NOPSEMA Regulatory Advice EP Guidance Note€“ Risk assessment processes – Performance...
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Transcript of NOPSEMA Regulatory Advice EP Guidance Note€“ Risk assessment processes – Performance...
EP Guidance Note Project: Objectives
• Develop useful, understandable and practical guidance
• Provide clear descriptions of NOPSEMA’s interpretation of regulatory requirements for environment plan (EP) content (administrative processes dealt with separately)
• Consistent with OPGGS(E) Regulations, with a reasonable and justifiable basis
• Consistent with objective-based regime
– Focus on ‘what needs to be demonstrated’ not ‘how to demonstrate’
• Avoid regulatory “creep” – expansion of requirements beyond Regulations
EP Guidance Note Project: Scope and Priorities• Key topic areas noted from Perth workshop
(March 2012):– Line-of-sight to Regulations– ALARP– Consultation– Risk assessment processes– Performance Objectives, Standards and Measurement
Criteria
EP Guidance Note Project: Development
• Following EP Guidance workshop, NOPSEMA reviewed:– Objectives of guidance note project– Feedback from operators workshop– Guidance note structure and alignment with Regulations– Review of relevant standards
• Outcomes:– Restructure guidance notes to emphasise process and
content requirements of Regulations– Maintain focus on risk management, ALARP, Performance
Objectives, Standards, Consultation, etc.
Approach:
• EP Guidance Notes - adopt a system-based model as basis
• Structured on process elements
• All priority issues/topics raised will be covered
Process Model Evolution
System-based interpretation of Regulations
AS/NZS ISO 31000
EP Advice Structure
OPGGS ActOPGGS Act
OPGGS (Environment) OPGGS (Environment) RegulationsRegulations
PolicyPolicy
Guidelines Guidelines and Guidance and Guidance
NotesNotesOtherOtherAdviceAdvice
Environmental Management Law
Advice
EP Advice: Forward Plan1. EP Guidance Note: Overview
– In preparation (this presentation)
2. EP Guidance Notes: Detailed processes and elements
– Prioritised development of a range of guidance documents providing detailed explanation of individual Regulation processes and elements
– Due for publication as soon available (up to 6 months for full series)
3. Other Advice:– Specific technical notes on priority topics e.g. ALARP,
OSCP, OSMP
EP Regulation basis:• ESD-based• Performance-based• Risk-based• Objective-based (not Prescription or Self-regulation)• System-based, and consistent with recognised
standards and systems (e.g. ISO AS/NZS)
Reg 3: Object of RegulationsThe object of these Regulations is to ensure that any petroleum activity or greenhouse gas storage activity carried out in an offshore area is:a) carried out in a manner consistent with the principles of ecologically sustainable development; andb) carried out in accordance with an environmental plan that has:
i. appropriate environmental performance objectives and standards; andii. measurement criteria for determining whether the objectives and standards have been met.
“The main objectives are to ensure that offshore petroleum exploration and development operations are performed in a way that is consistent with the principles of ecologically sustainable development, reduces environmental risks and effects to as low as reasonably practicable and is acceptable.“
Petroleum (Submerged Lands) (Management of Environment) Regulations 1999 No. 228 EXPLANATORY STATEMENT
EP Guidance Note: OverviewCore Objectives & Concepts
EP Regulation: System-basis• Explanatory Statements are clear, e.g. Select Legislative
Instrument 2005 No. 318 P(SL)A 1967 P(SL)(Management of Environment) Amendment Regulations 2005 (No. 1):– “ensure consistency with the Australian Standard for
environmental management systems (AS/NZS ISO 14001)”
Environmental Environmental PolicyPolicy
PlanningPlanningImplementation Implementation and operationand operation
CheckingChecking
Management Management reviewreview
Continual Continual improvementimprovement
AS/NZS ISO 14001
EP Regulation: Key principles• NOPSEMA must accept the environment plan if there are reasonable
grounds for believing that the environment plan meets the criteria outlined in Regulation 11(1), i.e.:– The Operator provides a reasonable basis for statements made in regard to
the requirements, to clearly outline the evidence for how the requirements have been met and to document this in the EP.
