them.

Safety Case makes the Duty Holders case for safety

– first submission reviewed and assessed by HSE and no operation can start until it has been accepted.

Ongoing inspection programme put in place by regulator prioritised to focus on higher risk/hazard installations and poorer performers.

Following an incident will always be some follow up from focal point and may or may not include an HSE investigation or a review of the DHs investigation.

Anything reported to the anonymous reporting line will always be investigated.

Any learnings from significant developments may result in a request for DH response

Oil & Gas UK Role

12

An interface between Industry and the regulator

Oil & Gas UK facilitate communication when it is an industry issue that is to be addressed e.g the EU Directive & changes required to UK legislation.

Oil & Gas UK have various groups in place for this

– Forums

– Technical Groups, for subject matter experts, e.g major hazards management, aviation safety, assurance & verification

– Task/Finish groups to address very specific topics.

Guideline/Guidance Development

13

These are developed to allow sharing and recording of good practice

Developed by a small group of volunteer subject matter experts on behalf of the industry HSE may sit on the group or peer review it and provide comment.

Recent publications in H&S

– Cumulative Risk

– Operational Risk Assessment

– Updated the Risk Based Decision Making Guidelines

– Maintenance Optimisation - Sharing & Learning of Approaches

– Fire & Explosion Guidance is being updated

Summary

14

Goal Setting Regulations isn’t easy – it shouldn’t be!

Requires thought and understanding

A strong and well resourced regulator is essential

Regular dialogue and challenge is essential for it to be effective

Needs continuous focus and a lot of hard work

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© 2016 The UK Oil and Gas Industry Association Limited, trading as Oil & Gas UK