5. Case studies: How regulators in Ireland, Mexico, and Oman currently address safety culture and behavioural biases

This chapter presents case studies from Ireland, Mexico and Oman that were prepared as part of the scoping work presented in Chapter 4. These seek to help understand more clearly the country’s regulatory context and identify some of the behavioural barriers present to inform the future experimental design.

    

Culture influences the decisions and behaviours of people in an organisation, and these behaviours ultimately drive safety outcomes and performance. Creating a safety culture entails changing the organisation’s norms, practices, competencies leading to a sustainable change in attitudes and behaviours towards safety. While there is a clear recognition that changing attitudes and behaviours towards safety is essential to avoid high consequence incidents, ‘how to do it’ poses a number of challenges, including biases, gaps and blind spots that originate in individuals’ cognitive capacities and then permeates the practices and decision-processes of organisations.

This chapter presents a series of case studies on the role, approach and issues in fostering a safety culture faced by:1

• Ireland’s Commission for Regulation of Utilities: electrical contractors, gas installers, gas supply, shipping, transportation and storage and upstream petroleum extraction and exploration activities;

• Mexico’s Agency for Safety, Energy and Environment: hydrocarbon sector (from upstream to downstream)

• Oman’s Authority for Electricity Regulation: electricity

The case studies were prepared as part of the scoping work presented in Chapter 3, and built on public sources and information provided by the five agencies. They identified key behavioural barriers to creating a safety culture and served as a basis to start designing experiments around behavioural barriers and solutions to safety culture.

This chapter first presents an overview of the key behavioural barriers identified, and then presents the each country’s case study. This chapter and Chapter 3 then combined to form the basis for the safety culture experiments conducted and presented in Chapter 4.

Key behavioural barriers identified through the case studies

The case studies highlighted a common recognition of the importance of creating a safety culture to ensure compliance and minimise the risk of accidents. They also stressed the challenges in fostering a safety culture through the methods and approaches of the regulator and the regulated entities.

The case studies suggest the importance of the approach to safety from the regulator to the regulated entities, including through the way in which the regulator oversees and communicates on safety with the regulated business and operators (inside the regulator). Key barriers to foster a safety oversight culture emerging from the case studies include:

• Framing: deeper understanding of the importance of safety can be undermined by inconsistency/contradictions in messaging.

• Saliency: the diversity of regulators involved in safety added to a focus on compliance with procedures rather than results can reduce effectiveness and saliency of communication;

• Overseeing/indicators: a challenge is to identify indicators that promote reporting of risks and possible hazards and track the emergence of a culture among leadership and staff. Heavy reliance on occurrence data models or subsectors with under-developed data collection systems can create blind spots.

Ultimately, however, the emergence of a safety culture depends on the extent to which safety is embraced as a key feature of the organisational culture of regulated entities (outside the regulator). The case studies stress a number of challenges and behavioural barriers in creating such an organisational culture:

• Leadership commitment: it is recognised as crucial in fostering a cultural change in organisations. Production pressures, poor internal communication and (false) perception that safety is just an extra cost all undermine safety leadership.

• Complacency: this can be significant when an operator has faced no major incident for a number of years. It can be linked to a (misleading) belief that this is the result of robust systems or of the use of new or established technologies that, because their use is widespread, must ensure safety.

• Information bias: staff can underestimate how certain actions or failure to take action can impact safety.

• Lack of clarity on roles and responsibilities for safety performance: this can include little attention for who is authorised to operate or test certain activities, or who has the authority to issue or cancel such permissions.

Ireland’s Commission for Regulation of Utilities

This section provides an overview of the role, approach and issues faced by the Commission for Regulation of Utilities (CRU) in fostering a safety culture in the sectors it oversees. The purpose is to identify key behavioural barriers to creating a safety culture and methods and approaches identified by regulators to tackle these barriers. This section draws on information provided by CRU as well as Driving Performance at Ireland’s Commission for Regulation of Utilities (OECD, 2018[1]).

Overall role and institutional set-up

The CRU is an independent multi-sector regulator with economic, customer and safety functions and duties in Ireland’s energy and water sectors. It was initially established as the Commission for Electricity Regulation (CER) by the Electricity Regulation Act, 1999; however, as its mandate increased, the Commission updated its name to become the Commission for Energy Regulation (CRU) in 2017. The CRU’s mission is “Protecting the public interest in water, energy and energy safety”.

The CRU operates in the framework of a Strategic Plan (2019-2021) that sets the following strategic priorities (CRU, 2019[2]):

• Deliver sustainable, low-carbon solutions with well-regulated markets and networks

• Ensure compliance and accountability through best regulatory practice

• Develop effective communications to support customers and the regulatory process

• Foster and maintain a high-performance culture and organisation to achieve our vision.

The CRU falls under the aegis of two line Ministries, the Department of Communications, Climate Action and Environment (DCCAE) and the Department of Housing, Planning and Local Government (DHPLG). Commissioners are appointed by the Minister. The Chair of the Commission is selected by the Minister from the serving Commissioners on a rotating basis for a period of typically two to three years, but there is no prescribed term for this (OECD, 2018[1]) .

Safety responsibilities

The primary focus of the CRU’s safety responsibilities is the protection of the public in three sectors: i) upstream petroleum activities; ii) natural gas and liquid petroleum gas (LPG) undertakings; iii) gas installers (CER, 2016[3]) and electrical contractors (CER, 2016[4]) carrying out domestic gas and electrical works.

Key functions include:

• Regulating gas network safety including gas shipping/supply, storage, transmission and distribution;

• Regulating petroleum (oil and gas) safety, including exploration, extraction and decommissioning (onshore and offshore);

• Designing and overseeing safety supervisory schemes for electrical contractors and gas installers;

• Setting programmes of audit and inspection of regulated entities;

• Issuing safety permits for petroleum activities and safety licences to LPG undertakings;

• Promoting and raising public awareness of electrical and gas safety issues.

Upstream petroleum activities

CRU has been responsible for the safety of both onshore and offshore petroleum activities focusing on major accident hazards within a Petroleum Safety Framework (CER, 2017[5]); (CER, 2017[6])set up under the Petroleum Safety Acts since December 2013 (Figure 5.1).2

Figure 5.1. Ireland’s Petroleum Safety Framework

(#) Petroleum Safety (Designation of Certain Classes of Petroleum Activities) Regulations 2013.

(+) Petroleum Safety (Petroleum incident) Regulations 2016.

($) and notifications.

Source: Information provided by CRU (March 2018).

