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Safety Case Approach

There is a public expectation that risks from major industrial activities, such as offshore petroleum operations, will be regulated and controlled. The safety regulator provides 'independent' assurance to society, governments, and industry that companies have identified the risks to health and safety and have put appropriate measures in place to control these risks. This 'control' can be exercised in a variety of ways, from a 'licence to operate' regime at one end of the spectrum to 'safety case regime' at the other.

Up until the early 1990s, the offshore petroleum industry in Australia was regulated by a mixture of State and Commonwealth legislation. This legislation prescribed specific laws that had to be complied with. In practice, it was the regulator that identified what was safe or not for the industry. Rapid changes in technology and operations meant that legislation and regulation were constantly 'catching up'.

However, in the years following the 1988 Piper Alpha disaster in the North Sea, Australia carefully considered what lessons it could draw from this disaster. Piper Alpha resulted in 167 deaths and substantial financial losses to the UK industry and Government. It was decided that Australia should introduce the safety case approach, which is underpinned by the objective based Offshore Petroleum (Safety) Regulations 2009 (OPS).

Objective based (or goal setting) regimes, including the safety case regime, are based on the principle that the legislation sets the broad safety goals to be attained and the operator of the facility develops the most appropriate methods of achieving those goals. A basic tenet is the premise that the ongoing management of safety is the responsibility of the operator and not the regulator.

The Offshore Petroleum (Safety) Regulations 2009 (OPS) regulations set out the requirements for the contents of safety cases. A safety case for a facility must comply with OPS.

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What is a safety case?

A safety case is a document produced by the operator of a facility which:

  • Identifies the hazards and risks
  • Describes how the risks are controlled, and
  • Describes the safety management system in place to ensure the controls are effectively and consistently applied.  
Safety cases must be produced by the operator of a facility.
  • The principle here is that those who create the risk must manage it. It is the operators' job to assess their processes, procedures and systems to identify and evaluate risks and implement the appropriate controls, because the operator has the greatest in-depth knowledge of their installation.  
The safety case must identify the safety critical aspects of the facility, both technical and managerial.
  • Analysis of disasters almost always show a combination of technical and managerial flaws which have led to the event occurring. 
Appropriate performance standards must be defined for the operation of the safety critical aspects.
  • A 'performance standard' is a standard, established by the operator, of the performance required of a system, item of equipment, person or procedure which is used as a basis for managing the risk of a major accident event. 
The workforce must be involved.
  • Workforce involvement is necessary so they know what happens in practice and why. This makes it more likely that they do the right thing because they know why, rather than relying on a 'rules-based' culture. 
The safety case is produced in the knowledge that it will be scrutinised by a competent and independent regulator.
  • NOPSA assesses safety cases and 'accepts' a safety case if it is satisfied that the arrangements set out in the document demonstrate that the risks will be reduced to as low as is reasonably practicable. Once 'accepted' NOPSA visits facilities to monitor the application of the safety cases in practice.

Questions and Answers

NOPSA has prepared a series of questions and answers to assist in explaining the role of the safety case, the requirement for compliance with the safety case and how the safety case can be used to improve safety at facilities.

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Safety Case Guidance

NOPSA safety case guidance notes are currently being developed and are in varying stages of completion. The safety case guidance note project lists the individual document status and provides copies of discussion documents for consultation.

Pending final issue of approved guidance notes, NOPSA provides the following documents about safety cases on this website:-

Further Guidance

Assessment Policy

NOPSA's approach to assessment is set out in a general policy on assessment and a supplementary policy on Safety Case Assessment.

Assessment Submissions

A submission cover sheet is provided which allows operators to identify the purpose of the submission and check it for completeness. Additional guidance on content requirements can be found here.

For the submission of documents for formal assessment please use the following email address:

submissions [at] nopsa.gov.au