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Requirement/Validation
A facility cannot be constructed, installed, operated, modified or decommissioned without a safety case in force for that stage in the life of the facility. The operator of a facility must submit the safety case for a facility to NOPSA. This submission should include a covering letter stating that the safety case is being submitted for assessment. Since it is the operator that must submit the safety case, registration of the operator must be completed prior to safety case submission.
The Offshore Petroleum (Safety) Regulations 2009 (OPS) set out the requirements for the contents of safety cases.
The OPS Regulations, state that NOPSA may, by notice in writing, require the operator of a proposed facility or an existing facility, to provide a validation in respect of the proposed facility or in respect of a proposed significant change to an existing facility.
In order to deliver a consistent approach to validation of proposed facilities or to significant change to existing facilities, NOPSA has recently reviewed and reinforced its internal processes to ensure that an administrative process is in place that is accurately aligned with the requirements of the legislation. As a result, NOPSA has developed a policy on Validation.
Once a validation is requested by NOPSA, an operator may not submit the safety case for a facility before the operator and NOPSA have agreed on the scope of validation for the proposed facility or proposed significant change to an existing facility.
The operator should allow sufficient time between agreeing on a scope of validation and submission of the safety case. Where validation has been requested, adequate validation forms part of the safety case acceptance criteria and therefore validation will need to be completed and received by NOPSA before the end of the assessment period in order for the Safety Authority to accept the safety case.
In general, the regulations impose safety case assessment time frames on NOPSA. For a new safety case, NOPSA has 90 days in which to either notify the operator that the safety case has been accepted, rejected, or to propose a new assessment timeframe. For revised safety cases NOPSA has 30 days to notify the operator.
If the initially submitted safety case is not acceptable, NOPSA will either notify the operator that the safety case has been rejected or seek additional written information.
The arrangement for pipelines is different. The pipeline licensee must submit the Pipeline Management Plan to the Designated Authority. The Designated Authority will then provide NOPSA with a copy of the Pipeline Management Plan (PMP) and NOPSA will decide on acceptance of the safety-related aspects of PMP [known as the Pipeline Safety Management Plan (PSMP)]. The Designated Authority is responsible for deciding on the overall acceptance of the PMP.
Policy - Validation
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