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. This approach looks at safety as an integrated system instead of prioritizing compliance with prescriptive regulatory requirements.

Owners or operators are empowered to create a written ASA plan, detailing how they will undertake regulated work or use regulated products, that is consistent with safety objectives in the Safety Standards Act and associated regulations.

In all cases, clients must demonstrate that their proposed alternatives will achieve an equivalent (or better) level of safety as compared to prescriptive regulations. Auditors and safety officers confirm whether clients are meeting requirements within the Safety Standards Act, associated regulations, and the approved ASA plan.

We accept two types of alternative safety approaches: an Equivalent Standard Approach (ESA) and a Safety Management Plan (SMP). Learn more about these approaches and the industry sectors that take part in this program.

Audit in Action

In a corporate environment, employee and personnel changes can have organizational impact, but when it comes to companies that use regulated equipment, it can also affect safety. An example can be seen from one of our clients, an experienced ASA holder in the gas and oil sector.

We conducted an audit following a review of the client’s annual report, where it was revealed that the ASA Administrative Authorized Representative had left the company after a restructuring. A change of representative was recognized as a substantial safety risk in the annual ASA risk-based assessment of the client program.

While the representative was replaced temporarily, the required change notification was not reported to the ASA team as required under the terms and conditions of the ESA. A full conformance audit with on-site field verification inspections was performed within three months of learning about the representative change.

During the audit, we identified that the vacant administrative role was not adequately managed. The company representatives at the audit were unaware of its ASA or required processes, including the requirement to have both a technical and administrative representative. The audit found that the ASA Technical Authorized Representative remained consistent and was tasked to maintain the day-to-day safety integrity of the company assets. However, the company did not have personnel designated as the Administrative Authorized Representative to manage the duties of document reviews, planning, financing, administering training and safety programs, staffing and contractor reviews.

Because of this safety gap, the audit resulted in a rating of “not effective.” The client has since submitted a corrective action plan, developed a process for correction, and expressed appreciation for the audit process and the identification of safety issues.

As the ASA program risk-based assessment model requires that a full conformance audit be performed within 12 months for any audit with a “not effective” rating, we will be reaching out to ensure the client has fully corrected the identified issues. We will also review the client’s performance when its next annual report is submitted to the ASA Safety Manager and arrange a follow-up conformance audit within the one-year period.