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what is a safety case? - Wind Energy Network

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COMMUNICATION HUB FOR THE WIND ENERGY INDUSTRY<br />

Ecology<br />

Jack-Up Vessels<br />

Spotlight on Ireland<br />

Special<strong>is</strong>t Tools<br />

August/September 2013 | £5.25


RISK MANAGEMENT<br />

RISK MANAGEMENT<br />

Safety Cases<br />

You either love’em<br />

or hate’em!<br />

...but implement them effectively and everyone will come to love them<br />

‘Safety Cases’ well and truly divide opinion. Some see them as an <strong>is</strong>olated exerc<strong>is</strong>e<br />

of complex analys<strong>is</strong> and written work that does not reflect the real world. Others<br />

see them as a large pile of documents produced to get somebody off their back<br />

before they sit on a shelf gathering dust. Whilst regrettably there <strong>is</strong> evidence to<br />

justify these views, the more informed recogn<strong>is</strong>e that a Safety Case approach<br />

<strong>is</strong> an excellent way of ensuring projects are conceived and executed safely and<br />

ultimately provide the written demonstration that your plant, facility etc. <strong>is</strong> safe. But<br />

they are not just about the ‘now’. They provide a framework and focus for ensuring<br />

<strong>safety</strong> throughout the project life-cycle. They provide assurance that everything <strong>is</strong><br />

and will continue to be safe!<br />

But <strong>is</strong> a Safety Case approach relevant and appropriate for the wind industry For the<br />

majority of onshore wind farms in remote, rural locations, the answer <strong>is</strong> most likely to<br />

be ‘no’. The potential r<strong>is</strong>k to people, assets etc. can be readily d<strong>is</strong>counted through<br />

observation and judgment without the need for an ultimate Safety Case. For offshore<br />

wind farms the situation <strong>is</strong> quite different. Managing offshore assets, and in particular<br />

getting people on and off safely, presents a number of significant challenges and r<strong>is</strong>ks.<br />

Also, similarities with offshore oil and gas facilities presents inevitable parallels with an<br />

establ<strong>is</strong>hed Safety Case culture.<br />

R<strong>is</strong>ktec concludes its series of articles on r<strong>is</strong>k management by providing a series of tips<br />

on how to develop a Safety Case for an offshore wind farm, building on the principles,<br />

tools and techniques and proportionate approach d<strong>is</strong>cussed in previous <strong>is</strong>sues.<br />

What <strong>is</strong> a Safety Case<br />

Safety Cases are detailed documents demonstrating that facilities are<br />

designed, constructed, comm<strong>is</strong>sioned, operated and decomm<strong>is</strong>sioned in<br />

such a way as to minim<strong>is</strong>e r<strong>is</strong>ks to personnel, the public and, for HSE <strong>case</strong>s,<br />

the environment. They;<br />

• Demonstrate to management and employees, investors, contractors and,<br />

where relevant, the Regulator and/or the Public that adequate controls are in<br />

place to ensure that the major HSE r<strong>is</strong>ks ar<strong>is</strong>ing from a particular operation are<br />

both tolerable and reduced to as low as reasonably practicable [ALARP].<br />

• Provide a reference point for everyone involved with facility operations to define<br />

the requirements for effective control of Safety <strong>is</strong>sues.<br />

Imagine giving someone a document on their first day working at your facility.<br />

It describes the facility, operations and processes very clearly. It identifies the<br />

potential r<strong>is</strong>ks and provides appropriate, proportionate arguments and evidence to<br />

demonstrate that they have been reduced ALARP, referencing more detailed studies<br />

and defines <strong>what</strong> needs to be done to maintain th<strong>is</strong> position. They find it easy to read<br />

and continuously refer to it as they get up-to-speed in their new role. Th<strong>is</strong> represents<br />

a good Safety Case!<br />

1) A Safety Case <strong>is</strong> not just<br />

about the destination, it’s about<br />

the journey too!<br />

Whilst a Safety Case <strong>is</strong> the written<br />

demonstration of why a plant, facility<br />

etc. <strong>is</strong> safe, it should not be seen as a<br />

retrospective justification and certainly not<br />

a piece of creative writing to ‘get away<br />

with’ an inadequate solution. A truly safe<br />

outcome can only be achieved by fully<br />

integrating design and <strong>safety</strong> assurance<br />

activities. The documentation of th<strong>is</strong><br />

process <strong>is</strong> arguably the most important<br />

element of a Safety Case. That <strong>is</strong> why it<br />

<strong>is</strong> called a Safety Case ‘approach’; you<br />

build and develop the Safety Case as the<br />

project progresses.<br />

2) Don’t re-invent the wheel;<br />

look to other Industries<br />

Safety Cases have been around a long<br />

time in other industries; particularly<br />

Nuclear Power and Oil & Gas. A huge<br />

amount of time and effort has gone into<br />

developing these approaches. Use th<strong>is</strong><br />

to your advantage. Cherry-pick the best<br />

bits for your offshore wind farm Safety<br />

Case. Th<strong>is</strong> does not need to be limited to<br />

the overall approach and structure. Use<br />

and adapt their tools and techniques to<br />

build your <strong>case</strong>; the ‘Bow-Tie’ technique<br />

pioneered in the Oil & Gas Industry [see<br />

Dec’12/Jan’13 <strong>is</strong>sue] and the ‘Claims,<br />

Arguments & Evidence’ approach used<br />

in the Nuclear Industry [see Figure 1] are<br />

two good examples.<br />

Figure 1; Example use of ‘Claims, Arguments, Evidence’ approach to justify Integrity of Offshore <strong>Wind</strong> Turbine foundation<br />