Safety permits are issued for petroleum production, well work, combined operations and decommissioning. The CRU has issued three production safety permits that remain active, two in respect of the Kinsale Gas Fields and one in respect of the Corrib Gas Field. The CRU has also issued five well work safety permits; in each case the designated petroleum activity has concluded.

The CRU has also put in place an additional safety case assessment option specifically for non-production installations, whereby rig owners can apply to be assessed for an Acknowledgement of Compliance (AoC) for their non-production installation prior to a safety permit application. An AoC is confirmation that, at the time of the related non-production safety case assessment, the information submitted satisfied the requirements of the CRU Safety Case Guidelines. This AoC can then be submitted as part of a future safety permit application with the intent of making that assessment process more efficient for the owner. The CRU has issued 4 such AoCs.

Natural gas and liquid petroleum gas (LPG)

The scope of the relevant legislation includes the safety regulation of all natural gas undertakings, including storage, transmission, distribution, supply, and shipping. From 2014, the Framework also included the safety regulation of Liquefied Petroleum Gas (LPG) undertakings. Specifically, the CRU is charged with:

• regulating the activities of gas undertakings with respect to safety, including gas network operators and gas suppliers;

• regulating gas installers with respect to safety;

• promoting the safety of gas customers and the general public with regards to the supply, storage, transmission, distribution and use of natural gas.

The regulated entities include one natural gas undertaking licensed to operate both the natural gas transmission and distribution networks, two LPG safety licensed undertakings supplying LPG to final domestic customers through piped LPG distribution networks, and 27 (as of the end of 2018) shipper/suppliers licensed to either ship and/or supply natural gas to final customers.

Gas installers and electrical contractors

The CRU is responsible for the designation and oversight of the safety supervisory bodies charged with monitoring gas installers and electrical contractors carrying out domestic gas and electrical works, respectively. Additionally, if a registered electrical contractor carries out non-domestic electrical work they must certify it. The Registered Gas Installer (RGI) scheme is being extended in 2021 to include non-domestic gas works. The CRU is responsible for policy decisions with respect to safety, the overall operation of the regulatory scheme, enforcement and review of appeals regarding registration decisions and complaints.

The CRU appointed the Register of Electrical Contractors of Ireland (RECI) to operate Safe Electric, the statutory regulatory scheme for electrical contractors, and the Register of Gas Installers of Ireland (RGII) to operate the RGI scheme, the statutory regulatory scheme for gas installers, for 2016-2022.

At the end of 2018, there were 2 999 gas installers and 4 122 electrical contractors registered with the RGI and Safe Electric schemes, respectively.

Approaches to safety culture

A key vision set by the CRU in its Strategic Plan 2019-2022 is to ensure that “energy is supplied safely.”

For petroleum and gas activities, the legislation places a fundamental obligation on owners and operators to ensure that the risk of all major accident hazards is reduced to a level that is “As Low As Reasonably Practicable” (ALARP) (Figure 5.2).

Figure 5.2. The “As Low As Reasonably Practical” (ALARP) Principle

Source: (CER, 2017[7]) ALARP Guidance – Part of the Petroleum Safety Framework and the Gas Safety Regulatory Framework, Version 3.1

The key tools that legislation assigns to CRU to foster petroleum and gas safety are:

1. 1. Assessment of safety cases and issuance of safety permits/licenses;

2. 2. Carrying out of audits and inspections;

3. 3. Carrying out of incident investigations; and

4. 4. Taking of enforcement actions.

In order to carry out a designated petroleum activity, a safety case must be submitted to the CRU for assessment. On acceptance of a safety case, the CRU issues an associated safety permit. Broadly speaking, designated petroleum activities are exploration, production and decommissioning and it is an offence to carry out these activities without a safety permit from the CRU.

Similarly, for natural gas and LPG activities, a gas safety case regime is applied to undertakings licensed by the CRU. This regime encompasses a risk and outcomes based approach to the management of gas safety risks whereby levels of risk are identified and managed to a level that is ALARP. Undertakings outline their adherence to the regime in a safety case submitted to the CRU for review and acceptance.

Where non-compliances with a safety case or the relevant legislation are identified, the CRU can take enforcement action. Non–compliances can be identified in any manner, for example, during an inspection or following an incident investigation. A number of enforcement options are available to the CRU under legislation, including the issuance of improvement notices and prohibition notices. These enforcement powers are progressive in nature to reflect the severity of the non-compliance identified. Failure to comply with these enforcement actions and other offences can result in fines and prosecution. Where the CRU is not satisfied that the holder(s) of a safety permit/licence is operating in accordance with the conditions of its permit/licence, the CRU can revoke the safety permit/licence.

In addition, for gas, a Gas Safety Promotion and Public Awareness regime is designed to increase the overall level of gas safety awareness amongst customers and the general public. Promotional activities are co-ordinated by the CRU and run by individual undertakings. The CRU, in conjunction with an industry group, the Gas Safety Promotion and Public Awareness Group (PAPA), chairs and oversees the development and review of national gas safety promotion and public awareness activities.

The approach is different for electrical contractors and gas installers. The first key step is registration. All electrical contractors and gas installers on the registers have been deemed competent to carry out electrical and gas works, respectively. They are insured and are subject to regular audit and inspection by Safe Electric and RGII. CRU exercises its powers to prosecute people who carry out electrical works and gas works when they are not registered as electrical contractors and gas installers, respectively, and those who portray themselves as registered contractors and installers when they are not. Finally, the CRU carries out activities to raise public awareness about the dangers associated with electricity and gas appliances and the need to use registered and competent contractors/installers when getting electrical and gas works done. Every time a contractor/ installer carries out domestic electrical/gas works, he is obliged to provide the customer with a completion certificate.

Assessing safety issues and risks

Safety cases

Prior to issuing a permit/license, the owner/operator must submit a safety case to the CRU for acceptance. The primary purpose of the safety case is for the owner/operator to demonstrate that adequate measures are in place to control the risk(s) of major accident hazards arising from the designated activities in such a manner as to reduce any risk to a level that is ALARP. The CRU has published detailed ALARP guidance to assist owners/operators in achieving compliance (CER, 2017[7]), including a decision process on assessing risks (Figure 5.3).

Figure 5.3. Decision process

Source: (CER, 2017[7]) ALARP Guidance – Part of the Petroleum Safety Framework and the Gas Safety Regulatory Framework, Version 3.1 (CER/16/106).

