Submissions for the Gas Supplementary Issues Paper on the review of Victoria’s electricity network safety framework closed on Friday 16 June. Along with the following organisations, R2A welcomed the opportunity to respond to the independent review.
- Australian Energy Market Operator
- Australian Energy Regulator
- Australian Gas Light Company
- Australian Gas Networks
- APA VTS
- Engineers Australia
Our response focuses on the following particular aspects of the review:
- The objectives of the safety framework in Victoria and an assessment of its effectiveness in achieving safety outcomes.
- The extent to which the regulatory framework governing network safety ensures effective risk management by energy network businesses.
In particular the reliance on the traditional quantified risk assessment (QRA) and the ALARP (as low as reasonably practicable) approach using target risk criteria (tolerable or acceptable) by the gas and major hazard industries which has two primary difficulties:
- Arguable non-compliance with the provisions of the Gas Safety Act (1997) and OHS Act (2004), and,
- Disutility for land use (safety) planning that the QRA-ALARP-target-risk-criteria process facilitates.
Many of the points in R2A’s submission on the electricity networks also apply to the Victorian gas industry. Much of R2A’s submission on the electrical safety in Victoria is devoted to explaining why the legal presentation of SFAIRP (so far as is reasonably practicable) is not equivalent to ALARP (as low as reasonably practicable). This argument also applies to gas safety.
Such an observation always generates commentary to the effect that major organisations like Standards Australia, NOPSEMA and the UK Health & Safety Executive (UK HSE) (a much-quoted source) say that it is.
For example, WorkSafe Victoria’s information sheet on land use planning near a major hazard facility states that operators of an MHF must reduce risk to the surrounding area so far as is reasonably practicable where it cannot be eliminated. However, it then goes on to say that WorkSafe believes it appropriate to present the extent of risk areas around a MHF as planning advisory areas:
- Inner planning advisory area – the individual risk of fatality from potential foreseeable incidents is greater than or equal to 1 x 10-7 per year (one chance in 10 million years).
These key points are expanded in the body of the submission together with a possible way forward. See the full response here.
 http://www.worksafe.vic.gov.au/__data/assets/pdf_file/0004/12397/More_Info_landuse_vs4.pdf for current advice for Major Hazards land use planning from Worksafe Victoria (viewed 14 June 2017).