Brunei regulator puts Human Factors in the spotlight

02 April 2014

By Charles Schalkwyk

The inclusion of Human Factors as part of the new Control of Major Accident Hazards (COMAH) Regulations in Brunei could bring about a step change in safety management for a number of oil and gas companies in the country. The regulations which came into force in Brunei on 1 January 2014, include a key workforce element - notably a requirement to focus on Safety Critical Tasks (SCTs) to ensure the right processes are in place to reduce the risk of major accidents. 

Against a backdrop of major onshore and offshore oil and gas activity, the regulations introduce a new safety case regime as part of efforts to reduce the risks of harm to people and facilities from major accident hazards. They apply where there are large quantities of hazardous substances or where drilling operations (for hazardous substances) are taking place.

This emphasis on Human Factors means that the safety case will identify the safety critical elements (SCEs) and include the role played by SCTs and procedures.  This is in sharp contrast to the former requirement of simply presenting an argument for how safety critical equipment should be managed. SCTs, Safety Critical Procedures (SCPs) and Safety Critical Personnel (SCPe) all now have to be included as part of the safety case. Human Factors and, indeed, the requirement for a Human Factors specialist, are very much part of the equation.

The regulations apply to both the onshore and the offshore oil and gas industry in Brunei, including the downstream petrochemical industry. They also cover various types of hazardous substances and thus will apply to other processing industries in the future.  The safety case document itself is only part of the story. COMAH places a legal requirement on a company to ensure that the procedures and arrangements described in the current safety case are followed.

For further information on any of the above issues please contact Charles Schalkwyk.

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