Practical proposals for improving the Department of Labour’s approach to high hazard industries
In June 2011, the Department of Labour’s Labour Group completed a review to identify practical steps it could take to improve its approach to high hazard industries such as mining and petroleum production.
This review helped inform the Department’s decision to establish a new High Hazards Unit focusing initially on mining and petroleum as well as geothermal.
The review also made a number of recommendations about how the Department could improve its overall approach to high hazard industries. These recommendations will be considered and addressed by the new High Hazards Unit.
This report was written for an internal audience and, as such, assumes a reasonable level of technical and operational knowledge about the Department’s work in this area.
Clarification relating to SGS M&I and its accreditation as an inspection body
During the drafting of the “Practical Proposals” report a check of IANZ’s online directory of accreditation could not confirm that SGS M&I was accredited as an inspection body under the Health and Safety in Employment (Petroleum Exploration and Extraction) Regulations 1999.
As a result, Attachment One of the Practical Proposals report stated that “it is unclear whether SGS M&I is still operating as inspection body under the Petroleum Regulations” and in a related table the report comments “it [SGS M&I] does not appear to be accredited with IANZ for work under these Regulations”. Furthermore, because SGS M&I’s certificate of accreditation was unavailable online at the time, the report did not include SGS M&I’s in the areas of scope of accreditation listed in Attachment Two.
Since publication, the Department has confirmed that IANZ has accredited SGS M&I as an inspection body under the Health and Safety in Employment (Petroleum Exploration and Extraction) Regulations 1999. The date of the current certificate of accreditation is 21 June 2011.
SGS M&I’s certificate accreditation includes the following statement:
“Inspection of new and existing boilers, pressure vessels, pipework and cranes for compliance with the requirements of the HSE (Petroleum Exploration and Extraction) Regulations 1999. Inspection of offshore structures and subsea pipelines shall be provided by RINA S.p.A and/or SGS Germany, with prior approval of the Regulator for review and incorporation into the process”.
SGS M&I’s certificate of accreditation also includes the following scope areas relating to petroleum regulations: boilers, pressure vessels, pressure piping, cranes and welds.
- Summary of recommended actions
- Recommendation one: Enhance the Department's focus, capacity and capability to deal with high hazards
- Planning and coordinating high hazard work on a national basis
- Establish a High Hazards Unit in National Office
- Provide additional internal resources to support high hazard work
- Formalise and recognise the contribution from general Health and Safety Inspectors
- Review and update information systems to support high hazards
- Recommendation two: Draw on certification, verification, plans and notifications
- Ensure all required information is up to date
- Establish a national standard for petroleum installation inspection bodies
- Collect information about inspection bodies' use of subcontractors
- Encourage the use of verification schemes
- Remind operators of all notifiable requirements and pull this information to the centre
- Invite petroleum operators to provide copies of reports of audits completed over the past six months
- Refresh inspection bodies and ensure they are kept current
- Open the possibility of self-inspection or industry-provided mutual inspection
- Encourage reporting near misses and major events
- Develop lead and lagging indicators for high hazards
- Develop a new industry liaison forum focused on high hazard
- Invite inspection bodies to inform the Department of conditions, limitations, qualifications on certificates
- Recommendation three: Strengthen relationships
- Strengthen the relationship with third party inspection bodies
- Strengthen the relationship with employee representatives and health and safety representatives
- Strengthen the relationship with NOPSA
- Strengthen the relationship with operators
- Strengthen the relationship with MED
- Strengthen the relationship with Maritime New Zealand
- Enable other regulators to access our data/information holdings
- Maintain international contacts - but lift them to a strategic level while also maintaining operational contact
- Recommendation four: Bolster the analysis of Safety Cases
- Third party review of current safety cases
- Third party review of future safety cases
- Consider developing an ACOP or guidance note on safety case development and/or assessment
- Selectively test conformity with safety cases
- Recommendation five: Help high hazard industries to comply
- Identify any international standards that can be adopted within the current regulatory framework
- Help mines complete a safety assessment/report by providing a simplified template
- Provide high hazard providers with targeted information on requirements of HSE, HSNO Acts and applicable regulations
- Recommendation six: Support environmental outcomes and regulation
- Actively support interim measures to promote environmental outcomes while legislation is underway
- Recommendation seven: Hold off further work on funding until these practical suggestions are implemented or progressed
- Flag the issue of funding but take it no further for now