For petroleum safety, Directive 2013/30/EU (European Parliament, 2013[8]) requires that offshore safety cases must include a description of how workforce consultation and involvement has been achieved such that members of the workforce have the opportunity to contribute to the safety case and are able to arrive at informed opinions about the management of hazards to which they may be exposed on the installation.

Guidelines for safety cases recognise the importance of creating a safety culture in operators:

• The operator’s or owner’s Corporate Major Accident Prevention Policy (CMAPP), to be included in the safety cases, needs to include, among others:

  • measures for building and maintaining a strong safety culture, including through co-operation with workers, protection of whistle-blowers and working with safety representatives;

  • measures for rewarding and recognising desired behaviours including the reporting of accidents and near misses.

• Safety cases should identify procedures for internal communication among the various levels and functions of the organisation, including those required to enable the lessons from accidents to be learnt across the organisation (CER, 2016[9]).

Once received, the safety case is assessed by the CRU with the support of external technical expertise, as necessary.

Safety performance reporting and indicators

Operators and owners must monitor and report to the CRU on safety performance every quarter. For petroleum and gas safety, the safety performance indicators include both leading and lagging indicators. The petroleum safety leading indicators are produced from active monitoring of risk reductions measures to ensure their continued effectiveness (Table 5.1), and the lagging indicators relate to incidents. The CRU uses these data to monitor trends, recognise good practice and identify areas for audit and inspection.

Table 5.1. Leading safety performance indicators
ID	Safety performance indicator	Guidance
L1	Number of anomalies raised by ICB(s) in the quarter	Details of the anomalies raised are not required to be reported
L2	Number of verification anomalies that are not closed-out by the planned due date at the end of the quarter
L3	Number of verification reservations raised by the operator or owner in the quarter
L4	Number of S(E)CEs with overdue preventative maintenance at the end of the quarter	For this safety performance indicator, S(E)CEs are counted in terms of discrete items, e.g. if 10 gas detectors have not had planned maintenance completed, 10 is reported
L5	Number of S(E)CE maintenance hours required to clear any backlog in safety performance indicator L4
L6	Number of live operational risk assessments at the end of the quarter	Operational risk assessments refer to risk assessments in place due to any impairment, loss or non-availability of an SCE or an abnormal situation
L7	Number of planned emergency drills not carried out within the quarter
Note: SECEs = Safety and Environmentally Critical Elements
Source: (CER, 2017[10]), Compliance Assurance System – Part of the Safety Case Guidelines under the Petroleum Safety Framework, Version 4.1 (CER/16/016).

Verification

For petroleum activities, operators and owners must have in place Verification Schemes for verifying the suitability and performance of Safety and Environmentally Critical Elements (SECEs) and the maintenance of well integrity, by one or more organisations, termed an Independent Competent Body (ICB).

The operator and owner must submit its choice of ICB to CRU for acceptance in terms of their competence and independence. Where an ICB identifies a failure in either of the operator’s or owner’s system for maintaining well integrity, or the performance of an SECE, or the associated assurance processes, or the Verification Scheme itself, it must raise an anomaly. Where the ICB and operator/owner cannot agree on a suitable date for the closure of an anomaly, or on whether an anomaly has been suitably closed out, the ICB must raise a “verification reservation” to the operator/owner which they, in turn, must notify to the CRU. In this way CRU’s attention is brought to issues relating to SECEs that cannot be resolved between the operator and the ICB. The Verification Scheme must be described or referenced in the Safety Case and must be sufficient to be able to judge whether the SECEs are initially and will continue to meet their performance standards, or well integrity is and will continue to be maintained. Verification records can be reviewed during audit and inspections. CRU can also inspect the verification body.

Audit and Inspection

Audits are based on examination and/or inspection of records, reports and other evidence produced or generated by an operator or owner relating to, for example, safety operation, safety performance, the Safety and Environmental Management System, and designs, including verification records, safety performance reports and Independent Safety Case Review reports (CER, 2015[11]).

For petroleum activities, inspections involve physical examinations of petroleum infrastructure, systems and parts of systems and are carried out by petroleum safety officers (PSOs) appointed by the CRU for this purpose. Audits and inspections are risk-based; the programme is determined annually and includes both scheduled and unannounced inspections.

For gas, the CRU has identified three type of inspection activities:

• internal safety audit and inspections, carried out by the undertaking;

• external safety audit and inspections, carried out by the CRU; and,

• detailed review of an undertakings’ safety case, carried out by an independent body on a 5 year basis.

Tripartite consultation and confidential reporting

For petroleum activities, the CRU has established tripartite consultation between the CRU, owners and operators, and worker representatives to facilitate dialogue and co-operation. Each year the CRU hosts separate meetings for operators of production facilities and for those involved in exploration and well work activities.

Prior to the tripartite meetings, the CRU inspectors engaged with the worker safety representatives as part of their inspection process and this will continue to happen. CRU inspectors ensure the worker safety representatives are aware that they can communicate and raise relevant issues with the inspections team that will be dealt with accordingly.

Workers can also submit confidential reports of safety and environmental concerns to CRU via a CRU template that is required to be shared with all staff.

Communication

The CRU has also been promoting open communication to ensure that management is fully involved in and aware of safety requirements and issues. Both the Gas Networks Company and the two LPG undertakings have dedicated points of contacts for interacting with the CRU. Correspondence concerning inspections or enforcement actions is addressed to these dedicated contacts or senior management. In addition, the CRU Director of Energy Safety meets quarterly with the Managing Director of the Gas Networks Company to discuss any safety issues that have arisen during the previous quarter. The CRU also plans to provide more structured data from the regular monitoring of key performance indicators for consideration at this meeting. The CRU Commissioners also meet regularly with the Gas Networks Company and its parent company and important safety issues may be raised at that meeting. The Director of Energy Safety also meets at least annually with the managing directors of the two LPG undertakings, and more recently with the Association representing the LPG companies.

The criteria for operation and governance of the schemes for gas installers and electrical contractor is open to public consultation. A gas installer representative panel meets quarterly with the RGII and the CRU to discuss matters relating to the operation of the scheme. A similar electrical contractor representative panel is to be established in 2020. Annual roadshows are held for installers and contractors, these enable general discussions and question and answers sessions with the scheme operators and CRU. Additionally committees have been established to consult on and oversee the extension of the RGI scheme to include non-domestic gas works.

The Gas Safety Committee is chaired by the CRU and includes the Department of Communications, Climate Action and Environment, the RGII, the Competition and Consumer Protection Commission, the National Standards Authority of Ireland and regulated natural and LPG gas undertakings. The Committee facilitates the safe transmission, distribution and use of natural and LPG gas through the sharing of information at their meetings.

