Inquiry Search
Rec-ID | Code | Recommendation |
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REC258-2535 | 32 - Doctrine, standards, and reform | Airservices Australia, in conjunction with the Department of Infrastructure and Regional Development and the Civil Aviation Safety Authority, reconsiders the policy on ‘Assessment of Priorities’ that stipulates that air traffic controllers sequence arriving aircraft based on category of operation, rather than on the accepted international practice of ‘first come, first served’. |
REC258-2543 | 6 - Insurance and legal liability | The Civil Aviation Safety Authority reintroduces a ‘use of discretion’ procedure that gives operators or individuals the opportunity to discuss and, if necessary, remedy a perceived breach prior to CASA taking any formal action. This procedure is to be followed in all cases, except where CASA identifies a Serious and Imminent Risk to Air Safety. |
REC258-2555 | 32 - Doctrine, standards, and reform | The Civil Aviation Safety Authority changes the current two-tier regulatory framework (act and regulations) to a three-tier structure (act, regulations and standards), with: |
REC258-2533 | 32 - Doctrine, standards, and reform | The Civil Aviation Safety Authority: |
REC258-2540 | 6 - Insurance and legal liability | The Civil Aviation Safety Authority continues to provide appropriate indemnity to all industry personnel with delegations of authority. |
REC258-2554 | 32 - Doctrine, standards, and reform | Recreational Aviation Administration Organisations, in coordination with the Civil Aviation Safety Authority, develop mechanisms to ensure all aircraft to be regulated under CASR Part 149 are registered. |
REC258-2531 | 32 - Doctrine, standards, and reform | The Civil Aviation Safety Authority’s Board exercises full governance control. The nonexecutive directors should possess a range of appropriate skills and backgrounds in aviation, safety, management, risk, regulation, governance and government. |
REC258-2538 | 32 - Doctrine, standards, and reform | The Department of Infrastructure and Regional Development and Department of Defence (and appropriate agencies) establish an agreed policy position on safety oversight of civil operations into joint user and military airports. |
REC258-2550 | 6 - Insurance and legal liability | The Civil Aviation Safety Authority introduces grading of Non-Compliance Notices on a scale of seriousness. |
REC258-2529 | 32 - Doctrine, standards, and reform | The Australian Transport Safety Bureau and the Civil Aviation Safety Authority utilise the provision in their bilateral Memorandum of Understanding to accredit CASA observers to ATSB investigations. |
REC258-2537 | 32 - Doctrine, standards, and reform | The Civil Aviation Safety Authority delegates responsibility for the day-to-day operational management of airspace to Airservices Australia, including the designation of air routes, short term designations of temporary Restricted Areas, and temporary changes to the classification of airspace for operational reasons. |
REC258-2548 | 17 - Assets and technology | The Civil Aviation Safety Authority shares the risk assessment outputs of Sky Sentinel, its computerised risk assessment system, with the applicable authorisation holder. |
REC258-2527 | 32 - Doctrine, standards, and reform | The Department of Infrastructure and Regional Development plays a stronger policy role in the State Safety Program. |
REC258-2562 | 32 - Doctrine, standards, and reform | The Civil Aviation Safety Authority amends the current Terms of Reference of the Industry Complaints Commissioner so that: |
REC258-2536 | 32 - Doctrine, standards, and reform | The Australian Transport Safety Bureau and the Civil Aviation Safety Authority amend the wording of their existing Memorandum of Understanding to make it more definitive about interaction, coordination, and cooperation. |
REC258-2544 | 6 - Insurance and legal liability | The Australian Transport Safety Bureau transfers information from Mandatory Occurrence Reports to the Civil Aviation Safety Authority, without redaction or de-identification. |
REC258-2557 | 6 - Insurance and legal liability | The Civil Aviation Safety Authority reassesses the penalties in the Civil Aviation Safety Regulations. |
Rec-ID | Code | Recommendation |
---|---|---|
REC257-1537 | 32 - Doctrine, standards, and reform | Commanding Officer Defence Explosive Ordnance Training School review and enforce Standard Operating Procedures to ensure that appropriate explosive ordnance accounting and handling practices, in accordance with Defence doctrine, are adhered to during all training activities. |
REC257-1544 | 17 - Assets and technology | Defence should not procure any firefighting vehicle for Marrangaroo Training Area without first consulting relevant personnel within the Rural Fire Service on an appropriate type of vehicle, and obtaining training for the personnel proposed to use it. Alternatively, Defence should explore contracted firefighitng support during periods of live-fire on Marrangaroo Training Area. |
REC257-1553 | 32 - Doctrine, standards, and reform | On matters relating directly to safety or risk, or when live-firing may occur, where there is ambiguity or apparent inconsistency, the most conservative or restrctive order should be followed until formal clarification has been provided. |
REC257-1543 | 32 - Doctrine, standards, and reform | Range Standing Orders be amended to include a direction that no Defence vehicle is to leave the administration area of Marrangaroo Training Area during a bushfire, except to leave Marrangaroo Training Area itself through the main gate, unless it is a properly equipped bushfire fighitng vehicle havig at least four wheel drive capabiliy and self-protection equipment. |
REC257-1552 | 32 - Doctrine, standards, and reform | Authority be given to the regional Environmental Officer to close a range or impose live-firing restriction in addition to any set out in Range Standing Orders if circumstances so warrant. |
