Safety Alternatives for Owners and Operators of Regulated Equipment
An alternative safety approach (ASA) is an innovative way of achieving safety that is acceptable under the Safety Standards Act (SSA). It is an approach that gives owners and operators of regulated equipment flexibility in managing safety. The approach treats safety as an integrated whole instead of simply complying with a series of prescriptive requirements. ASAs enable innovations in technology and work practices within a structured and controlled regulatory environment.
ASA agreements provide a variance to existing regulations, codes or standards, when a safety management system or plan is proposed detailing alternative methods to achieving an equivalent or superior level of safety. Such plans or systems are then used as the framework for regulatory assessment and compliance. Unlike all other regulations within the SSA, the adoption of an ASA is optional.
An ASA Agreement can only be held by the owner-operator but it can be structured to offer alternative approaches in any or all phases of a project, from design and manufacturing, through to construction, installation, and/or operation.
There are two options available under the Alternative Safety Approaches Regulation:
- An Equivalent Standard Approach (ESA) which usually applies to one aspect of an installation or operation.
- A Safety Management Plan (SMP) which is a broader approach and can apply to the safety of an entire facility.
Each instrument type is suitable to varying scopes of alternatives, which are further detailed and explained in the ASA manuals located in the green box on the right side of this page.
Why our clients are choosing Alternative Safety Approaches:
- Administrative process alternatives
- Harmonization of international codes and standards, and/or of their own technical standards and operating procedures held in other regulatory jurisdictions
- Equipment certification alternatives
- Alternatives to prescribed worker qualifications
Submitting an ASA
If you wish to submit an alternative safety approaches application, please be prepared to demonstrate that your alternative meets or exceeds the objectives of the prescribed regulations, codes or standards within the SSA. Given the varying scopes and magnitude of possible alternatives, there is no standard template for an ASA proposal.
Typically, an ASA can be developed by itemizing the regulatory sections, codes or standards, which are being suggested for “exemption”, and offering a well articulated and auditable proposal for alternatives which will meet or exceed the required safety outcomes of the Act. ASA Guidance documents are provided to help you better understand and structure your proposal for application.
Alternative Safety Approaches Application Submission Process
Please follow these steps if you are submitting an Alternative Safety Approaches application package:
- Decide if you are submitting an Equivalent Standard Approach* or a Safety Management Plan** Approach. The Alternative Safety Approaches Process Overview (MAN 4035-03) document will guide you in deciding which approach best suits your needs.
- Once you have decided on the approach, review the Alternative Safety Approaches Safety Management Plan Application Guide (MAN 4034-02)when completing Alternative Safety Approaches Application Form (FRM-1356-00).
*Note: If you are submitting an Equivalent Standard Approach, please refer to the Alternative Safety Approaches Equivalent Standard Approach Application Guide (MAN 4042-01) document.
**Note: If you are submitting a Safety Management Plan, please refer to the Alternative Safety Approaches Safety Management Plan Guide (MAN 4032-00) document.
The timing required to process an ASA application depends on the the scope and nature of the desired alternative(s). Accordingly, we recommend you contact us for a meeting to introduce your project as early as possible.