Behavioural barriers to safety culture

CRU responsibilities cover sectors which might face different safety challenges. Nevertheless, across these sectors, there seem to be some common behavioural barriers and challenges. Behavioural barriers include:

• Over-confidence/complacency: this can be significant when an operator has faced no major incident for a number of years. It can be linked to a (misleading) belief that this is the result of robust systems or of the use of new or established technologies that, because their use is widespread, must ensure safety.

• Information bias: all employees (including small installers and contractors) might underestimate how certain actions or failure to take action can impact safety.

• Framing: deeper understanding of the importance of safety can be undermined by inconsistency/contradictions in messaging. This can come also from the number of regulators involved in the same sectors, if they are not joint up.

• Resistance to change and to being regulated: Entities may have self-regulated or been subject to a “lighter touch” regulation in the past, sole traders tend to be particularly resistant to perceived additional bureaucracy

• Lack of committed safety leadership: dilution/lack of consistency of safety messages may occur if relying on a third party to operate regulatory schemes, similarly lack of committed safety leadership may exist

• Lack of vigilance : investigations and actions are not taken in a timely manner

• Lack of resiliency: underdeveloped professionalism/not aware of related risks.

Mexico’s Agency for Safety, Energy and Environment

This section provides an overview of the role, approach and issues faced by the Agency for Safety, Energy and Environment (ASEA) in fostering a safety culture in the sectors it oversees. The purpose is to identify key behavioural barriers to creating a safety culture and methods and approaches identified by regulators to tackle these barriers. This section draws on information provided by ASEA as well as Driving Performance of Mexico’s Energy Regulators (OECD, 2017[12]) and Driving Performance at Mexico’s Agency for Safety, Energy and Environment (OECD, 2017[13]).

Overall role and institutional set-up

ASEA is a multi-disciplinary regulatory organism with the mission of guaranteeing the safety of the people and the integrity of the environment with legal, procedural and costs certainty in the Hydrocarbons Sector.

While the overall contribution of the oil sector to the country’s GDP has decreased considerably over the years (from approximately 10% in 1996 to 5% in 2016), the sector continues to hold significant weight in the country’s political and economic agenda and was the subject of a major structural reform in 2013-14 that included the opening of the hydrocarbons sector to foreign and private operators, effectively ending the monopoly of state-owned PEMEX (OECD, 2017[14]).

The regulator was established with the enactment of the ASEA Act in August 2014, as part of Mexico’s ambitious energy reform that opened the hydrocarbons sector to private and foreign operators. Since becoming operational in March 2015, ASEA has tackled complex transfers of responsibilities and powers from other federal entities and states and, in the area of industrial and operational safety, has had to regulate in an area previously self-regulated by PEMEX.

ASEA is a deconcentrated agency of the Ministry of Environment and Natural Resources (SEMARNAT). It has technical and managerial independence, but is dependent of the Ministry for financial and budgetary aspects. During its first years of operation, ASEA has been financed by the executive, although it is foreseen that, in the upcoming years a great portion of its funding will come from the payments made from Regulated Entities by the concept of paperwork management & non-compliance fines. The Executive Director of the Agency is directly appointed and can be removed by the President of Mexico.

Since September 2017, ASEA forms part of the System of Energy Regulators that it established jointly with the Energy Regulatory Commission (CRE) and the National Hydrocarbons Commission (CNH). The joint system aims to regulate and supervise sector activities in a reliable and co-ordinated manner in order to promote productive investments and the energy sector’s efficient and sustainable performance for the benefit of Mexico. A number of joint initiatives, including the opening of the one-stop-shop Bureau for Co-ordinated Assistance to the Energy Sector (ODAC) that provides information to sector stakeholders in areas that involve more than one regulator, have already been carried out by the co-ordination body.

Safety responsibilities

ASEA is the safety regulator of Mexico’s hydrocarbons sector. It oversees activities throughout the hydrocarbons value chain, from upstream exploration and extraction to midstream and downstream transformation, production and storage, as well as distribution and retail at petrol station level (see Figure 5.4). This breadth of responsibilities makes ASEA internationally unique.

Figure 5.4. Functions of the Agency for Safety, Energy and Environment (ASEA)

Source: (OECD, 2017[13]), Driving Performance at Mexico's Agency for Safety, Energy and Environment, OECD Publishing, Paris (updated in March 2018 based on information provided by ASEA).

More specifically, the ASEA Act, August 2014, assigns amongst others the following functions to the Agency:

• Contribute technical elements relative to industrial and operational safety and the environment protection, to the competent authorities, for environmental and energetic policies of the country.

• Collaborate with the distinct government organisms, dependencies and competent entities, in the design and attention of the national and international prevention plans to attend the emergency situations in the Sector activities.

• Regulate, supervise and sanction on industrial and operational safety and environmental protection matters, in relation to the Sector activities, including the stages of dismantling and abandonment of the facilities and the integral control of waste and atmospheric emissions.

• Set the guidelines for the conformation and operation of the SEMS that the Regulated Entities must have and, authorise said SEMS.

• Supervise and watch over the compliance by the Regulated Entities of the legal and regulatory systems and norms applicable to the subjects of their competence.

• Authorise Agency´s public servers and accredit natural or legal persons to carry out supervisions, inspection and verification activities, technical evaluations and investigations, as well as certification and audits activities.

• Impose safety measures, precaution measures or sanctions that are applicable to the corresponding legislation.

• Carry out root cause analysis in case of operational, industrial and environmental incidents and accidents, according to the issued guidelines or set the basis for the Regulated Entities carry out their own analysis, as well as the risk and lessons learned communication.

• Issue, suspend, revoke or deny licenses, authorizations, permits and records in environmental matters.

• Boost sustainable regional development and demand that the related Sector activities are performed with protection, conservation, compensation and restauration of the ecosystems, including flora and fauna, environmental services, in coordination with the competent administrative units.

Approaches to safety culture

Notwithstanding its enforcement powers, the Agency pursues a strategy that favours compliance over punishment, as well as performance or results-based technical regulation over prescriptive regulation. These approaches underlie ASEA’s approach to safety culture in the hydrocarbons sector.

Safety culture is understood as the set of beliefs, values, attitudes and behaviours that a group of people has in common with respect to the management of risk and safety; consequently, ASEA promotes within industry the understanding that the risk management is a regular practice that benefits entities’ own performance.