REC257-1542 | 17 - Assets and technology | Firefighitng capability at Marrangaroo Training Area be upgraded so that Australian Defence Force members are not placed in situations of unacceptable risk. Specifically, those participating in range practices must have access to a firefighting vehicle close by and easily deployed, and capable of throwing a large quantity of water an appreciable distance into areas adjacent to the ranges, should a fire occur. |
REC257-1551 | 32 - Doctrine, standards, and reform | The use of Internal and External ranges at MTA for patrolling activities be prohibited. |
REC257-1541 | 17 - Assets and technology | A Stryker unit, or an upgraded firefighting unit, be present at the range sentry point, remain manned and ready to deploy during range activites, with its driver in direct radio contact with the Range Safety Officer. Upon the range being declared clear by the Safety Officer inspecting the range after a demolition serial, the firefighting unit must proceed forward to the range wile the periphery of the range continues to be inspected by the Safety Officer, and remain on the range until the Safety officer declares that the area is clear of fire or that it is otherwise appropriate for the fireghting unit to leave the range area. |
REC257-1550 | 32 - Doctrine, standards, and reform | Defence engage with both the Bureau of Meteorology and the Rural Fire Service to determine a more suitable index system. In the interim, Range Standing Orders be amended so that live-firing on the ranges on Marrangaroo Training Area not be permitted where the Forest Fire Danger Index for either the Central Ranges District or Greater Sydney Region is 12, it being the threshold for HIGH Fire Danger Rating or above. put another way, and in a practical sense, Range Standing Orders should, as an interim measure, require the Officer in Charge Practice and the Range Control Officer to consider the Forest Fire Danger Index for both Central Ranges District AND Greater Sydney Region on the day of any given serial. If either index is as 12 or above, live-firing should not be permitted. Any indication in Range Standing Orders or elsewhere that live-firing is permitted on Marrangaroo Training Area when the Fire Danger rating is HIGH should be rescinded. |
REC257-1538 | 32 - Doctrine, standards, and reform | Commanding Officer Defence Explosive Ordnance Training School amend relevant instructions, both generally and specifically, so as to ensure that explosive ordnance used in training serials is logged in real time, in accordance with extant doctrine. |
REC257-1549 | 32 - Doctrine, standards, and reform | Marrangaroo Training Area Range Standing Orders should be reviewed to impose a requirement that the Officer in Charge of any live-firing practice ascertain and consider current weather parameters, temperature, humidity, wind strength and direction, registered at Mt Boyce immediately prior to any demolition serial. The setting of those parameters and their limits should be decided in consulation with the Bureau of Meteorology and Rural Fire Service and inserted into Range Standing Orders. |
REC257-1554 | 32 - Doctrine, standards, and reform | All documents be reviewed to remove ambiguity and perceived inconsistencies. Marrangaroo Training Area Range Standing Orders be subject to further examination, with particular consideration of the bushfire mitigation strategies referred to in the Bushfire Management Plan 2011-2014 before amendments to Chapter 10 are made. the basis upon which Range Standing Orders might fix a cut-off point for live-firing exercises should depend on continued bushfire strategies. Range Standing orders and Marrangaroo Training Area Bushfire Management Plan be reviewed annually. if hazard reduction has not occurred or the fire trails degraded, Range Standing Orders should take into account of heightened risk. |
Rec-ID | Code | Recommendation |
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REC256-1560 | 37 - Funding | The Australian Government should: |
REC256-1569 | 32 - Doctrine, standards, and reform | The provisions in the Queensland Sustainable Planning Act 2009 for injurious affection should be repealed. |
REC256-1559 | 37 - Funding | The Australian Government should gradually increase the amount of annual mitigation funding it provides to state and territory governments to $200 million. Initially, this funding should be distributed to state and territory governments in accordance with the allocation under the National Partnership Agreement on Natural Disaster Resilience. |
REC256-1565 | 13 - Mapping and data quality | Governments should task the Australia–New Zealand Emergency Management Committee with leading the development of guidelines for the collection and dissemination of natural hazard mapping, modelling and metadata. Guidelines should be developed for all hazards that need to be modelled and mapped at the local/regional level and where consistency across regions is desirable. |
REC256-1558 | 37 - Funding | Funding to state and territory governments for community recovery should be provided as untied grants, with a transition period pending the development of a framework to assess community recovery costs. During the transition period, the Australian Government should continue to provide funding for community recovery through a reimbursement model. |
REC256-1564 | 6 - Insurance and legal liability | State and territory governments, local governments and insurers should explore opportunities for collaboration and partnerships. Partnerships, for example, could be formed through the Insurance Council of Australia and state-based local government associations (or regional organisations of councils). Consideration could be given to the Trusted Information Sharing Network model. Partnerships could involve: |
