PROCESS SAFETY APPROACH IN THE MIDDLE EAST SELF REGULATION OR REGULATORY RX? Darrell Dowd

2 Types of Regulation to achieve certification / assurance PRESCRIPTIVE: Prescribed methods on how to achieve results Assurance becomes the responsibility of the operator Minimum Compliance Based PERFORMANCE BASED/GOAL SETTING SELF REGULATING: Goals to achieve are set using standards set by industry/government agencies Up to the operator to determine how/what method to use Success or compliance can be based on internal criteria

3 Prescriptive Regulation Compliance methods and measurement set by outside agencies (not by Operators) Several major incidents have occurred within a highly prescriptive system (at the time) Dating back to Piper Alpha to the BP gulf of Mexico Traditionally will predict what companies are required to do to assure (offers transparency) Operators will/can follow minimum requirements Regulatory agencies do not always possess the SME or latest technologies when setting requirements Can be limiting, inflexible and inefficient

4 Self Regulation – Performance/Goal Based Designed to promote internal control systems Outside agencies provide objectives or goals, not methods of achieving Operators have control on the methods used to achieve assurance Can be influenced by what is good for the particular industry from a commercial or business perspective Relies on the use of safety case methods to establish assurance Restricts public input and transparency as operators protect intellectual property and competitive advantage

5 Safety Case use in a self regulated system BASIC PRINCIPLES Those who create the risks are responsible for controlling them Safe operations are achieved by setting and reaching goals Government sets the goals while operators determine what methods they will use Safety Cases are typically the balancing of benefit of an activity while protecting those who may be affected by it In essence – Safety Case = Cost Benefit Analysis (CBA) The concept of As low as reasonable Practical (ALARP) is widely used

6 Challenges with Safety Case use Relying largely on probabilistic analysis, historical failure rates are used When newer technologies and processes are introduced there may be a lack of data to support Subject to proving a system/activity is safe, rather than unsafe Confirmation Bias is possible that confirms preconceptions or ideas People will focus and interpret evidence in a way that confirms the goal they have set Often focused on what is probable, not what could be catastrophic

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