Safety, Reliability, Maintenance & Technical Management Plans

A key license requirement for electricity entities under the Electricity Act 1996  is to prepare and periodically revise a Safety, Reliability, Maintenance and Technical Management Plan (SRMTMP). Regulation 31C (2) of the Electricity (General) Regulations 1997  covers the matters that must be dealt with by the plan. SRMTMPs provide an auditable quality approach to industry safety encouraging the continuous improvement of safety systems and technical compliance.

SRMTMPs represent a form of safety case, whereby the regulated entities make a case for the safe operation and maintenance of their facilities and processes according to the requirements of the Regulations. Safety cases are a well established safety process particularly used in the high risk sectors of the petroleum industry. Safety cases combined with good Quality Management procedures indicate the ability to ensure a safe and reliable operation.

The SRMTMP is an all encompassing document relating to the operation of the entity. Occupational Health Safety and Welfare issues form a small component of this document. The major section of the SRMTMP addresses the issues relating to the technical standards, operating and maintenance procedures, and management practices applicable to the entity. The SRMTMP demonstrates the means by which the entity will comply with the direct requirements of the legislation as well as the Standards and Codes called up by the legislation. These Standards and Codes form the technical backbone to ensure the industry is performing with high levels of safety and reliability. The SRMTMP provides a mechanism to review and compare safety and reliability expectations with actual performance.

The SRMTMP and any revision must be approved by the Essential Services Commission of SA  (ESCOSA). Approval of the plan may only be given by ESCOSA on the recommendation of the Technical Regulator. The Technical Regulator may make recommendations and comments to assist the entity in refining the plan before recommending the approval of the plan to ESCOSA. Non-licensed entities must, if required by the Technical Regulator, also prepare and periodically revise a SRMTMP. The Technical Regulator will review and either approve the plan or make recommendations and comments to assist in refining the plan before approving it.

Both licensed and non-licensed entities are required to comply with the approved plan and annually conduct an audit of compliance of the plan, reporting the results of the audit to the Technical Regulator. The Technical Regulator may make recommendations and comments to assist entities refine future audit reports.

SRMTMPs are confidential documents and are not available to the general public.

Annual Reports to the OTR

Electricity entities are required, under Regulation 31D (3) of the Electricity (General) Regulations 1997 , on or before the 31 August in each year, lodge with the Technical Regulator a report relating to the previous financial year containing information on:

• Unsafe, failed or malfunctioned electricity infrastructure and the action taken to rectify, prevent or minimise the risk of recurrence
• Compliance with the Safety, Reliability, Maintenance and Technical Management Plan and whether the plan has been operating effectively.

In June 2002 an agreement was reached with ESCOSA for the submission of this report to be combined with the annual report to ESCOSA, reducing the amount of duplication in reporting. Currently, most generators submit the one annual report to the OTR, a copy of which is then forwarded to ESCOSA.  

The Technical Regulator has exempted some entities from all or part of this reporting requirement, under Regulation 31B (2).