REC256-1577 | 37 - Funding | The Australian Government should develop a formula for allocating mitigation funding to state and territory governments on the basis of where such funding is likely to achieve the greatest net benefits, taking into account the future risks of natural disasters. This should be completed within five years and in consultation with state and territory governments. |
REC256-1557 | 37 - Funding | Where asset management plans at the local, state or territory level pre-identify and cost betterment of assets (improving asset resilience to natural disasters), the Australian Government should share 50 per cent of the betterment component of reconstruction costs following damage from a (eligible) natural disaster. |
REC256-1563 | 13 - Mapping and data quality | Governments at all levels should make new and currently held natural hazard data publicly available in accordance with open public sector information principles. When collecting new natural hazard data or undertaking modelling, all levels of government should: |
REC256-1574 | 32 - Doctrine, standards, and reform | The Australian Government should establish a framework for the development of benchmark prices for the reconstruction of essential public assets. This should set out the broad parameters that state and territory governments should follow, without prescribing particular prices to be used. |
REC256-1556 | 37 - Funding | The Australian Government should fund natural disaster recovery by: |
REC256-1562 | 32 - Doctrine, standards, and reform | The Australian Government should: |
REC256-1572 | 6 - Insurance and legal liability | Insurers should provide additional standardised information to households regarding their insurance policies, the natural hazards they face and indicative costs of rebuilding after a natural disaster. This work should be led by the Insurance Council of Australia developing guidelines, within one year, to ensure consistency in the provision and presentation of this information across insurers. |
Rec-ID | Code | Recommendation |
---|---|---|
REC207-2879 | 37 - Funding | Firm up approval processes and funding for any departures from provision of the basic product set |
REC207-2885 | 13 - Mapping and data quality | Increased automation and outsourcing of observations |
REC207-2877 | 37 - Funding | Explore opportunities to re-phase investments in large scale projects and programs such as the Strategic Radar Enhancement Program, the NexGen Forecast and Warning System Products and the Improving Water Information Program. |
REC207-2884 | 32 - Doctrine, standards, and reform | Focus leadership practices to re-orient culture away from customisation and experimentation and towards reliable, efficient and consistent documented processes |
REC207-2893 | 37 - Funding | Explore options to obtain revenue from advertising on the Bureau’s website |
REC207-2875 | 32 - Doctrine, standards, and reform | Agree clear allocation of responsibilities to state and local government for flood management, with defined boundaries on the Bureau’s role and: |
REC207-2883 | 32 - Doctrine, standards, and reform | Start a project to introduce organisational process thinking with a view to standardising processes and product specifications. |
REC207-2892 | 37 - Funding | Apply a consistent cost-recovery model to all services delivered to state/territory fire agencies. |
REC207-2874 | 32 - Doctrine, standards, and reform | Formalise and standardise service levels provided to emergency services. |
REC207-2881 | 17 - Assets and technology | Extend ICT governance arrangements to all applications and subject in-house development to rigorous approval processes. |
REC207-2890 | 37 - Funding | Review and rebalance relative investment in long term climate modelling and medium-term seasonal outlook. |
REC207-2880 | 32 - Doctrine, standards, and reform | Ensure the Bureau puts in place necessary planning and governance arrangements to develop its bid for capital funding to maintain its critical supercomputing capacity |
REC207-2889 | 37 - Funding | Review level of investment in research activities to free up budget and reduce pressure on computing capacity |
Rec-ID | Code | Recommendation |
---|---|---|
REC205-1905 | 6 - Insurance and legal liability | The Australian Government should only proceed with reforms that require all household insurers to offer flood cover if it can be demonstrated that the benefits to the wider community would exceed the costs. |
REC205-1895 | 32 - Doctrine, standards, and reform | Reforms to address barriers to effective climate change adaptation should be assessed on a case-by-case basis to determine whether they are likely to deliver net benefits to the community. This should include consideration of any risks to their implementation. |
REC205-1906 | 6 - Insurance and legal liability | Governments should not subsidise household or business property insurance, whether directly or by underwriting risks. |
Rec-ID | Code | Recommendation |
---|---|---|
REC189-2909 | 32 - Doctrine, standards, and reform | Equipping the regulator with a wider range of compliance tools under the legislation should continue to be a policy priority. The aim should be to enhance the regulator’s capacity to secure compliance in an appropriately graduated way. The opportunity should be taken to ensure that the regulator and inspectors can, in appropriate cases, bring proceedings that do not require referral to the Commonwealth Director of Public Prosecutions, such as actions for civil penalties or injunctions. |
REC189-2914 | 32 - Doctrine, standards, and reform | The review team recommend that: |
Rec-ID | Code | Recommendation |
---|---|---|
REC177-3308 | 32 - Doctrine, standards, and reform | Volumes of cement used in connection with barrier installation should be calculated with the assistance of a pro‐forma which records all relevant baseline data, which should be verified by onshore personnel. |
