Validation versus Verification

Australian Regulatory Summary

All facilities within Australian Commonwealth fall under The Offshore Petroleum
Act 2006 (OPA 2006). The National Offshore Petroleum Safety and Environmental
Management Authority (NOPSEMA) is the government body which administers this.
Supporting this act are the Offshore Petroleum and Greenhouse Gas Storage
(Safety) Regulations [OPGGS(S)R] 2009 which set out the requirements for the
contents of safety cases and set out general requirements for Validation
and Verification.

Australian Regulatory Summary - The validation process (as detailed in with verification. Validation is a purely
Key Requirements NOPSEMA Validation Guideline N-04200- documentation review exercise that can,
1. N
 OPSEMA requests validation (this is GL0525, section 4.4) in theory, be completed before or by the
their stated policy for all new facilities Validation is primarily a process early stages of construction, provided
and significant modifications). undertaken by an independent sufficient documentation on the design,
2. N
 OPSEMA / Operator reach agreement competent party, namely the Validator, construction and installation of the SCEs
on the scope of validation, i.e. what to ensure that the design, construction has been made available to the Validator
safety-critical elements of the facility and installation of the Safety Critical and all comments resolved. Verification
are required to be validated and Elements – SCEs - (safety-critical generally requires someone to physically
against which codes and standards. hardware, firmware and software, check that, for example, safety-critical
3. T
 he scope of validation is agreed by including instrumentation, process equipment has been installed correctly
NOPSEMA in writing and Validation layout and process control systems) of and in-situ is fit for its function and use
commences (if not already under way). the facility will incorporate appropriate and is, in the main, a surveillance, witness
4. O
 perator submits facility safety case. measures that will protect the health and manufacturing/test documentation
5. Safety
 Case assessment underway and safety of persons at the facility. review activity. The inclusion of elements
(including formal comment from Note that Validation activities related to of verification within a Validation scope
NOPSEMA). construction and installation are limited is potentially problematic, particularly for
6. V
 alidation finalised and “clean” to a review of related documentation fixed facilities.
Statement delivered. (for example inspection and test plans,
7. Safety case final decision-making. welding plans, etc), and do not include For example, verification that a piece
8. V
 erification is a separate process which physical survey of equipment. of safety-critical equipment is fit for
applies throughout, in parallel with its function and use often can only be
and continuing after Validation. Validation, as referred to in the conducted once the equipment has
legislation, should not be confused been installed.

Working together
for a safer world
However, this equipment cannot be NOPSEMA require that Validation be Validation of:
installed until a safety case, which documented as a separate assurance – design is the review of design
provides for the installation of process, provided for by the regulations documentation against nominated
equipment, has been accepted by and tied to safety case decision making. codes and standards in order to form
NOPSEMA, and any acceptance of a a view about the appropriateness of
safety case related to such a proposed What is Validation? the standards for the safety critical
modification to a facility can only occur Validation is the process required in elements and to confirm that they
if the operator has provided a suitable order for an operator to obtain Safety are consistent with the Formal Safety
Validation statement as part of the safety Case acceptance. The operator will Assessment (Safety Case).
case assessment process. produce a Scope of Validation (SoV) to – construction and installation are
be agreed by NOPSEMA. A Validator reviews of documentation to ensure
Consequently, NOPSEMA require that will perform a Validation in accordance that the intent of the design is specified
verification be documented as a separate with this scope and issue a Validation to be carried forward into actual
and distinct process from Validation and Statement which allows NOPSEMA to be facility build. Typically this would
generally should be addressed within assured that the design, construction and include construction and installation
the safety case for the facility rather installation of safety critical systems will specifications such as piping or
than documented in combination incorporate measures that protect the structural fabrication specifications,
with Validation. health and safety of persons to the extent procedures such as anchor pile
required by the scope of Validation, installation procedures, and inspection
Regulations on safety case contents provided the agreed codes and standards and test plans. Again, the codes and
requirements, such as Regulations are implemented as specified in the standards must be appropriate
2.12, 2.14(2), 2.18 and 2.22(3), detail documentation reviewed by the Validator. and consistent with the Formal
verification requirements that must be Validation of design, construction and Safety Assessment.
addressed in the safety case for a facility. installation can be defined as follows.
As such, it is possible for Validation
to be completed before construction
is complete and prior to installation
Scope of Scope of Safety Case Safety Case
as it covers forward-looking
Validation Validation Submitted to acceptance by project documentation.
Submitted to agreed by NOPSEMA NOPSEMA
NOPSEMA NOPSEMA The scheduling and relationship
by operator between the Scope of Validation, the
Validation and Safety Case acceptance
NOPSEMA NOPSEMA is illustrated.
Review and Review and
comment comment
period period 90 What is Verification?
Verification is not required in relation to
the acceptance of a Safety Case but is a
requirement within the Safety Case. The
Validator performs Validation Safety Case will contain a commitment
from the Operator that a suitable
verification process has been performed.
Verification is the determination that
Validation “the safety critical elements have actually
Statement issued been designed, constructed, installed,
to operator by tested and commissioned in accordance
Validator for with the nominated codes and
submission to standards”. It is the ‘physical’ survey of
NOPSEMA to
the onshore procurement, construction,
testing and pre-commissioning and the
Verification
offshore installation, testing and final
commissioning.
NOPSEMA’s Legislation and Regulations web link: http://www.nopsema.gov.au/legislation-and-regulations/
NOPSEMA’s Validation web page: http:// www.nopsema.gov.au/safety/safety-case/validation/

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