A practical approach for the safety assurance of projects at pre-consent
All capital projects supporting the energy transition face evolving safety risks that must be understood and managed effectively. Committing the right amount of capital to de-risk a project is crucial. Spending too much or taking on too much risk by spending too little, can seriously damage the return on investment.
Safety assurance at the pre-consent stage plays a significant role in reducing the risk profile of the project. It provides comfort to all stakeholders that the asset will be safe, and that planning consent will be gained. But how do project developers ensure the appropriate level of time and resource is spent?
What is project safety assurance?
A Safety Assurance Process (SAP) ensures an asset’s safety-related equipment and activities do what they need to do to keep people safe. SAPs look different from project to project; for example, additional safety studies would be expected for an offshore wind project to address marine risks that are not present for an onshore windfarm. Furthermore, the SAP will evolve as the project progresses through its lifecycle stages.
At pre-consent the SAP revolves around doing enough to demonstrate that the facility will be safe in the planned location, as well as making commitments about what will be done post-consent to manage future lifecycle safety risks.
TAKE A proportionate approach
The effort spent on safety assurance should be proportionate to the safety risks. Pragmatically the focus should be on the most significant risks. In the UK the legislative requirement is to reduce risk to people to As Low As Reasonably Practicable (ALARP). Many multi-national companies have adopted a similar standard. Pre-consent, the onus is on the project developer to demonstrate that the residual risk arising from the design will be ALARP.
Avoid boxING YOURSELF into a corner
As the design progresses towards a frozen position ready for planning application, it is crucial that decisions are not committing the project to an unsafe future scenario. Undoing design decisions late in a project is extremely costly.
For example, be confident in the footprint of the facility such that post-consent there is no need to acquire any further land at an inevitably higher premium. This might involve ensuring adequate land rights over visibility splays or sightlines at all junctions with a public road.
The opportunity to eliminate risks entirely is greatest during pre-consent. For example, eliminating the risk of contaminating a neighbour’s private water supply by providing an alternative water source for them.
Moreover, paying attention to the interdependencies of design decisions is important not just from a safety perspective, but also for wider project, asset and commercial considerations.
For instance, configuring the layout of battery containers such that they can be replaced without lifting over adjacent live battery containers. This not only eliminates the safety risk of dropped objects on live plant but also minimises the commercial impact by keeping more batteries live during the swap-out.
YOU CAN’T ENGAGE TOO MUCH
Consultation is rightly demanded by legislation, but stakeholder engagement should not be limited to statutory consultees. All stakeholders require comfort that the facility will be designed, constructed, operated, maintained and decommissioned safely.
Engaging with everyone impacted by the scheme will enhance the prospects of gaining planning consent. Also, this strategy often helps to identify unusual safety risks early in the project, allowing them to be addressed by the design.
Landowners and users, for example, can be critical sources of risk information as they have an appreciation of the site’s inherent risks and their own operations. Fine details such as the configuration of cattle grids required by farmers at junctions can significantly impact the safety of road users and pedestrians.
DO THE first THING RIGHT
Fortunately, there are tools and techniques available to help navigate safety assurance pre-consent – doing enough but not overdoing it.
Figure 1 – A practical approach to project safety assurance
Figure 1 presents a tried and tested approach. The keystone involves understanding what can go wrong. The hazard identification (HAZID) study, the bread and butter of major hazard industries, is an excellent technique for identifying potential hazards.
HAZID workshops are best run by an experienced facilitator and recorded by a scribe, and attended by key stakeholders such as designers, constructors and operators. These systematic brainstorming sessions aim to deliver a comprehensive, project-specific hazard register which forms the backbone of the SAP.
These workshops should be proportionate to the risk and complexity of the facility, so they can range from half a day to several days in duration. Project teams often get far more from the sessions than simply identifying safety risks. The best facilitators will create an open and stimulating atmosphere that often yields insights into wider project risks and opportunities.
Involving other stakeholders in the HAZID workshop can bring significant benefit. This arises not just from tapping into their expertise and knowledge, but laying the foundation for a constructive, ongoing working relationship.
FOCUS ON THE BIG THINGS
The hazard register created from the HAZID study is updated and refined as the project transitions through its lifecycle phases. The register provides a record that can be included in pre-construction information and health and safety files, performing a useful function in the UK for those projects falling under the Construction (Design and Management) Regulations 2015.
The hazard register offers a structure to differentiate between primary and secondary safety issues. Primary safety issues are those which are fundamental to demonstrating that the proposed facility will be safe in its planned location. They require specific management attention. Secondary safety issues are not fundamental to the justification and there is no need to resolve them to inform a consenting decision.
This approach avoids unnecessary effort and expense, with only the primary safety issues needing to be resolved in support of the consenting decision. An action plan for the secondary safety issues post-consent will suffice.
All primary and secondary safety issues would be taken forward in the project’s SAP, through consent and the final investment decision, and on into detailed design, construction and operation. Should consent unfortunately not be granted, then time and resource spent on safety assurance has been restricted to the primary risks alone.
Conclusion
Spending too much effort and funds on safety risks at the pre-consent stage can jeopardise energy transition projects by putting undue financial pressure on project developers, as well as reducing available funds on the journey to net zero.
Using a proven safety assurance approach in a proportionate, pragmatic and systematic way, supports efforts to gain consent. It also neatly sets up the project for successful delivery post-consent.