REC177-3325 | 32 - Doctrine, standards, and reform | Relevant personnel from licensees and rig operators should meet face to face to agree on, and document, well control issues/arrangements prior to commencement of drilling operations. Well control should be regarded as a so‐called SIMOP to signify its critical importance to both licensees and rig operators, and to ensure that they each take responsibility for achievement and maintenance of well control. |
REC177-3355 | 32 - Doctrine, standards, and reform | The Inquiry also supports Bills and Agostini’s recommendation: ‘…in relation to safety case development and compliance overall, that NOPSA revise its approach to interacting with operators prior to the safety case assessment process and subsequently direct more resources into its advisory functions. We further recommend that NOPSA develop and implement a formal plan for supporting and guiding each operator prior to safety case acceptance, as well as for ongoing compliance with that safety case, recognising the unique experience, capabilities and assessed risk of that operator. Each plan needs to include advice, education and liaison meetings with the operators. The plan needs to be continuously reviewed and reassessed based on the latest information, including the interaction with the operator’. |
REC177-3276 | 32 - Doctrine, standards, and reform | WOMPs should be comprehensive and freestanding, rather than an overarching document cross‐referencing many other documents (although the Inquiry also recommends a freestanding well control manual; this should be a guide to rig and onshore personnel on good oilfield practice). |
REC177-3292 | 32 - Doctrine, standards, and reform | Licensees should be subject to an express obligation to inform regulators of the proposed removal of a barrier, even if they consider that well integrity is not thereby compromised. The information should be provided by way of special report, rather than included in a standard reporting document (such as a DDR). The information provided should include risk assessment details. Removal of a barrier should not take place without prior written approval of the relevant regulator(s). |
REC177-3313 | 32 - Doctrine, standards, and reform | Barriers should not be installed or removed off‐line. The derrick should be located over a well at the time of removal and installation of any barrier. This will enable more decisive action to be taken in the event a problem arises. |
REC177-3334 | 32 - Doctrine, standards, and reform | Licensees, rig operators, and relevant third party contractors should develop well control competency standards for their key personnel. Wherever possible, the competencies of key personnel should be benchmarked against their roles and responsibilities. |
REC177-3364 | 37 - Funding | The funding arrangements that support the National Plan should be reviewed to ensure that the costs associated with both preparedness and response capability are equitably shared between the shipping and offshore petroleum industries. |
REC177-3301 | 32 - Doctrine, standards, and reform | The industry standard of two barriers should be replaced with the concept of ‘two or more barriers’ as a minimum standard. A minimum standard when operations proceed normally should never be regarded as a sufficient standard in other circumstances. |
REC177-3318 | 32 - Doctrine, standards, and reform | Manufacturers should be consulted about how to address non‐routine operational problems affecting their well control equipment. |
REC177-3342 | 32 - Doctrine, standards, and reform | Written (rather than verbal) approval from the DA (or new regulator) should be obtained before the commencement of well activities that lead to a physical change of a wellbore, other than in a true emergency situation (requiring amendment to regulation 17 of the Management of Well Operations Regulations). |
REC177-3369 | 6 - Insurance and legal liability | The obligation of companies involved in an incident to meet the full costs of monitoring and remediation should be made a condition of approval of proposals under the EPBC Act and OPGGS Act. Suitable arrangements (insurance or otherwise) need to be in place to ensure that companies have this capacity. |
REC177-3307 | 32 - Doctrine, standards, and reform | Any indication of a compromised cemented shoe which cannot be resolved with a high measure of confidence should result in the installation of additional well control barrier(s). |
REC177-3324 | 32 - Doctrine, standards, and reform | The mere fact that the rig is over the platform should not be regarded by licensees or regulators as sufficient justification for reliance on only one barrier. The default position should be that producible wells are shut‐in when a rig is moved on and off a platform, or when a drilling unit is moved between wells on a platform. |
REC177-3354 | 32 - Doctrine, standards, and reform | NOPSA develop a policy of engagement with operators so as to enable experts (including safety experts) to canvas all available options for well control in the event of a blowout. |
REC177-3275 | 32 - Doctrine, standards, and reform | Well Operations Management Plan (WOMPs) submitted by licensees to the regulator(s) should continue to be the primary framework document for achieving well integrity. |
REC177-3284 | 32 - Doctrine, standards, and reform | Memoranda of Agreement should be entered into between operators in relation to provision of emergency assistance in the event of blowouts. |
REC177-3312 | 32 - Doctrine, standards, and reform | The BOP and rig should not move from a well until barrier integrity has been verified. |
REC177-3329 | 17 - Assets and technology | Logistics management of well control equipment should be conducted in such a way as to operate as a check against deficient well control practices, for example, use of serial numbers to track availability, testing, and deployment of well control equipment. |
REC177-3363 | 32 - Doctrine, standards, and reform | DEWHA, in concert with AMSA and with expert input, should develop ‘off the shelf’ monitoring programs that can be speedily implemented following incidents in Commonwealth waters. In this context, the utility of the current Scientific Monitoring program should be peer reviewed to inform future policy. |