The Safety and Environmental Management System (SEMS) that regulated entities are obligated to design, submit for authorisation by ASEA and implement constitute the corner stone of this framework. The SEMS is a set of interrelated and documented elements that cover the entire life cycle of the regulated entity’s facilities with the overall purpose of prevention, supervision and improvement in the areas of industrial and operational safety and environmental protection.

ASEA emitted secondary regulation on SEMS for upstream and midstream activities in May 2016 (SASISOPA), covering activities linked to exploration and extraction of hydrocarbons; refining, transportation and storage of oil; transportation, storage and distribution of natural gas; transportation and storage of Liquefied Petroleum (LP) gas; transportation and storage of petroleum.3 Further to this, ASEA emitted secondary regulation on SEMS for downstream and retail in June 2017, covering activities linked to the sale to the public of natural gas; distribution and sale to the public of Liquefied Petroleum Gas; distribution and sale to the public of petroleum products.4

As per these regulations, regulated entities need to count with the authorisation of their SEMS by ASEA before initiating any activity in the building stage. The process of authorisation of SEMS is expected to be carried out over 90 working days by the Agency, as per the steps described in Figure 5.5.

The SEMS is intended as a dynamic framework based on continuous improvement that will guide the activities, supervision and learning of the regulated entity. Operators are required to have a dedicated unit in charge of the implementation, evaluation and improvement of the SEMS, with necessary written procedures, computer tools, and management platforms that are to be implemented in a constant and consistent manner. In addition, a number of assessments are required to be carried out by external parties (external audits by third parties). Following authorisation of an entity’s SEMS by ASEA, regulated entities are required to submit the following reporting to the Agency:

• Semi-annual compliance reports of the SEMS Implementation Program.

• An annual performance report based on the indicators of the SEMS (must be delivered during the first quarter of the year).

• Biannual reports on the results of the external audit carried out on the SEMS.

Importantly, regulated entities are required to consider organisational culture and job satisfaction in the fields of industrial safety and environmental protection, and the effectiveness of processes for employee participation as essential dimensions for the success of SEMS (Article XXXII.3.c) and e) of SASISOPA). Furthermore, ASEA requests regulated entities to implement mechanisms to promote openness and culture of disclosure of incidents and accidents (Annex IV, Section B, Article VIII.3) of SASISOPA).

Figure 5.5. Authorisation process for Safety and Environmental Management Systems (SEMS) by ASEA

Note: Acronyms refer to working days (WD) and the Regulated Unique Reference Code (CURR in Spanish).

Source: Information provided by ASEA, 2018.

Given the recent entry in vigour of SEMS related regulation and requirements, ASEA had not yet received reports from regulated entities as of 2018 for Systems approved in 2016. The Industrial Management and Planning Units of ASEA published guidelines with regard to SEMS indicators (13.b) in December 2019. ASEA plans to use data from these indicators in its Annual Report on Safety Performance.

Finally, the SEMS must be rooted in the Policy of Regulated Entities that commits the regulated entity and staff to perform the identification of safety issues as a constant activity. It is to be formulated by the senior management of the regulated entity and is to include the following elements, in the shortest document possible:

• Nature of risks and environmental concerns linked to the entity’s activity;

• Framework for the definition of the objectives of the entity’s SEMS;

• Commitment to the assessment of risks and environmental impact and to compliance with the normative framework on behalf of the regulated entity, its contractors, subcontractors, providers and service providers;

• Commitment to continuous improvement in performance for industrial and operational safety and the protection of the environment.

Once formulated, this policy is signed by the regulated entity’s senior management signalling leadership commitment to safety values. It will be distributed to all staff, as well as contractors, subcontractors, providers and service providers in the form of flyers.

Technical managers will also be required to communicate the contents of the policy to staff and teams via weekly chats, using flyers or other materials to support these conversations for effective communication aiming to enhance safety culture. These suggestions are included in guidelines prepared by ASEA and published online.5

Assessing safety issues and risks

ASEA definition and approach to assessing safety issues and risk

Risk assessment is a task performed by the regulated entity from the moment it presents its SEMS for assessment and authorisation by ASEA. It is regarded as a process performed by the regulated entity, according to the methodology of its choice, to estimate the probability and magnitude of the identified risks.

Risk is understood by the Agency as the probability of occurrence of an unwanted event and is measured in terms of its consequences to the people, facilities, environment or community.

The Agency does not distinguish between actual and potential risks because the risk itself is a probability; however, it does distinguish critical risk. A critical risk implies an imminent danger and requires immediate action to reduce the risk to an acceptable level without limiting the cost of its solution.

Box 5.1. ASEA risk-based management model

ASEA implements a risk-based management model to tackle its ample responsibilities and target its resources in the most efficient manner. This model is based on five pillars:

• Regulated entities are requested to design, implement and report on Safety and Environmental Management Systems (SEMS), which include risk assessment and strategies that are followed up on a yearly basis.

• ASEA prioritised emitting regulation on regulated entities’ insurance requirements, to ensure sufficient financial responsibility in case of incidents or accidents.

• ASEA favours performance-based rather than prescriptive regulation, allowing for innovation by industry.

• ASEA favours corrective enforcement over sanctions, emitting recommendations for corrective measures designed to decrease risk.

• Inspections are fielded according to analysis of the level of risk, targeting high-risk sites, and are supported by accredited third parties.

Figure 5.6. Risk management model

Source: (OECD, 2017[13]), Driving Performance at Mexico’s Agency for Safety, Energy and Environment, the Governance of Regulators, Paris. Based on information provided by ASEA in 2016.

Risk and hazard identification in regulated entity policy and SEMS

The Policy of the Regulated Entity as well as the SEMS are required to include the identification of safety issues. The identification of hazards and risk analysis should be carried out in routine activities, based on the application of internationally accepted methodologies, as well as in non-routine activities. Risk assessments must include necessary mitigation, prevention and control measures to reduce the identified risks.

In continuous operations, the regulated entity must update its hazard identification at least every five years or in case of an accident. The Agency requires the regulated entity to deliver, during the execution of its SEMS Implementation Program, the following documents:

1. 1. The list of mechanisms used to identify hazards.

2. 2. Documentary evidence of the team members’ technical competences.

3. 3. The five-year programme for updating hazard identification.

4. 4. The list of dissemination and communication mechanisms of the results derived from the identification of hazards to its staff, contractors, subcontractors, service providers and suppliers.

It is important to emphasize that the results of the risk analysis must be included in the operation, maintenance and inspection procedures; as well as emergency response plans. In all this, the regulated entity must document the follow-up that is made to the actions and recommendations derived from the risk analysis.