3) Proportionality <strong>is</strong> key!<br />

The level of detail, analys<strong>is</strong> etc. you<br />

present in your Safety Case must always<br />

be proportionate to the associated r<strong>is</strong>k.<br />

Too little and your Safety Case will be<br />

inadequate. Too much and you’ll waste<br />

valuable time, effort and resources and<br />

degrade the perceived value of the<br />

exerc<strong>is</strong>e. Th<strong>is</strong> <strong>is</strong> particularly important<br />

when cherry-picking tools and techniques<br />

from higher hazard industries. As such,<br />

Safety Cases can be large and complex<br />

for say a nuclear installation [complex and<br />

highly hazardous] or be very brief and<br />

simple for less complex, less hazardous<br />

facilities such as wind farms.<br />

4) Understand the scope of your<br />

Safety Case<br />

You must be clear on <strong>what</strong> plant,<br />

operations etc. your Safety Case <strong>is</strong><br />

covering. Whilst clearly it will cover<br />

the wind turbines, it <strong>is</strong> unlikely to<br />

cover the onshore substation or<br />

access vessels as these will likely be<br />

operated by others. That said, it must<br />

dove-tail with the <strong>safety</strong> justification for<br />

these to ensure all interfaces are fully<br />

understood and mutually achieved.<br />

5) Involve all Stakeholders<br />

You must involve all stakeholders to<br />

ensure that the above interfaces are<br />

adequately managed. Involving people<br />

with hands-on experience in all aspects<br />

of the design and operation of a wind<br />

farm <strong>is</strong> critical. They know <strong>what</strong> goes on<br />

in the real world! They will bring valuable<br />

experiences from other projects which will<br />

help make your Safety Case more robust.<br />

A major benefit of a Safety Case approach<br />

<strong>is</strong> the sharing of knowledge, experience<br />

and best practice along the journey.<br />

6) Safety Case v Occupational<br />

Health and Safety Management<br />

System [OHSMS]<br />

Your Safety Case doesn’t need to<br />

go back to first principles to ensure/<br />

demonstrate your wind farm <strong>is</strong> safe.<br />

Your corporate and/or wind farm specific<br />

OHSMS should provide a framework for<br />

safe operations. Rely on your OHSMS<br />

[see Figure 2] and use it to simplify your<br />

Safety Case and ensure a cons<strong>is</strong>tent<br />

approach across all your wind farms.<br />

Figure 2; Safety Case and OHSMS<br />

Interfaces<br />

7) A ‘Life-Cycle’ Safety Case<br />

It <strong>is</strong> important that you identify key Safety<br />

Case milestones at the outset of your<br />

project. How and when are you going to<br />

demonstrate your wind farm has been<br />

designed, constructed, comm<strong>is</strong>sioned,<br />

operated and decomm<strong>is</strong>sioned safely<br />

Can these milestones be combined What<br />

structure <strong>is</strong> appropriate for each milestone<br />

8) A Safety Case <strong>is</strong> no guarantee<br />

of future <strong>safety</strong><br />

Once you have written your Safety Case<br />

don’t just stick it on a shelf and rest on<br />

your laurels. Remember, it’s action that<br />

reduces r<strong>is</strong>k, not paperwork! You must<br />

use it to retain focus on safe operations<br />

whilst making sure it <strong>is</strong> updated to<br />

reflect the evolving nature of the facility.<br />

Also, things inevitably get m<strong>is</strong>sed. Don’t<br />

become blinkered to new hazards/r<strong>is</strong>ks.<br />

Ensure emergent <strong>is</strong>sues are folded into<br />

the Safety Case as they ar<strong>is</strong>e to ensure<br />

they are managed effectively. It must be<br />

a living document that reflects the actual<br />

plant status and mode of operation<br />

otherw<strong>is</strong>e it <strong>is</strong> worthless. Th<strong>is</strong> takes effort<br />

and commitment and must be factored<br />

into your resource plans.<br />

We can’t tell you <strong>what</strong> a <strong>safety</strong> <strong>case</strong><br />

process should look like for your<br />

organ<strong>is</strong>ation because of the diversity<br />

of the industry and the internal<br />

management arrangements within<br />

your organ<strong>is</strong>ation. But if you follow the<br />

principles above you’ll end up with a<br />

valuable, proportionate process tailored<br />

to the needs of your organ<strong>is</strong>ation that<br />

doesn’t leave a bitter taste in your mouth!<br />

Gareth Ellor<br />

R<strong>is</strong>ktec Solutions Ltd<br />

www.r<strong>is</strong>ktec.co.uk<br />

38 www.windenergynetwork.co.uk<br />

www.windenergynetwork.co.uk 39

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