REC177-3300 | 32 - Doctrine, standards, and reform | Licensees and rig operators should install an additional barrier whenever (i) there is any real doubt as to the integrity of any barrier; (ii) whenever the risk of flow from a reservoir increases materially in the course of operations; and (iii) where the consequences of a blowout are grave (for example, for reef systems or shorelines). |
REC177-3317 | 32 - Doctrine, standards, and reform | Any equipment (including PCCCs) used as, or to install, a barrier should be manufactured for that purpose and be generally recognised as fit for purpose. If equipment is designed in‐house by a licensee or rig operator it should not be approved for use unless and until it is subjected to expert external analysis. |
REC177-3341 | 32 - Doctrine, standards, and reform | The definition of ‘good oilfield practice’ in the OPGGS Act is unduly narrow. The current definition is incapable of application except where things ‘are generally accepted as good and safe’. The definition should be amended such that ‘good oilfield practice includes…’. |
REC177-3368 | 32 - Doctrine, standards, and reform | The regulatory framework should provide that in respect of all activities in Commonwealth waters: |
REC177-3306 | 32 - Doctrine, standards, and reform | It should be standard industry practice to re‐test a cemented casing shoe (that is, after WOC) whenever the plugs do not bump or the float valves apparently fail. Standard industry practice should require consideration of other tests in addition to a repeat pressure test. |
REC177-3323 | 32 - Doctrine, standards, and reform | Where multiple wells are drilled, operations and occurrences at one well must be carefully assessed for any implications with respect to well control at other wells. |
REC177-3353 | 32 - Doctrine, standards, and reform | The regulatory regime should also impose an obligation on an operator to ascertain the availability, and provide details to the regulator, of any potential relief well rigs, prior to the commencement of drilling operations (including prior to each phase of a drilling operation where applicable). |
REC177-3283 | 32 - Doctrine, standards, and reform | A separate, identifiable barrier manual should be agreed upon and used by licensees, rig operators, and cementing contractors. These manuals should set out best industry practice in relation to achieving and maintaining well integrity. They should describe barrier types, barrier standards, general principles of well integrity, testing and verification methods and technologies, standard operating procedures (including procedures for the capture and communication of relevant information within and between relevant stakeholder entities). Barrier manuals should address blowout control during drilling, completion, re‐entry, tie‐back of casing strings and so on. Barrier manuals should be the subject of expert external review, and should be regularly updated. |
REC177-3311 | 32 - Doctrine, standards, and reform | Horizontal or high angle penetration of a reservoir should be avoided wherever practicable until such time as the apparent problems associated with the cementing of a casing shoe in these situations are satisfactorily overcome. If a casing string does penetrate a well horizontally or at a high angle, standard practice should be to install two secondary barriers in addition to the cemented casing shoe. |
REC177-3328 | 32 - Doctrine, standards, and reform | All communications between on‐rig and onshore personnel relating to well control should be documented in a timely manner. |
REC177-3362 | 32 - Doctrine, standards, and reform | Procedures for the approval of development projects should ensure that conditions of approval are comprehensive and clearly set out the obligations of their proponents in relation to environmental matters (including expected monitoring and remediation obligations). |
REC177-3298 | 32 - Doctrine, standards, and reform | Reliance upon one barrier against a blowout must not take place except with the prior written approval of the relevant regulator and then only in a true emergency situation (see below). |
REC177-3316 | 32 - Doctrine, standards, and reform | Wells should be re‐entered with a BOP in place unless a documented risk assessment indicates that well control can be maintained at all times. |
REC177-3340 | 32 - Doctrine, standards, and reform | To better ensure that ‘risks’ are identified and managed in accordance with sound engineering principles and good oilfield practice, it is recommended that regulation 25(1)(a)(i) and (2)(a)(i) of the Management of Well Operations Regulations, be reworded as follows: ‘A titleholder must not commence / continue a well activity if…a well integrity hazard exists in relation to the well’. |
REC177-3367 | 32 - Doctrine, standards, and reform | Procedures and accountabilities should be established to ensure, in the event of a future incident, that: |
REC177-3305 | 32 - Doctrine, standards, and reform | Cement integrity should be evaluated wherever practicable by way of cement evaluation tests, rather than relying on pre‐operational calculations of cement and displacement fluid volumes. |
REC177-3322 | 32 - Doctrine, standards, and reform | Batched drilling operations should only be undertaken after careful assessment of the special risks which such operations give rise to; well control must be maintained during the course of batched drilling operations. |
REC177-3352 | 32 - Doctrine, standards, and reform | The regulator, rather than the responsible Minister, should be given the power to direct an operator to use a particular rig for the purpose of well control operations, if appropriate in the circumstances, and the power should be used in the future if that rig is the best option available. This would necessarily involve the operator fully compensating for the use of the rig and any other associated costs. The Inquiry suggests that this power could be invoked and given effect as a condition of an operator’s licence. |
