27/11/17 27/11/17

Update on Victoria’s Energy Safety Framework Review

On 19 January 2017, the Minister for Energy, Environment and Climate Change announced an independent review of Victoria’s Electricity Network Safety Framework, to be chaired by Dr Paul Grimes. On 5 May 2017, the Minister announced an expansion to the Review's Terms of Reference to include Victoria’s gas network safety framework.The interim report was released in October and can be viewed at: https://engage.vic.gov.au/application/files/6915/0942/0613/Interim_Report_-_Review_of_Victorias_Electricity_and_Gas_Network_Safety_Framework.pdfR2A provided submissions for both gas and electrical safety which have previously been blogged at:

From R2A’s reading of the interim report, the primary recommendation is that there should be a single piece of energy safety legislation that covers electricity, gas and pipelines, all to be administered by a single agency, Energy Safe Victoria.Pleasingly, from R2A’s perspective, the decision making criteria for safety should be consistent with that of the 2004 OHS act, that is, a precautionary approach that uses the SFAIRP principle rather than an ALARP principle using target levels of risk.In coming to this view Dr Grimes comments favourably on the R2A understanding of issues involved. He notes that R2A in its submission to the Review expressed a view that there needs to be clarity and consistency around the question of what constitutes “ reasonably practicable ” and, in addition, the language that is adopted to express the objective of the safety framework.

Nevertheless, the methodological distinction between the target risk and a precaution based approaches, and the other important practical implications identified by R2A, are highly relevant to the Review’s consideration and have helped inform its assessment of leading practice. (footnote on page 72)

Dr Grimes concludes that:

The Review is persuaded by the arguments that a pure target risk approach, while having some theoretical elegance, is less robust in practice than a precaution - based approach…(page 73) … the Review is proposing a draft recommendation that this definition be formally adopted for electricity and gas network safety.

The R2A Board considers the adoption of the precaution based approach to be an outstanding outcome and congratulates Dr Grimes on his acuity.The cutoff date for comment on the interim report of the Review of Victoria’s Electricity and Gas Network Safety Framework is the 27^th November.

13/3/17 13/3/17

Powerline Bushfire Safety Committee

Gaye recently attended the second meeting of the Powerline Bushfire Safety Committee (PBSC) at Energy Safe Victoria (ESV).As set out in the Committee Charter, the purpose of the PBSC is to provide the Director of Energy Safety (DoES) with comprehensive expert advice to support ESV in its administration of the Electricity Safety (Bushfire Mitigation) Amendment Regulations 2016 (the regulations) and any advice ESV may, in turn, provide government on further policy changes that may be required in the light of initial network experience implementing the regulations.In addressing its purpose, the PBSC will have regard to the regulations, the regulatory impact statement (RIS) including the target fire risk reduction benefits set out herein, and the statement of reasons (SoR).The objective of the PBSC is to provide transparent, independent oversight and advice to ESV in undertaking its regulatory responsibilities to hold the distribution business accountable for the delivery of the fire reduction benefits implicit in the regulations.Gaye’s role is to provide risk management and best practice advice. All documents relating to the Committee’s activities can be found on the ESV website.

7/12/16 7/12/16

Problems and Solutions: The Power of Perspective

Imagine you have a great idea. Perhaps it’s for a start-up venture. Perhaps it’s a new, better way of doing something at your workplace. Perhaps it’s changing the way your business has always done something. Perhaps it’s a substantial capital works project.Each of these will require a business case to convince stakeholders that your idea is, in fact, great, and ought to be implemented. Key aspects considered and explained should include:

what the good idea is
how it fits into the current market or organisation
the benefits it will bring
the upfront and ongoing costs that it will entail
the risks the proposed course of action will carry
what will be done to address these risks

These points can be separated into the three elements of any good business case: the ‘what’, the cost-benefit analysis, and the risk management strategy. The effort and detail required to prepare a convincing business case will vary depending on the idea, but it is unlikely to gain stakeholder acceptance without these three key elements.The ‘what’ and the cost-benefit analysis are generally well understood. However, business case risk management strategies are often difficult to interpret for readers. When you consider that those reading a business case will likely be those deciding if your (great) idea is accepted, the benefit of a clear and concise risk management strategy becomes obvious.So, what does a clear and concise risk management strategy involve? How can one best be prepared and presented? And how can it be made convincing as part of a business case?

Perspectives

The essence of a convincing risk management strategy is emphatically not a statement of “here are the risks, and here is what we will do about them so we don’t think they will happen.”This is, essentially, a list of problems. When deciding on a new course of action as a start-up, a small business or a large organisation, a list of problems in a business case will not give decision-makers confidence.This is especially the case if, as proposed by AS31000 (the Australian Standard for risk management), the goal of the risk management strategy is to ensure risks are ‘tolerable’, which generally means they are unlikely to occur. This argument to unlikelihood is particularly unconvincing if a decision-maker asks “I accept that this risk is unlikely, but what if it happens?”A clearer and more convincing approach is to present a case that states “here are the critical issues, here is why we don’t believe any have been overlooked, and here is why we believe all reasonable measures are in place to address them.”This approach takes a solution (rather than hazard) based approach. A hazard-based approach typically identifies many specific problems and puts them in a list, before thinking of things to do about them. Its perspective is “here’s what could go wrong with my great idea, and here’s why I don’t think it will.”This approach tends to focus on problems and their complexity, going into detailed, oft-impenetrable risk analysis, making it difficult for senior decision-makers to fully comprehend due to the specialist skill-sets required. Problems are often taken out of context for the organisation, and measures identified for each problem tend to be specific to each problem and as such hard to justify. It creates analysis paralysis.A solution-based approach, by contrast, begins by looking at what measures are in place in similar situations, and what further measures might be needed for this specific context. It is actually an options analysis and provides the case for action. Its perspective is "here’s what we should have in place to be confident going ahead with my great idea.”This shift from problems to solutions is key to presenting a convincing business case. It pushes the focus to the way forward, and takes an overarching, holistic viewpoint, making recommendations clearly explicable to senior decision-makers. It ensures the organisation’s context is always considered, and identifies a smaller number of solutions that address multiple potential issues, with a focus on implementing recognised good practice rather than presenting unnecessarily detailed analysis.Where needed, this approach can still generate the level of detail required for budget contingency estimation (e.g. through Monte Carlo simulation). However, it ensures that this detail remains contextually sound, and is only provided where beneficial to decision-making.This approach is also simpler, faster, more efficient, often cheaper, and certainly more defensible if something does go wrong. They provide an argument as to why decisions are diligent, rather than why they are ‘right.’ In short, a solution-based approach provides a far superior decision basis than a hazard-based approach. And that’s something that any business case should aim for.

This article first appeared on Sourceable.

25/11/15 25/11/15

Hazards Fester whilst Precautions Boil

One of the most interesting aspects of the precautionary approach to safety risk is that innovation is encouraged, whilst with the hazard based approach using tolerable or acceptable risk levels, innovation falters and festers.

The reason is simple. Having demonstrated that an acceptable target level of risk or safety has been achieved, annual safety reviews become a chest beating exercise to show why the previous analysis was numerically in error, and that, as a consequence, more needs to be done. If this can’t be demonstrated, then the review becomes a repeat of prior work, which on the 5^th or 6^th iteration becomes quite meaningless and completely alienating to the workforce.

On the other hand the precautionary approach always tests for what else can be done. It keeps testing and changing and innovating. It looks for the application of new technology and work methods to improve things. It engages those at risk and keeps the safety message on the boil. It reinforces the fact that safety precautions are there for a single purpose – to save those around you from death and maiming.