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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 Petroleum (Submerged Lands) (Management of Safety on Offshore Facilities) Regulations 1996 (MoSOF).

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 Petroleum (Submerged Lands) (Management of Safety on Offshore Facilities) Regulations 1996 (MoSOF) regulations set out the requirements for the contents of safety cases. A safety case for a facility must comply with MoSOF.

Directions Revoked and now Addressed by the Safety Case

When the previous, prescriptive system of regulation was replaced by the present process of assessing safety cases, several matters that were the subject of specific regulations were revoked, and not included in the new regulations. These matters are the safety related items identified in the Schedule of Specific Requirements , and are no longer required by the Designated Authorities which previously administered them.

[Note: Legislation to revoke these requirements is expected to be introduced in Western Australia shortly.]

NOPSA's regulatory responsibilities do not include the matters identified in the Schedule of Specific Requirements , however where operators were previously required to comply with a criterion or standard defined in a regulation or obtain a certificate or licence, these requirements are no longer in force but are expected to be addressed by the operator in the safety cases they submit. The operator is now required to identify its responsibilities under the law and develop adequate systems and standards for satisfying those responsibilities.

Changes to Certification of Crane Drivers
One of the matters affected by the changes to the Schedule of Specific Requirements is the certification of crane drivers, for which an explanatory note has been provided.

Crane Driving - National Unit of Competency
The national training package PMA08 now contains a unit PMASUP305A 'Operate Offshore Cranes'. The PMA08 Package was formally signed-off on 27 May 2008. It is expected that the Unit will appear shortly on the NTIS data base.

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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 Guidelines

NOPSA has withdrawn the 2004 Safety Case Guidelines. The 2004 Guidelines included a set of principles associated with developing and assessing safety cases. NOPSA's assessment process was aligned with this "principles" approach. NOPSA believe it is significantly simpler to only assess safety cases against the requirements stated in the regulations; and our safety case assessment process has been revised accordingly. As a result of these changes the "principles" approach used in the Guidelines is no longer aligned with NOPSA's preferred assessment approach.

NOPSA provides the following documents about Safety Cases on this website:-

  • NOPSA Assessment policy (N-04000-PL0050)- a general policy document explaining NOPSA's position on all assessment processes.
  • NOPSA Safety Case assessment policy (N-04300-PL0052) - a policy document specific to Safety Case assessment.
  • Q&A - What is a Safety Case? - a guidance document putting forward NOPSA's view of how Safety Cases work in our offshore petroleum environment.
  • Level of Detail – Expectations for Safety Case Submission
  • Making assessment submissions to NOPSA (N-04300-GL0225)

    • Guidance on related topics

    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

    Guidance on the format and presentation of the safety case documents is provided in the Safety Case Assessment Administration summary and a submission cover sheet is provided which allows operators to identify the purpose of the submission and check it for completeness.

    Discussion Papers for Comment

    Detail in a Safety Case

    One of the main issues identified during the use of NOPSA's Safety Case Assessment Core Process is the level of detail expected in a safety case submission. The attached draft discussion paper provides guidance on the level of detail expected to be included in relation to each of the major aspects of a safety case submission. The period of comment on this paper has now closed and responses are being reviewed.


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