By law regulated entities are required to involve external parties in their risk assessment activities, by external audits of their operations as well as inspections carried out by third parties. ASEA has the authority to authorise third parties to carry out inspections on its behalf as per the Official Mexican Standards and in the General Administrative Provisions issued by the ASEA. ASEA supervises third parties according to a schedule designed by its Unit of Inspections, which consists of both a documentary and in situ assessment.

Inspections by the regulator

ASEA’s risk-based inspections framework is informed by data from three sources: i) risk evaluations and inspections by regulated entities as part of the SEMS implementation programme: ii) inspections by insurance companies; iii) inspections by ASEA targeting high-risk sites based on an analysis of the previous information.

When ASEA inspectors detect regulatory breaches they strive to close the detected gap and reduce the likelihood of its recurrence. Information on potential breaches is written up in the Inspection Act that is shared with the regulated entity. These normative breaches in the actions of the regulated entities and the third parties are detected from:

• Risk analysis in which it is possible to evaluate the protective barriers and reduce the risk.

• Incident and Accident Statistics.

• Complaints and Complaints.

• Analysis of Root Cause Investigations and their recommendations.

• Results of previous verifications.

• Compliance with corrective measures, urgent application measures and security measures.

• Compliance with the conformity assessment procedure.

Behavioural barriers to safety culture

Some of the key challenges faced by ASEA in addressing the emergence of a safety culture in the sector are:

• The recent establishment of the regulator and its on-going work defining the safety conditions of the sector, including covering regulatory gaps;

• The ample scope of activities and types of operators in different stage of the hydrocarbons value chain regulated and supervised by ASEA, their geographical distribution, the number of operators and third parties as well as the level of required expertise to inspect their activities;

• Effective communication of the regulator’s approach that compliance over penalty to regulated entities;

• Establishing safety culture at all levels of regulated entities;

• Establishing professional responsibility in third parties authorised to inspect and evaluate operator performance by ASEA, and ASEA’s ability to monitor and verify the performance of the third parties;

• Defining indicators to measure safety culture, communicate those indicators and verify their proper compliance;

• Achieving the perception of safety as an investment that carries benefits, advantages and opportunities for business.

Oman’s Authority for Electricity Regulation

This section provides an overview of the role, approach and issues faced by the Authority for Electricity Regulation (AER) in fostering a safety culture in the sectors it oversees. The purpose is to identify key behavioural barriers to creating a safety culture and methods and approaches identified by regulators to tackle these barriers. This section draws on information provided by the AER.

Overall role and institutional set-up

The AER is an independent regulator with economic and technical functions and duties in Oman’s electricity sector and related aspects of the water sector. It was initially established by Article (19) of the Law for the Regulation and Privatisation of the Electricity and Related Water Sector (2004) and amended by Royal Decree 59/2009 and 47/2013 on the Sector Law.

The AER’s statutory functions and duties under the Sector Law are to protect the interests of customers, companies, and the government. Its principal duties according to Article (22) of the Sector Law are as follows:

• Ensure security of electricity and related water services in Oman;

• Promote competition in the electricity and related water sector

• Ensure safe, effective and economic operation of the electricity and water sector in the interest of the public;

• Protect and serve in the interest of vulnerable customers;

• Ensure compliance with government policies regarding environmental protection, Omanisation and Omani Content 6;

• Ensure Licensees meet all reasonable demands relating to financial and technical capabilities;

• Facilitate the privatisation and liberalisation of the electricity and related water sector;

• Guarantee fair and transparent competitions held by Oman Power and Water Procurement Company (OPWP) in procuring new generation capacity;7

• Provide advice to Ministries and the Public Authority for Electricity and Water (PAEW);

• Conduct an annual review on the scope for further privatisation and liberalisation of the electricity and related water sector;

• Prepare and maintain a Public Register of licenses, exemptions and such related matters

The AER manages its budget independently and reports directly to the Council of Ministers.

Safety responsibilities

The AER’s safety responsibilities include to securing and developing the safe, effective and economic operation of the electricity and related water sector, and enhancing the safety of the public in relation to sector activities.

Key safety functions include:

• Conducting Health and Safety audits of Licensees’ safety policies, plans, processes and procedures according to their statutory obligations

• Investigate safety-related incidents, mainly in the event of accidental death

• Reviewing significant incident reports in the sector

• Investigate technical incidents as required to ensure system performance

Health and Safety Audits

AER periodically undertakes Health and Safety audits of all regulated entities under its mandate. The frequency of formal audits is determined according to routine monitoring of performance and behaviours. For its upcoming 2018 Work Programme, the AER plans to conduct Health and Safety audits of Oman Electricity Transmission Company (OETC), Oman Power and Water Procurement Company (PWP) and Dhofar Power Company (DPC) (AER, 2017[15]). The audits are focused on the health and safety performance of Licensees at all levels, including the activities of the companies under their contract. Audits include reports to and decisions taken by the Board of Directors to administer and implement Health and Safety rules at the operational level.

Regulation of Electric Vehicles

In accordance with its 2018 Forward Work Plan, the AER carried out a review of international best practices relating to a regulatory framework to support the introduction of electric vehicles in Oman (AER, 2017[15]). As part of this review, the AER looked into safety issues associated with electric vehicles. The study was conducted in 2018.

One of the outcomes was identification of safety requirements for connecting EV charges which was embedded in the new update of the Wiring Regulations (known as Oman Electrical Standard 4 “OES4”). Edition 3 of OES4 was approved by the Authority which is intended to come to effect in January 2020.

Environmental Compliance

Prior to issuing licenses, the AER requires Licensees to take due account of applicable environmental standards prevailing in the Sultanate of Oman and establish a written policy on protecting the environment from harmful effects of its licensed activities, together with the operational and management arrangements for its implementation. Although overall environmental compliance is the responsibility of Ministry of Environment and Climate Affairs, the AER has previously audited the environmental performance of network licensees.

Approaches to safety culture

Ensuring the safety and security of the electricity and related water sector in the interest of the public, companies and government is one of the key mandates of the AER. The key tools that legislation assigns to AER to achieve safe and secure electricity and related water provisions include:

1. 1. Issuing licenses to operate/deliver activities in the sector;

2. 2. Carrying out audits and inspections;

3. 3. Carrying out incident investigations; and

4. 4. Taking enforcement actions including fines

Non–compliances with health and safety obligations are typically identified by audits and inspections, or following a safety report or incident investigation.

