Journal of Loss Prevention in The Process Industries, Vol.46, 154-162, 2017
Regulatory approaches - Safety case vs US approach: Is there a best solution today?
In the wake of the August 2012 fire at the Chevron refinery in Richmond, California, the United States (US) Chemical Safety Board proposed the safety case regulatory approach as an alternative to the current approach used in the US today. The current regulations known as the Process Safety Management (PSM) regulations were promulgated in 1992. This followed several highly publicized catastrophic incidents (e.g., Phillips 66 Pasadena, Texas polyethylene plant explosion, 1989; Piper Alpha, North Sea, 1988 and Bhopal, India, 1984). The US approach to regulation is best described as a combination of prescriptive and performance-based regulations that address safety-considerations in design and operations. A safety case approach, as used in the United Kingdom (UK), Australia and Norway, requires a detailed analysis of hazards and steps taken to address those hazards, and thus minimize or mitigate the risk. Both the safety case and PSM processes address many of the same aspects such as management of change, identification of hazards and assessment of risks, but the process and format for documentation and regulatory review differs. The question then arises as to the effectiveness of these two regulatory regimes in preventing process safety related incidents. Many reputable organizations and research groups have taken positions regarding whether the US should abandon the existing system of safety regulations. Review of several global incidents has shown that while appropriate hazards and risks were identified, operational shortcomings led to incidents. Uniform and consistent process safety data are in the early stages of being collected and published by such organizations as the American Petroleum Institute (API) and The International Association of Oil & Gas Producers (OGP), using API RP 754 defined metrics. For this paper, data have been collected on oil and gas operations in the US, UK, Norway and Australia to compare the performance of the differing regulatory regimes. While the data are not comprehensive, from existing data on major incidents, spills and fatalities, one cannot conclude that one regulatory regime is superior to the other. Consistent reporting of incidents in a database with appropriate metrics is sorely needed. Furthermore, the authors express the need to move beyond regulatory compliance and suggest research on application of a systems approach to process safety by developing a process resilience analysis framework for process design and operations. (C) 2017 Elsevier Ltd. All rights reserved.