State of Safety: Alternative Safety Approaches
The Alternative Safety Approaches (ASA) program offers flexibility to owners or operators of regulated equipment in how they manage safety. Owners or operators are empowered to create a written plan, detailing how they will undertake regulated work or use regulated products differently than in prescribed regulations, that is consistent with safety objectives in the Safety Standards Act and associated regulations.
Auditors and safety officers ensure clients are meeting requirements within the Safety Standards Act, associated regulations, and the approved ASA plan. In all cases, clients must demonstrate that their proposed alternatives will achieve an equivalent (or better) level of safety as compared to prescriptive regulations.
Audit in Action
In 2022, our ASA team performed an audit at the BC operations of one of the largest energy companies in the world. This company has five Safety Management Plans (SMPs) with Technical Safety BC under the electrical technology and the boilers, pressure vessels and refrigeration technology. The audit was performed in Fort St. John and found that the client’s performance was generally effective. The audit resulted in some items requiring correction and opportunities to help the client improve their SMPs. These included:
- 4 low-risk non-compliances (related to regulation requirements)
- 3 low-risk non-conformances (related to requirements of their SMPs)
- 10 opportunities for improvement (continuous improvement to their SMPs)
Since the audit, the client has confirmed that all identified issues have been addressed and provided us with an action plan to complete the correction of the audit findings.
"Clients must demonstrate that their proposed alternatives will achieve an equivalent (or better) level of safety as compared to prescriptive regulations."
Types of Alternative Safety Approaches
We accept two types of ASA:
An Equivalent Standard Approach (ESA)
This typically involves only one technology and requires a “like-for-like” substitution of prescriptive regulatory requirements with an alternate regulation or code to provide an equivalent level of safety.
A Safety Management Plan (SMP)
This may include multiple technologies and involve the replacement of specified prescriptive regulatory requirements with detailed, comprehensive safety management systems. An SMP is mandatory for exemptions related to permitting, licensing, or qualification requirements.
We currently manage 14 Safety Management Plans (SMP) and 29 Equivalent Standard Approaches (ESA).
Sectors that currently take part in the ASA program include:
- Oil and gas
- Liquified Natural Gas (LNG)
- Electrical generation
- Public institutions (e.g. schools and recreation centers)
Clients in the ASA program take on increased responsibility for the safety of their regulated equipment and regulated work performed by employees and contractors.
We monitor the implementation of ASA through a variety of oversight tools to assess client performance and the effectiveness of an ASA program. ASA audits and site inspections form a major part of our oversight to confirm that the client is maintaining their plan in compliance with regulations, and that they are proactive about safety.
Two types of audits are performed by the ASA program:
- Registration audits are performed to assess a client's readiness to implement their alternative safety approach.
- Conformance audits are performed to assess the degree to which a client is effective in implementing the alternative safety approach.
Audit findings for sites operating with an accepted ASA are rated according to the following:
Processes and/or controls are adequate, appropriate, and effective to provide reasonable assurance that risks are being managed.
Effective, Except For
Processes and/or controls are adequate, appropriate, and effective to provide reasonable assurance that risks are being managed, however, there are deficiencies that need to be addressed by management.
Processes and/or controls are adequate, appropriate, and effective to provide reasonable assurance that risks are being managed. There are a number of critical and high-risk deficiencies that need to be addressed by management. These deficiencies have a significant impact on operations.
2022 ASA Audit Results
In all cases, clients must address all identified non-compliances as required and documented in the audit report.
The timeframe for correction depends on the as-found hazard rating of each identified non-compliance.