Alternative Safety Approaches
Annual State of Safety 2023
State of Safety: Alternative Safety Approaches
The Alternative Safety Approaches (ASA) program enables innovation and offers flexibility to owners or operators of regulated equipment in how they manage safety. This approach looks at safety as an integrated whole instead of simply complying with a series of prescriptive requirements.
Owners or operators are empowered to create a written 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 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 findings for sites operating with an accepted ASA are given one of the following ratings.
Effective | 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. |
Not effective | 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. |
The ASA Program in 2023
In 2023, the ASA program received 25 new applications and expressions of interest. These applicants included:
- Operators motivated by existing ASA clients in the same sector to apply for ASAs
- Existing ASA clients that hold successful ASAs in one technology (for example, electrical) and wish to apply for new ASAs in other technologies (for example, gas or boiler
- New clients working in areas of new technology, such as hydrogen and liquified natural gas, that do not have appropriate codes or standards available under prescriptive regulation
- Smaller companies that have applied for ASAs to streamline their operational requirements and costs
We are optimistic that the increased interest reflects clients’ acceptance of ASA as an effective approach to manage their safety operations and indicates their satisfaction collaborating with Technical Safety BC’s ASA team. To better support our clients, we added two new Senior Safety Officers to facilitate the review, issuance, audit, and oversight of ASAs. These enhanced resources will further advance the ASA program.
Audit in Action
LNG production in BC faces complex challenges, due to the nature of their operations. One challenge is the construction of regulated equipment and modular assembly outside of British Columbia. Third party Inspection Agencies are relied upon to ensure regulatory compliance and quality management of the project outside of Technical Safety BC's jurisdiction. Understanding that the assembly of modules outside of British Columbia may be considered part of the installation, it is essential for companies to have an ASA to manage their regulatory requirements.
The ASA team has performed an audit on an LNG operator in 2023 and found supporting evidence through their Safety Management Plans and effective quality management, that these project challenges can be effectively addressed and managed.
For this audit, we looked extensively into multiple technologies, reviewing documentation and performing field verification inspections at the construction location. The audit confirmed that the client is effectively operating their ASA program. We found no non-compliances related to regulation requirements; no non-conformances related to the requirements of their SMP; and two opportunities for improvement as a part of continuous improvement to their SMP.
2023 Audit Results
Audits and site inspections are an important part of our oversight. We currently manage 16 Safety Management Plans (SMP) and 29 Equivalent Standard Approaches (ESA).
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 non-compliance.
In 2023, we rated nine audits as “effective,” seven audits as “effective, except for.” We did not have any audits resulting in a “not effective” rating.
Audits in 2023 were postponed due to extreme forest fire conditions in Northeastern BC. These audits will be completed in 2024.