phase 4 report - DNV

RN04: ESCAPE, EVACUATION AND RESCUE OF PEOPLE // Guidance on Creating Performance Standards2.4. Alignment with National AuthoritiesThe purpose of this section is to present a simplifiedoverview of a process that could be adopted to alignthe use of existing and developing national rules andregulations with the application of international bestpractice and standards.Essentially where international best practicehas adopted a performance-based approach,existing rules and regulations are often found to beprescriptive, as was the case with the UK regulatoryStatutory Instruments prior to the Piper Alphadisaster in 1986. The Lord Cullen enquiry concludeda number of recommendations that are beingadopted worldwide by International Standards.The challenge projects face is to demonstrate howexisting rules can be satisfied, in part or whole, whileadopting lowest risk goal-setting objectives usingperformance standards that demonstrate risks arebeing or have been reduced to below those laid downby prescriptive rules and regulations. For example,understanding how a project can satisfy all nationalrules and regulations where inter-relationships andhierarchy is confusing, because they either fall underGovernment, Ministries and Authorities or underregional municipality and regional divisions ofnational authorities, would be most challenging atthe start of a project.Appreciating the differences and similaritiesbetween national rules and regulations andinternational standards (ISO) is fundamental toestablishing and agreeing the process that leads tothe necessary approvals. Not all clauses in rulesand regulations are relevant for every offshoreproject at its specific location, and so a gap analysisapproach is first necessary to establish the most likelyrequirements ahead of establishing PerformanceStandards and those that are not likely to berelevant. A seamless process is necessary, one thatis understood, supported and accepted by nationalauthorities, one that includes the need to take aperformance-based approach, fully evaluating thespecific risks and then demonstrating compliancewith relevant rules and regulations.Both the Authorities and Operators shouldbe aligned in the principle of achieving designsand operations that have reduced risks to people,environment and assets to ALARP, and in so doing,satisfy relevant national rules and regulations.Demonstrating compliance with internationalbest practice for Escape, Evacuation and Rescuesystems therefore relies on correctly identifying theparts of the facility and its operations that requiretransparent demonstrations that risks have beenevaluated and reduced to ALARP. The setting offacility Performance Standards, i.e. those partsthat are safety critical by definition with respect topreventing, detecting, controlling and mitigatingMajor Accident Hazards, are the key, as has beenproven over many years internationally. Merging theexpectation of rules and regulations compliance withthe performance standards approach can both besatisfied by providing a logical 4 step process. RN04concluded that these sequence steps can providesuccessful and timely approvals, while deliveringan auditable project decision trail that reduces risksduring Escape, Evacuation & Rescue. It should beadopted also for many other systems determined tobe safety-critical and even processes that are not,such as production availability / flow assurance.150RUSSIAN–NORWEGIAN COOPERATION PROJECT