Where non-compliances with a safety case or the relevant legislation are considered to be a breach of a Company’s licence, the AER can issue a notice to secure improvements. A number of enforcement options are available to the AER under legislation, including the issuance of improvement notices and fines (although fines are only permitted for instances where a company fails to comply with the terms of a breach of licence notice).

The Authority has used a variety of regulatory tools to secure improvements, including issuing breach of licence notices, imposing fines, and refusing to issue a licence to a company until health and safety concerns are fully addressed. According to the Sector Law, if it is revealed to the AER that a Licensee or exemption holder is violating or likely to violate a condition of the license or exemption, or any of the duties imposed on him pursuant to the provisions of the law, the AER has the right to revoke a license or exemption in case the holder of a license or exemption abstains from implementing the decisions issued by the AER in respect to the violations. The AER has not yet revoked a license or exemption, although it has in the past refused to issue a license or exemption until the company applicant improved its health and safety performance. The Authority is presently in the process of formalising regulations to allow for immediate penalties for unsafe electrical installations.

It appears that AER both regularly and informally communicates with senior management of regulated entities about health and safety concerns, considerations, and recommendations. However, AER correspondences with regulated entities suggest that regulated entities have tended to respond to concerns raised by AER on a case-by-case basis rather than on a systematic or pre-emptive basis. However, although the AER thereby appears to expend significant efforts and resources to actively and continuously supervise regulated entities for chronic infringements, the AER has identified more sustainable risk identification and management processes that licensees have started to implement.

Assessing safety issues and risks

Health and Safety Management Plans

Licenses with operators and owners require a written Health and Safety policy, including details of implementation and management arrangements. The content of the policy are at the discretion of the Licensee.

Some Licensees have pursued international certifications in Integrated Management System to demonstrate Health, Safety and Environment (HSE) performance. However, it is not clear to what extent the pursuit and/or achievement of such certifications are sufficiently reflected in HSE safety practices or working culture on the ground.

Safety performance reporting and indicators

According to the Distribution Code (Distribution Operating Code DOC5) and the Grid Code (Operating Code OC6), Network Licensees shall review their Safety Rules every twelve months.

Each Network Licensees shall prepare a report of each review, which should summarise the relevant events that have been considered as part of the review. The report may recommend changes to the Safety Rules, the implementation of the Safety Rules, or amendments to the codes of practice to support the Safety Rules. The report shall be presented to the Distribution Code Review Panel for consideration and review, and then presented to the Grid Code Review Panel and the AER for overall consideration of Safety Rules.

The AER examines the H&S performance of Licensees against the requirements of the license.

The overall safety performance of the electricity and related water sector has improved dramatically since 2005. However, the individual performance of Licensees varies from one to another. With regular monitoring, it is expected that safety performance will continue to improve.

Audit and Inspection

For the electricity and related water sector, the AER has identified three types of inspection activities:

• internal safety audit and inspections, carried out by the Licensee;

• external safety audit and inspections, carried out by the AER; and,

• third party auditing

Self-audits by Licensees are typically based on examination and/or inspection of records, reports and other evidence produced or generated by an operator or owner relating to safety operation or performance, including performance reports and verification records.

AER audits, inspections and communications may be done formally or informally, and may involve scheduled and/or unscheduled physical inspections of electricity installations, including equipment. Investigations may be conducted by a technical team within the AER or by external consultants, depending on the severity or complexity of the issue or incident.

AER may also contract third party consultants to undertake audit and inspection.

Time-dated photographs may be taken as evidence of health and safety infractions. If installations are assessed by the AER to constitute a health or safety risk, the Licensee may be subject to fines ranging from 500 to 1000 Omani Rial (USD 1 300 to 2 600) per infraction. The AER may send such photos to Licensees with requests for remedial actions and/or to accompany notices of fines will be issued for health and safety infringements.

Licensees are responsible for ensuring compliance of health and safety rules and standards by staff, contractors and consultants. Licensees do not always and may not be able to impose financial penalties on contractors found in breach of health and safety rules. In the past, this has been because Licensees and contractors do not always operate on formal contracts or work permits, or the issuance of contracts or work permits to contractors have not given sufficient weight to health and safety performance. However, health and safety is generally considered at the contract award stage, and penalties are imposed for non-compliance with the relevant requirements.

Health and safety workshops

Health and safety workshops are occasionally conducted for Licensees and exemption holders, including network companies. Health and safety concerns, as well as best practices, could be discussed and presented in such workshops.

Behavioural barriers to safety culture

AER responsibilities cover sectors which might face different safety challenges. Nevertheless, across these sectors, there seem to be some common behavioural barriers and challenges. Behavioural barriers include:

• Over-confidence/complacency: this can be significant when an operator has faced no major incident for a number of years. It can be linked to a (misleading) belief that this is the result of robust systems or of the use of new or established technologies that, because their use is widespread, must ensure safety.

• Information bias: all employees (including small installers and contractors) might underestimate how certain actions or failure to take action can impact safety.

• Responsibility deflection: inspection reports suggest that regulated entities readily deflect the responsibility of HSE breaches to contractors, even where the AER and other inspectors confirm that said breaches are attributable to the regulated entities. In some cases, managers have also deflected responsibility to lower level staff on the grounds that the staff has received delegated authority to ensure compliance with HSE rules.

It does not appear to be uncommon for the AER to find that staff, contractors and consultants working for Licensees have not been formally trained on company safety rules, or in some cases have never read them.

Other times, staff, contractors and consultants are familiar with the basic requirements of various safety standards, including the Oman Electrical Standards, but are little motivated to ensure their full compliance. Staff and contractors have been observed to comply with safety requirements only when inspector or auditors are around; once the checks are over, it is business as usual.

Previous investigations have revealed systematic failures to apply operational safety procedures on the part of Licensee. While all Licensees appear to have company-wide electricity safety rules, they are neither consistently applied nor enforced; in some cases they have been blatantly ignored. Furthermore, companies are not always able to provide evidence that safety rules have been adequately taught and/or learnt by all relevant staff, or that all relevant staff have seen or received a copy.

Possible reasons that have been identified in AER or incidence reports to explain low or non-compliance with safety rules and procedures include:

• Weak leadership from executive management to support and prioritise HSE improvements in the workplace. For example, in at least one company, senior management and other managers responsible for safety have failed to attend a scheduled meeting with the AER to discuss HSE performance;

• Perceived lack of clarity on the requirements and application of safety rules among staff;

• Fatigue on the part of key personnel who have had to work long hours. At least one panel report recommended a review of the number of competent, authorised and senior authorised persons responsible for ensuring health and safety, particularly with regards to current and future workload, and including an assessment of the effects of excessive working hours on worker safety;

• Lack of clarity on roles and responsibilities for HSE performance, including who is authorised to operate or test certain activities, or who had the authority to issue or cancel such permissions;

• Staff, contractors and/or consultants operating at levels exceeding their competence or understanding.

