NOPSEMA Environment Management Regulatory Update and Workshop Melbourne 29 October 2012
Introduction • Agenda – Safety briefing + introductions – Regulatory guidance – Spill Assessment updates – Key priority focus areas – Regulatory update • inherited EPs • statistics
Regulatory Guidance
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
Environmental management external document structure OPGGS Act OPGGS Act OPGGS (Environment) OPGGS (Environment) Regulations Regulations Policies Policies Guidelines Guidelines Guidance Guidance Note Note Practice Practice Note Note
Process model evolution Establishing the context consultation Monitoring andreview Risk identification & Communication and analysis Risk evaluation and treatment Approach: • EP Guidance Notes - adopt a system-based model as basis • Structured on process elements • All priority issues/topics raised will be covered
Environment plan content Process Element (regs) Activity Describe 13(1)(2) Environment Requirements Acceptable level Detail 13(3a) Impacts and risks Impacts and risks Evaluate 13 (3b) ALARP Demonstrate 11(1b,c) Acceptable level Objectives Perform 11(1d) 13(4) >Measurement criteria Monitor 11 (1e) Standards Monitoring Reporting Consult 11 (1f) Consultation Plan to implement Implementation strategy
EP process AS/NZS ISO 31000:2009 DESCRIBE DETAIL CONSULT PERFORM & DETAIL MONITOR EVALUATE & DEMONSTRATE EVALUATE & DEMONSTRATE
Environment plan process Activity assessment Strategy (Plan for implementation) Establishing the context Continual Continual improvement improvement consultation Monitoring andreview Management Management Risk identification & analysis review review Communication and Environmental Environmental policy policy Checking Checking Planning Planning Risk evaluation and treatment Implementation Implementation and operation and operation AS/NZS ISO 14001
Elements in the EP process
Application of elements in the EP process Consultation Consultation Communication & consultation Evaluate & Evaluate & Perform & Perform & Describe Describe Detail Detail Demonstrate Demonstrate Report Report Monitoring and Review Establish the context Risk identification & analysis Evaluation & Treatment Context: • ESD principles • Activity Detail Impacts • Environment Evaluate I&R and Risks • Stakeholders • Policy • Requirements Acceptable Level Performance Objectives Acceptable Level & ALARP & Measurement Criteria Performance Standards Controls & Measurement Criteria Implementation strategy
EP Overview Guidance Note: example PROCESS ELEMENT EVALUATE & DEMONSTRATE: ALARP Regulation 11 (1) (b) demonstrates that the environmental impacts and risks of the activity will be reduced to as low as reasonably practicable; 14 (3) The implementation strategy must identify the specific systems, practices and procedures to be used to ensure that the environmental impacts and risks of the activity are continuously reduced to as low as reasonably practicable and that the environmental performance objectives and standards in the environment plan are met. Regulatory Interpretation: Objective To ensure the environmental impacts and risks of petroleum activities are managed to as low as reasonably practicable (ALARP) while allowing individual companies to adopt environmental practices and technologies best suited to individual company circumstances, activities and locations. Core Concepts • ALARP is the point where the sacrifice required to reduce the environmental impacts and risks of the activity any further would be grossly disproportionate to the environmental benefit gained • The Operator must demonstrate in the EP that impacts and risks will be managed to ensure they are reduced to ALARP • The implementation strategy must show how impacts and risks will continue to be ALARP for the life of the activity • Operators need to provide sufficient justification and supporting information in the EP in order for the Regulator to have reasonable grounds for believing the environmental impact and risks are ALARP • The demonstration of ALARP must be appropriate for the nature and scale of the activity • Demonstration of ALARP is a particular requirement of the Regulations, but should be considered in conjunction with the acceptable level requirement. Impacts and risks must be managed to ALARP and must also be at an acceptable level. Considerations • ALARP is specific to the context of the activity and its impacts and risks, which means that what is ALARP in one circumstance, may not be ALARP in another • Management measures or controls that are required to ensure environmental impacts and risks are ALARP should be clearly identified • Where management measures or controls are introduced, any impacts or risks that could be caused by the control must also be addressed by the EP • Any statements made by the operator to demonstrate that impacts and risk are ALARP should be adequately justified. The justificationof statements should include sufficient supporting evidence or references such that NOPSEMA can reasonably determine their accuracy and reliability • The approach used in providing the required demonstration of ALARP within an EP is at the discretion of the operator • Approaches that could be considered in presenting an ALARP demonstration include: • Application of the control hierarchy (best first): elimination; prevention; reduction and mitigation • Comparative assessment of alternatives to reduce environmental impacts and risks relative to their sacrifice (e.g. cost, schedule, operability, safety) • Impact or risk is sufficiently low, such that any benefit gained is likely to be negligible (and consequently any significant sacrifice would be grossly disproportionate) • Comparison of impact and risk with company and societal values for what is reasonably practicable Definitions Management measure or control - a system, an item of equipment, a person or a procedure, that is used as a basis for managing environmental risk
OSCP Practice Note Guidance Scope – Offshore petroleum activities – Oil spill impacts and risks only Guidance Content – Oil spill risk control measures their impact and selection – Planning process in accordance with the regulations – General advice on what to consider in demonstrating ALARP and acceptable – Possible approaches to oil spill risk management Fully integrated with current National Plan arrangements A232763 13
2012 • Published interim guidance for consultation Q1 2012 • Consultation workshop with industry • Rev 1 released for use Q2 2012 • Consolidated Government and other stakeholder feedback • Rev 2 released for use Q3 2012 2013 • Planned review of guidance note in context of other NOPSEMA Guidance Q1 2013 • Planned review of content based on known changes to Regulations Q2 2013 • Consultation process complete and revision 3 published Q3 2013 A232763 14
OSMP Practice Note Scope • Practical advice to operators on how to prepare a high standard and fit- for-purpose OSMP that can be rapidly implemented in the event of a spill • Information will cover lessons learnt from recent incidents as well as planning, design and implementation of a monitoring program to meet regulatory requirements • Operational (Type 1) and scientific (Type 2) monitoring Content • Guidance will give effect to Govt’s directive regarding OSMPs from Montara COI • Complement and expand on other Government guidance on oil spill monitoring (e.g. AMSA handbook) • Provide sufficient topic coverage to meet both sets of legislation (OPGGSA and EPBC Act) • Monitoring during normal operations included in future guidance
OSMP • Preliminary drafting • Consultation with industry groups + Govt agencies Q2 2012 • Draft OSMP guidance undergoing internal review Q3 2012 • Technical and Commonwealth Government Review (SEWPaC, RET, AMSA, CSIRO, AIMS, GA) Q4 2012 • Industry workshop (Dec) • Interim guidance issued for use and industry comment – December 2012 Q4 2012
NOPSEMA Advice OPGGS Act OPGGS Act OPGGS (Environment) OPGGS (Environment) Regulations Regulations NOPSEMA Assessment Policy Policies Policies EP Assessment Policy Reasonable Grounds Guidelines Guidelines Appropriate… Acceptable level Guidance Guidance EP Content Requirements Note Note Petroleum Activity ALARP Practice Practice Consultation Note Note OSCP + OSMP Performance Objectives Performance Standards A232763 17
Questions?
Spill Assessment Update
Objective 1. Provide regulatory clarity on the complexities of vessel based petroleum activities 2. Provide an overview of Victorian oil spill response arrangements
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