High Consequence Recognition
References: AS2885.6 Clause 1.5.6 AS2885.6 Appendix H
High Consequence recognition is a new requirement in AS 2885.6-2018. Its intent is to ensure that key personnel in Licensee organisations are aware and acknowledge the potential consequences of a pipeline failure in a HCA, despite the usually very low likelihood of such a failure. The purpose of this requirement is to unmask the high consequence threats and 'black swan' events, which might otherwise be buried amongst other low risks such as a frequent but insignificant incident.
How does High Consequence Area recognition differ from "controls fail" testing?
(Peter Tuft) High consequence recognition and control failure check are unrelated. Control failure check now applies where an SMS does not encounter any threats that require risk evaluation, because doing an SMS that never gets to any risk evaluation just doesn't seem right. It is important to be aware of the potential consequences of failure even if the workshop considers that all threats are adequately controlled. The output from a control failure check (if done) may be one of several bits of information sent to the Licensee's representative for them to assess as part of the high consequence recognition process. But it's only one among many.
(Susan Jaques) Where there is a high consequence area classification, additional communication is required so that the Licensee is made aware of the consequences of pipeline failures in that area, as well as the controls in place and their limitations - regardless of what causes the failure.
What is a regulators' view on sufficient evidence that a Licensee is aware of high consequence and has adequate controls in place? Seems open to interpretation.
(Peter Tuft) This is a question for individual regulators. It would probably be reasonable for them to take the recommendations of Part 6 Appendix H as a starting point.