REC177-3377 | 32 - Doctrine, standards, and reform | The Minister consider legislative amendments to the OPGGS Act which make clear that |
REC177-3280 | 32 - Doctrine, standards, and reform | Well construction and management plans should include provision for an independent compliance review of well integrity (i) in the event of stipulated triggers; and (ii) at least once in the period between perceived achievement of well integrity and production. The independent compliance review should be undertaken by an expert who is not involved in the day‐to‐day drilling operations. Reviews should be completed in sufficient time to enable results to be implemented in a meaningful manner. |
REC177-3310 | 6 - Insurance and legal liability | Consideration should be given to ways to ensure that contractors who are involved in barrier installation (such as cementing companies) have a direct interest in the performance of works to a proper standard. In particular, consideration should be given to (i) preventing contractors from avoiding the economic consequences of negligent installation of barriers; and/or (ii) imposing specific legislative standards of workmanship on contractors with respect to well control (similar to those which presently apply to licensees). |
REC177-3327 | 32 - Doctrine, standards, and reform | Information relevant to well control must be captured and communicated within and between licensees and rig operators (and relevant third party contractors), in a manner which ensures it comes to the attention of relevant personnel. In particular, protocols should be developed to ensure that changes in shift and hitch do not operate as communication barriers. |
REC177-3361 | 32 - Doctrine, standards, and reform | The National Plan should be revised to ensure that it fully comprehends environmental matters and that it recognises the importance of the prompt implementation of Scientific Monitoring to facilitate the assessment of the environmental impacts of an incident. |
REC177-3297 | 32 - Doctrine, standards, and reform | A minimum of two barriers should be in place at all times (including during batched operations) whenever it is reasonably practicable to do so. |
REC177-3315 | 32 - Doctrine, standards, and reform | PCCCs should be installed in a timely manner (for example, to prevent corrosion in the MLS apparatus). Non‐installation in order to park a BOP is not acceptable. |
REC177-3339 | 32 - Doctrine, standards, and reform | The Inquiry supports the objective (rather than prescriptive) approach to regulation now followed in Australia. However, the pendulum has swung too far away from prescriptive standards. In some areas relating to well integrity there needs to be minimum standards. |
REC177-3366 | 32 - Doctrine, standards, and reform | The National Plan should be reviewed: |
REC177-3304 | 26 - Research | It is recommended that industry, regulators, and training/research institutions liaise with one another with a view to developing better techniques for testing and verifying the integrity of cemented casing shoes as barriers (particularly in atypical situations such as where the casing shoe is located within a reservoir in a horizontal or high angle position at great depth). |
REC177-3320 | 32 - Doctrine, standards, and reform | Any pro‐formas used by licensees, rig operators and contractors for recording information about installation of barriers should explicitly provide for ‘exception reporting’, that is, the form should include provision for recording any unforseen or untoward events which occur in the course of installation. |
REC177-3350 | 32 - Doctrine, standards, and reform | The recommendations of the Inquiry in relation to suitable ways of achieving well integrity contained in Chapter 3 be included in a guidance manual that is issued for the assistance of industry and regulators. |
REC177-3373 | 32 - Doctrine, standards, and reform | Arrangements should be developed to minimise duplication between the EPBC Act and the OPGSS Act Environment Regulation. |
REC177-3277 | 32 - Doctrine, standards, and reform | The concept of ‘good oilfield practice’ should be supplemented by the requirement to incorporate into WOMPs non‐exhaustive minimum compliance standards in relation to well control: for example, stipulations as to when BOPs and/or well control systems must be in place and when they can be removed and minimum barrier requirements (a number of other factors that should be stipulated are outlined in other recommendations below). |
REC177-3309 | 32 - Doctrine, standards, and reform | If performance of barrier installation is outsourced by a licensee, the contractor (for example, the cementing company) should be engaged on terms which clearly require the provision of expert advisory services by the contractor with respect to barrier integrity. |
REC177-3326 | 32 - Doctrine, standards, and reform | Prior to commencement of drilling operations, senior representatives of the licensee and rig operator should exchange certificates to the effect that their respective key personnel and contractors have been informed in writing of agreed well control arrangements. |
REC177-3359 | 32 - Doctrine, standards, and reform | The National Plan should be reviewed to clarify the arrangements to apply in Commonwealth waters regarding key roles and responsibilities, including in relation to the ESC, in the event of an oil spill. This should also address any necessary training required. |
REC177-3296 | 32 - Doctrine, standards, and reform | Use of single strings of intermediate casing to penetrate hydrocarbon bearing zones should be carefully risk assessed. Multiple strings of intermediate casing have the advantage of isolating lost circulation zones and sealing off anomalous pressure zones. If intermediate casing is set in a hydrocarbon zone it should be treated as production casing. |
