How to Work Effectively with Your AsBo and Avoid Pitfalls

Do you have an AsBo?! If so, whatever you do, do not PANIC!!

As I am sure you already know, if a project is deemed ‘Significant’ according to the Common Safety Method for Risk Evaluation and Assessment Regulations (CSM RA), then an independent assessment of the application of the CSM RA risk management process needs to be made by an Independent Assessment Body; commonly referred to as an AsBo.

Now when it comes to working with an AsBo a lot of projects can get quite worked up over it! AsBos can often be seen as being expensive, unhelpful, and all too willing to provide Safety Assessment Reports (SARs) which are NOT supportive of how projects are applying the CSM RA process.

However, often it is the project’s own failings that can lead to multiple reviews being required (time is money after all) and unsupportive SARs being issued.

Early and regular engagement with your AsBo is key, ideally starting as early as the Option Selection stage of your design. This provides the project the opportunity to bring the AsBo on the journey with you and demonstrate how safety has influenced design and hopefully how potential hazards have been eliminated as the project has developed. 

Early engagement will also allow the project to present its approach to safety engineering and get the buy in of the AsBo early, helping to make sure that adequate review periods are also built in to your CSM RA submissions schedule (if you don’t have one, get one!). Whilst obviously the independence of the AsBo cannot be compromised, if you listen carefully then the odd hint and tip can be picked up in terms of what they expect to see moving forwards; but only if you are seen to be really putting the effort into demonstrating the safety of your system.

Regular reviews with the AsBo of your key safety assurance documentation (System Definition, System Safety Plan, Hazard Record, HAZID Minutes, Safety Justification Report etc) can help issues be identified early and make sure that everyone is on the same page. If there are issues with respect to the demonstration of safety then make the AsBo aware; it would not be a good thing for an assessor to find out on their own; rightly wondering what else they haven’t been told about.

When its time to submit your Hazard Record and supporting Safety Justification Report to the AsBo prior to commissioning, it is very important to ensure that you are clear on what safety assurance evidence remains outstanding as well as the who, what, when and how this assurance evidence will be made available. Given that pre-commissioning Hazard Records and Safety Justification Reports need to be submitted sometimes up to 15 weeks prior to a commissioning then clearly not all compliance information will be available. This shouldn’t in theory cause too many issues as long as the project can demonstrate it is still in control and you can demonstrate that this evidence is becoming available as promised during the AsBo review period.

If you need assistance in working with your AsBo to demonstrate your system is being safety integrated and that you have complied with the CSM RA regulations, then let’s talk.

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