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Requirements for Design Safety Cases



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CER 13283 Safety Case Guidelines
7
Requirements for Design Safety Cases
Section 7.1 provides guidance on the scope of a Design Safety Case. Sections 7.2 to 7.7 provide the structure and outline contents fora Design Safety Case. The content requirement of certain sections of the Design Safety Case is equivalent to the content requirements of a Production Safety Case (described in section 4). To avoid unnecessary duplication within the Guidelines, these content requirements are cross referenced.
7.1
Scope of Design Safety Case
To carry on a production activity, the petroleum undertaking must hold a Production Safety Permit for that specific production activity which will be issued pursuant to an approved Production Safety Case and, in respect of new Production Activities or Production Activities which involve a material change a corresponding approved Design Safety Case. A Design Safety Case must allow the CER to assess the design of a Production Installation before it is too late in the design process to change any aspect of it. This will beat the stage in the development of the design such that there is sufficient information available to allow an assessment by the CER of those features that cannot readily be changed later in the project. Thus, the timing of the submission is important in that the design should not have progressed so far that change is difficult and expensive, but also not be so early that there is insufficient detail to allow anything other than a very high level, generic assessment. Therefore, the Design Safety Case should detail the basic nature of the proposed petroleum infrastructure (floating, subsea, fixed jacket etc, the nature of the hydrocarbon export method and the basic design with respect to key safety parameters of any processing plant and equipment together, for an offshore installation, with layout and accommodation for the expected number of persons on-board. In short, the key Safety Critical Elements will have been considered and the concept for them defined such that the way in which hazards are managed and risks are reduced to ALARP is evident. The Design Safety Case is not a document that needs to be maintained in tandem with the Production Safety Case. Its purpose is served once the design has been constructed and the corresponding Production Safety Case approved. If a Design Safety Case is being submitted in relation to a material change to an existing Production Safety Case, this new Design Safety Case need only cover aspects that are relevant to the change. This means that for some changes, (e.g. new riser from a subsea well) the Design Safety Case maybe a relatively short document, while fora major change
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Where a petroleum undertaking has had a plan of development submitted pursuant to a petroleum lease approved by the Minister prior to the publication of these Guidelines, the petroleum undertaking shall not be required to submit a Design Safety Casein the first instance.


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(e.g. anew onshore production train) it will be a larger document and potentially similar in extent to a Design Safety Case fora new Facility. For the case of a material change, the Design Safety Case can refer to details contained in the corresponding Production Safety Case. For the example of anew riser from a subsea well, it is likely that the SMS section of the Design Safety Case simply refers to the SMS in the Production Safety Case, though the petroleum undertaking has to always ensure that the SMS covers all aspects of the operation. If a material change occurs to the Design Safety Case, it needs to be resubmitted to the CER for approval. The threshold for whether a change is material in relation to the Design Safety Case is a higher one than fora Production Safety Case, due to the fact that it is describing the petroleum infrastructure, its safety systems and the demonstration that all risks to safety have been reduced to ALARP is at a higher level.

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