REC177-3314 | 32 - Doctrine, standards, and reform | Secondary barriers (including PCCCs) should only be installed, tested, and removed with a BOP in place unless a documented risk assessment indicates that well control can be maintained at all times. |
REC177-3335 | 32 - Doctrine, standards, and reform | Licensees, rig operators and relevant third party contractors should develop well control competency standards for key personnel in other entities involved in well control operations. |
REC177-3365 | 6 - Insurance and legal liability | The National Plan should specify that the cost of responding to an oil spill, or other damage to the offshore marine environment, will be totally met by the owner/operator. This would be consistent with the Inquiry’s recommendation for legislative changes to the regulatory framework concerning owner/operators meeting the cost of monitoring and remediation of environmental damage. |
REC177-3302 | 32 - Doctrine, standards, and reform | Industry, regulators, and training/research institutions should develop standards that address best practices for cementing operations (including liaising, as appropriate, with overseas regulators) with a view to overcoming problems which can effect the integrity of cemented casing shoes, annulus and cement plugs. |
REC177-3319 | 32 - Doctrine, standards, and reform | Drilling programs dealing with barrier installation should incorporate relevant aspects of manufacturer’s instructions. |
REC177-3343 | 32 - Doctrine, standards, and reform | The OPGGS Act should be amended to allow for a power to suspend a petroleum production licence (in addition to the current power to cancel a licence or suspend its conditions). |
REC177-3370 | 32 - Doctrine, standards, and reform | Environment plans and OSCPs should be made publicly available as a condition of approval of proposals under the OPGGS Act, and should clearly set out Scientific Monitoring requirements in the event of an oil spill. |
Rec-ID | Code | Recommendation |
---|---|---|
REC161-3027 | 32 - Doctrine, standards, and reform | That powers should be conferred on National Offshore Petroleum Safety Authority to enable it to effectively regulate safety and integrity for all facilities and pipelines in the water and the WA islands which export gas by pipeline. National Offshore Petroleum Safety Authority’s authority should extend to the nearest valve on the mainland above the shore crossing. |
REC161-3036 | 32 - Doctrine, standards, and reform | That the Commonwealth and States/Northern Territory legislate to establish a properly resourced and empowered independent national safety investigation capacity to investigate serious oil and gas industry (including pipeline) incidents including near miss events that could have led to a major accident event. We further recommend that the regulatory investigatory powers under the Offshore Petroleum and Greenhouse Gas Storage Act 2006 be reviewed in the context of powers for the proposed independent national safety investigator, noting that the regulator must retain those investigatory powers necessary in order to fulfil its legislative functions. |
REC161-3026 | 32 - Doctrine, standards, and reform | That the Commonwealth consider a plain English rewrite of the Navigation Act 1912 with the aim of producing a modern, performance-based Act. |
REC161-3033 | 32 - Doctrine, standards, and reform | That the Commonwealth Petroleum (Submerged Lands) (Management of Safety on Offshore Facilities) Regulations 1996 regulations be amended to explicitly enable assessment of safety culture, leadership, and consideration of operator past history, motivation and current capacity in approvals of safety cases. National Offshore Petroleum Safety Authority should be able to audit against these criteria and challenge operators on these issues. |
REC161-3040 | 32 - Doctrine, standards, and reform | We recommend the Commonwealth consider a plain English rewrite of the Navigation Act 1912 with the aim of producing a modern, performance-based Act. |
REC161-3025 | 32 - Doctrine, standards, and reform | That Australian Maritime Safety Authority should have a role in assuring continuing marine standards that are not inconsistent with Offshore Petroleum and Greenhouse Gas Storage Act 2006 provisions and that Australian Maritime Safety Authority needs defined powers to assist National Offshore Petroleum Safety Authority (NOPSA) in minimising risk in the offshore petroleum industry. Potential mechanisms for achieving this outcome include: providing Australian Maritime Safety Authority with defined powers and obligations under the Offshore Petroleum and Greenhouse Gas Storage Act 2006, thereby ensuring that the Authority becomes an effective inspector/regulator of vessels while they are deemed to be facilities; or revising the current Commonwealth maritime legislation disapplication provisions of the Offshore Petroleum and Greenhouse Gas Storage Act 2006 with the aim of achieving the same goal. If it can be readily achieved and is an efficient regulatory option, we believe the first option is preferable. |
REC161-3032 | 32 - Doctrine, standards, and reform | That the Offshore Petroleum and Greenhouse Gas Storage Act 2006 and its subsidiary regulations be amended to enable National Offshore Petroleum Safety Authority to have a broader range of graduated compliance tools including the ability to impose a civil fine on an operator per day of non compliance with an improvement or prohibition notice. Legislation should also be considered that would enable National Offshore Petroleum Safety Authority to make public, with appropriate safeguards, specific information concerning its enforcement actions including the name of the operator, the breach, and the enforcement action required including potential penalties. |
