6.6 Analysis of preliminary design (including the HazId report) footnote
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6.6 Analysis of preliminary design (including the HazId report) footnote

6.6.1 Procedural intent

  6.6.1.1 For alternative and/or equivalent designs (unless the regulation challenges are deemed insignificant or of negligible impact in terms of safety), a HazId will always be required, as it fulfills the requirement that the basic risk assessment should address the parameters of the submitted design known to this point and evaluate where further scrutiny is justified and necessary.

  6.6.1.2 The Submitter should consider:

  • .1 statements of main conclusions from initial meetings, including key elements of risk that may be examined further;

  • .2 description of HazId procedure applied;

  • .3 documentation in support of any assumptions made;

  • .4 documentation of existing safeguards and control measures;

  • .5 plans and means for proposed safeguards and control measures;

  • .6 levels of agreement within the team and the qualifications and experience of the participated members;

  • .7 points of discussion and further examination, including further analysis and applicable techniques;

  • .8 needs for further in-depth examination of historical evidence/expert judgment or calculations; and

  • .9 sources of information.

  6.6.1.3 When receiving the HazId report and monitoring the session(s), the Administration may consider:

  • .1 whether safety issues have been comprehensively covered (whereas commercial risks in this context are beyond the scope of the Administration);

  • .2 whether all relevant, conceivable scenarios have been considered, ranked and prioritized;

  • .3 whether the composition of the HazId team ensures that all relevant areas of expertise are represented and heard in the process, both from a scientific, theoretical, operational and practical standpoint;

  • .4 whether the qualifications and experience of the participants are verifiable upon request;

  • .5 whether existing and proposed safeguards and control measures are adequate and viable. (The adequate reduction of risk to acceptable level, or plans to perform such reduction in the Final design process, is a condition of preliminary approval.); and

  • .6 whether identified significant hazards can be adequately analysed and reduced by means of the planned detailed risk analysis processes.

  6.6.1.4 The Administration reserves the right to request further participants if certain areas of expertise or experience have not been adequately covered by the team composition as described (an Administration representative may participate to ensure that potential comments from the Administration to the Submitter are covered to the maximum extent possible).

  6.6.1.5 The HazId further serves to clarify and rank all identified hazards. As mentioned above, the HazId is a meticulous, formalized brainstorming process, documenting any contributory factors impacting on safety critical elements. The documentation derived from the process is submitted to the Administration.

  6.6.1.6 If the expert group does not agree on the prioritization of scenarios (or at any other stage where expert judgment is applied), the level of disagreement may be reflected and documented where the scope would be to achieve a "good" level of consensus within the expert group performing the task.

6.6.2 Documentation to be delivered

  6.6.2.1 The Submitter supplies the following to the Administration:

  • .1 full HazId report (also see recommendations in the FSA Guidelines), including the following:

    • .1 prioritized lists of hazards and scenarios (ranking);

    • .2 causal sequences considered; and

    • .3 documentation on background information applied (historical data, sources, impacts, effects, relevance);

  • .2 desired field verifications of measures;

  • .3 related or equivalent systems or subsystems (can equivalence be applied/documented at any given instance);

  • .4 details of the qualifications of the HazId team members as well as the project team members (to ensure the application of sound operational principles and adequate expertise within the team);

  • .5 details on how and based on which evidence consequences and probabilities have been ranked; and

  • .6 any supporting documentation which may potentially validate estimates during the HazId.

  6.6.2.2 Queries by the Administration preceding preliminary approval:

  • .1 To what extent are known and standardized techniques applied in the identification of hazards and which techniques have been applied?

  • .2 Have all relevant areas of expertise contributed to achieve the most comprehensive overview possible?

  • .3 To what extent is the data material (such as material applied for the evaluation of frequencies and consequences) relevant (i.e. derived from similar industries)?

  • .4 To what extent can reliance be placed in the applicability of the data?

  • .5 Are references made to all applied information sources to enable fact-checking?

  • .6 Have criteria for individual risk and societal risk been accepted.


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