• The environment plan should be appropriate to the nature and scale of the activity:– All aspects of the environment plan should be appropriate to the nature and
scale of the activity or proposed use and are relative to the size, complexity and environmental impact and risk level of an activity
– Applies to overall EP and also to its components e.g. for a particular activity, those events with a high potential environmental impact and risk level should receive more attention in an environment plan than those with a low environmental impact and risk level
EP Regulation: Acceptance and Compliance
• Planning Phase: Acceptance of the activity’s EP takes place and has two parts:– Activity Acceptance (“Snapshot”): the EP must demonstrate that it meets the
requirements of the Regulations and how the activity’s environmental impacts and risks are assessed and managed. This demonstration is submitted for acceptance prior to the activity commencing
– Strategy Acceptance (“Ongoing”): the EP must demonstrate that there is a specific ongoing system in place to ensure the activity will be in compliance when it is conducted - the Implementation Strategy, which is a systematic approach that demonstrates EP objectives and Regulations will be met when the activity is conducted
• Operations Phase: Monitoring of compliance takes place for the activity. Compliance includes: reporting by the operator to the Regulator; submission of proposed revisions, monitoring by the Regulator; and enforcement by the Regulator.
DESCRIBE 13(1)(2)
DETAIL 13(3a)
PERFORM 11(1d) 13(4)MONITOR 11 (1e)
DEMONSTRATE 11(1b,c)EVALUATE 13 (3b)
CONSULT 11 (1f)
PROCESS
ENVIRONMENT PLAN PROCESS
ALARPACCEPTABLE
IMPACTS AND RISKS
ACTIVITYENVIRONMENTREQUIREMENTS
OBJECTIVESSTANDARDS
IMPACTS AND RISKS
REPORTING
ELEMENT (REGS)
>MEASUREMENT CRITERIA
CONSULTATION
> CONTROLS
ACCEPTABLE LEVEL CRITERIA
GOALSELEMENT (INTERPRETED)
IMPLEMENTATION STRATEGYPLAN TO IMPLEMENT
AS/NZS ISO 31000:2009
DESCRIBE
DETAIL
EVALUATE & DEMONSTRATE
EVALUATE & DEMONSTRATE
CONSULT PERFORM MONITOR
DETAIL
EP Process
EP Process
Mon
itorin
g an
dre
view
Com
mun
icat
ion
and
cons
ulta
tion
Risk identification and analysis
Risk evaluation and treatment
Establishing the context
Environment Plan Content
Mon
itorin
g an
drev
iew
Com
mun
icat
ion
and c
onsu
ltatio
n
Risk identification & analysis
Risk evaluation and treatment
Establishing the context
Activity assessment
Environmental Environmental PolicyPolicy
PlanningPlanning
Implementation Implementation and operationand operation
CheckingChecking
Management Management reviewreview
Continual Continual improvementimprovement
Strategy (Plan for implementation)
AS/NZS ISO 14001
From Planning to Operational phase
Environment Plan Implementation
Planning Phase Operational Phase
Acceptance Monitor & Enforce Compliance
PROCESS ELEMENT
Development of EP Core Concepts & Guidance
ACTIVITYDESCRIBE
OBJECTIVE:Provide information important to the context of the EP by identifying all the activities at an appropriate level and particularly those activities relevant to impacts and risks.CORE CONCEPTS• The operator must determine if an activity meets the definition of an activity in the Regulation and therefore if an EP is required.• An activity is a petroleum activity as defined in the Regulations and includes the proposed activity and any stages of that activity.• The EP’s description of the activity should be appropriate for the nature and scale of the activity.• The description of the activity provides general and outline details of “where, what, how and when” for an activity and additional
information relevant to impacts and risks.• A comprehensive description of activity allows a description of the affected environment and for impacts and risks to be detailed
and evaluated.
CONSIDERATIONS• The description of the activity is a general section at the beginning of an EP that helps to set the context and allows impact and risk
identification and evaluation. • Only activities that are described in the EP are assessed and accepted.• If an activity, or component of an activity, that is relevant to impacts and risks is not described in an EP, then it is not part of the EP
acceptance.• The activity description could be further detailed as sub-activities or aspects which are the basis for impact and risk identification
and evaluation.
EXAMPLE:
REGULATION4(1) (definition of activity); 5 (activity and any stage of an activity); 6 (must have EP in force);11(1)(a) is appropriate for the nature and scale of the activity or proposed use13(1) (a-d) The environment plan must contain a comprehensive description of the
activity including the following …GUIDANCE:
Implementation strategy basis• Implementation Strategy is system level
– System requirements 14(1-3)– Prescribed requirements 14(4-9)
• Specific system applied to specific activity:– to ensure environmental performance objectives and
standards in the EP are met– impacts and risks are continuously reduced to ALARP
• Not necessarily expected for each individual impact and risk control
• Additional EP component for operational implementation – not an activity assessment