AER and third party auditors/inspectors have attempted to encourage greater safety compliance by sharing peer performance evaluations with Licensees. In at least one external audit, a Licensee’s company activity performance – including in HSE and risk categories – has been compared against the performance of their peers’. It is unclear to what extent Licensees have been encouraged to improve their safety behaviour or practices after seeing their relative performance ranking vis-a-vis other license holders.

References

[15] AER (2017), 2018 Forward Work Programme, Authority for Electricity Regulation, Oman, http://www.aer-oman.org/pdfs/FWP_2018_English_Final.pdf.

[7] CER (2017), ALARP Guidance Part of the Petroleum Safety Framework and the Gas Safety Regulatory Framework, Commission for Energy Regulation, Dublin, https://www.cru.ie/wp-content/uploads/2017/11/CER16106-ALARP-Guidance-V3.0.pdf (accessed on 2 March 2020).

[10] CER (2017), Compliance Assurance System part of the Safety Case Guidelines under the Petroleum Safety Framework Version Reference Number Changes from Previous Version Date, Commission for Energy Regulation, Dublin, https://www.cru.ie/wp-content/uploads/2017/11/CER16016-Compliance-Assurance-System.pdf (accessed on 2 March 2020).

[6] CER (2017), Guidance for Notification of Incidents Part of the Petroleum Safety Framework, Commission for Energy Regulation, Dublin, https://mk0cruiefjep6wj7niq.kinstacdn.com/wp-content/uploads/2017/11/CER16037-Guidance-for-Notification-of-Incidents.pdf (accessed on 2 March 2020).

[5] CER (2017), Requirements of the Petroleum Safety Framework, Commission for Energy Regulation, Dublin, https://www.cru.ie/wp-content/uploads/2017/11/CER16023-Requirements-of-the-Petroleum-Safety-Framework-V1.1.pdf (accessed on 2 March 2020).

[4] CER (2016), Electrical Safety Supervisory Criteria Document (Version 3.0), Commission for Energy Regulation, Dublin, https://safeelectric.ie/wp-content/uploads/2017/06/Criteria-Document.pdf (accessed on 2 March 2020).

[9] CER (2016), Safety Case Requirements Part of the Safety Case Guidelines under the Petroleum Safety Framework Version Control Version Reference Number Changes from Previous Version Date, Commission for Energy Regulation, Dublin, https://www.cru.ie/wp-content/uploads/2016/07/CER16024-Safety-Case-Requirements.pdf (accessed on 2 March 2020).

[3] CER (2016), The Regulation of Gas Installer with respect to Safety; Criteria Document Version 1.6, Commission for Energy Regulation, Dublin, https://mk0cruiefjep6wj7niq.kinstacdn.com/wp-content/uploads/2017/09/Gas-Criteria-Document-Version-1.6.pdf (accessed on 2 March 2020).

[11] CER (2015), CER Audit and Inspection System part of the Petroleum Safety Framework Version Control Version Reference Number Changes from Previous Version Date, Commission for Energy Regulation, Dublin, https://www.cru.ie/wp-content/uploads/2016/07/CER16015-CER-Audit-and-Inspection-System.pdf (accessed on 2 March 2020).

[2] CRU (2019), 2019-2021 Strategic Plan, Commission for Regulation of Utilities, Dublin, https://mk0cruiefjep6wj7niq.kinstacdn.com/wp-content/uploads/2019/03/CRU19030a-CRU-Strategic-Plan-2019-2021-English-Version.pdf (accessed on 2 March 2020).

[8] European Parliament (2013), Directive 2013/30/EU of the European Parliament and of the Council of 12 June 2013 on safety of offshore oil and gas operations and amending Directive 2004/35/EC Text with EEA relevance, European Parliament, https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32013L0030 (accessed on 2 March 2020).

[1] OECD (2018), Driving Performance at Ireland’s Commission for Regulation of Utilities, The Governance of Regulators, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264190061-en.

[13] OECD (2017), Driving Performance at Mexico’s Agency for Safety, Energy and Environment, The Governance of Regulators, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264280458-en.

[12] OECD (2017), Driving Performance of Mexico’s Energy Regulators, The Governance of Regulators, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264267848-en.

[14] OECD (2017), OECD Economic Surveys: Mexico 2017, OECD Publishing, Paris, https://dx.doi.org/10.1787/eco_surveys-mex-2017-en.

Notes

← 1. Case studies were also collected from the Korea Occupational Safety and Health Agency that focuses on workplace safety (including construction and manufacturing) and the United Kingdom’s Office for Rail and Road, which focused on railway safety. Insights into behavioural biases in their sectors was included in the below analysis. For the sake of consistency with the experiments, the cases were omitted from this publication.

← 2. Petroleum (Exploration and Extraction) Safety Acts 2010 and 2015.

← 3. Lineamientos para la conformación, implementación y autorización de los Sistemas de Administración de Seguridad Industrial, Seguridad Operativa y Protección al Medio Ambiente aplicables a las actividades del Sector Hidrocarburos https://www.gob.mx/cms/uploads/attachment/file/257218/dacg_sasisopa_dof_13_may_2016.pdf.

← 4. Lineamientos para la conformación, implementación y autorización de los Sistemas de Administración de Seguridad Industrial, Seguridad Operativa y Protección al Medio Ambiente aplicables a las actividades de Expendio al Público de Gas Natural, Distribución y Expendio al Público de Gas Licuado de Petróleo y de Petrolíferos. https://www.gob.mx/cms/uploads/attachment/file/231626/2017_06_16_mat_semarnat2a_sasisopa_expendio.pdf.

← 5. Guía para la conformación del sistema de administración de seguridad industrial, seguridad operativa y protección al medio ambiente aplicable a las actividades de expendio al público de gas natural, gas licuado de petróleo y petrolíferos https://www.gob.mx/cms/uploads/attachment/file/264154/gu_a_sasisopa_validada_final.pdf.

← 6. Omanisation refers to the Government’s policy for employing Omani nationals, and Omani Content refers to the use of Omani materials.

← 7. OPWP is the single buyer and seller of electricity and related water.