REC161-3039 | 32 - Doctrine, standards, and reform | We recommend that AMSA should have a role in assuring continuing marine standards that are not inconsistent with Offshore Petroleum and Greenhouse Gas Storage Act (OPGGS) Act provisions and that AMSA needs defined powers to assist NOPSA in minimising risk in the offshore petroleum industry. Potential mechanisms for achieving this outcome include: providing AMSA with defined powers and obligations under the OPGGS Act, thereby ensuring that the Authority becomes an effective inspector/regulator of vessels while they are deemed to be facilities; or revising the current Commonwealth maritime legislation disapplication provisions of the OPGGS Act with the aim of achieving the same goal. If it can be readily achieved and is an efficient regulatory option, we believe the first option is preferable. |
REC161-3024 | 32 - Doctrine, standards, and reform | That the Commonwealth Petroleum (Submerged Lands) (Management of Safety on Offshore Facilities) Regulations 1996 Regulations be amended to ensure that the safety case for a floating facility specifically identifies when command structure changes occur (which may be well before departing the site and associated zone). We also recommend that the Offshore Petroleum and Greenhouse Gas Storage Act 2006 be amended so that a vessel becomes a facility when any part of it comes within 500 metres of the site and continues to be a facility until no part of the |
REC161-3031 | 32 - Doctrine, standards, and reform | That National Offshore Petroleum Safety Authority develop a robust risk assessment matrix for use in assessing and responding to the changing risk associated with each facility and the operator. Further, we recommend that National Offshore Petroleum Safety Authority increase auditing frequency and duration to audit each manned facility on average twice per year (covering each staff swing), but more often if the risk matrix indicates this is necessary; and that audits should average several days actually on major facilities. |
REC161-3038 | 32 - Doctrine, standards, and reform | We recommend that the Commonwealth Petroleum (Submerged Lands) (Management of Safety on Offshore Facilities) Regulations (MOSO) be amended to ensure that the safety case for a floating facility specifically identifies when command structure changes occur (which may be well before departing the site and associated zone). We also recommend that the OPGGS Act be amended so that a vessel becomes a facility when any part of it comes within 500 metres of the site and continues to be a facility until no part of the vessel remains within 500 metres of the site. |
REC161-3023 | 32 - Doctrine, standards, and reform | That the Commonwealth undertake legislative change that will ensure that when any floating facility reverts to a ‘navigable form’, the relevant provisions of the Navigation Act and the OHSMI Act will apply regardless of any voyage criteria. This will help to ensure that all Australian seafarers are covered. |
REC161-3029 | 32 - Doctrine, standards, and reform | In relation to safety case development and compliance overall, that National Offshore Petroleum Safety Authority revise its approach to interacting with operators prior to the safety case assessment process and subsequently and direct more resources into its advisory functions. We further recommend that National Offshore Petroleum Safety Authority develop and implement a formal plan for supporting and guiding each operator prior to safety case acceptance, as well as for ongoing compliance with that safety case, recognising the unique experience, capabilities and assessed risk of that operator. Each plan needs to include advice, education and liaison meetings with the operators. The plan needs to be continuously reviewed and reassessed based on latest information, including the interaction with the operator. Implementation should be reviewed at a senior level within National Offshore Petroleum Safety Authority. |
REC161-3037 | 32 - Doctrine, standards, and reform | We recommend that the Commonwealth undertake legislative change that will ensure that when any floating facility reverts to a ‘navigable form’, the relevant provisions of the Navigation Act and the OHSMI Act will apply regardless of any voyage criteria. This will help to ensure that all Australian seafarers are covered. |
Rec-ID | Code | Recommendation |
---|---|---|
REC149-3129 | 32 - Doctrine, standards, and reform | The consequences of the disapplication of the Navigation Act 1912 should be analysed, the actual consequences identified and unintended consequences addressed. |
REC149-3141 | 32 - Doctrine, standards, and reform | NOPSA should complete the next revision of Safety Case guidelines in consultation and agreement with stakeholders and continue its program to achieve consistency with a firmer hand from the CEO and management. |
REC149-3140 | 32 - Doctrine, standards, and reform | The industry should provide advice to NOPSA on where the regulations do not provide sufficient clarity and consider developing broad policy/process guidelines in consultation with the regulator to provide clarity and consistency. Regulators should not take personal views or preferences. |
REC149-3134 | 32 - Doctrine, standards, and reform | Improved and agreed guidelines for Safety Case application and assessment, including suggested structure and content, would alleviate many current problems related to Safety Case processes. |
REC149-3130 | 32 - Doctrine, standards, and reform | The regulations pertaining to vessels of opportunity or their interpretation should be changed to facilitate a risk based approach to regulation. This approach will be consistent with the approach taken in other jurisdictions. |
Rec-ID | Code | Recommendation |
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REC118-3642 | 26 - Research | Establish a Regional Centre of Excellence for Tsunamis to focus Australian and international science/research and collaboration on the challenge of understanding tsunamis and mitigating their consequences. |