Approval is a somewhat fraught topic among regulators and people who write standards, but perhaps hardly on the radar of most practising engineers. AS 2885.0-2008 has an apparently clear definition. This is the entirety of Section 3:
The concept of approval is fundamental to the Standard.
Approval by the Licensee demonstrates that the Licensee has accepted responsibility for the safety and integrity of the pipeline.
Items requiring approval are identified in each part of the Standard.
Approval requires a conscious act and is given in writing.
The Licensee’s approval can only be given by the Licensee or under the authorized written delegation of the Licensee; however, the responsibility for approval can not be delegated.
There is a slightly different definition in AS 2885.1-2007:
Approved by the Licensee, and includes obtaining the approval of the relevant regulatory authority where this is legally required. Approval requires a conscious act and is given in writing.
Standards Australia committee ME-038 is currently working on harmonisation of some topics that cut across the various Parts of AS 2885, and one of those topics is approval. It’s not appropriate for me to preempt the outcome of that harmonisation process, other than to note that it reiterates the fundamental importance of approval, and is likely to go into more detail of what needs approval and how it should be approved.
One of the possibly contentious aspects of approval is the extent to which approval is required by the regulator in addition to the pipeline Licensee. The Standard has to sidestep that because each State or Territory jurisdiction has its own philosophy of approval, and they vary markedly.
Some jurisdictions have a fairly hands-off approach whereby they put strong reliance on the competence of the pipeline Licensee’s approval and do mostly high-level checks on compliance with AS 2885. Others get quite involved through participation in technical discussions and safety management study workshops, and still others in effect delegate the technical aspects of approval to a third-party verifier. There is no right or wrong, best or worst among these diverse regulatory attitudes. All have advantages and disadvantages for both parties.
I get a strong sense that all regulators feel they have an important duty to protect the public against the potentially catastrophic consequences of pipeline failure, whether caused by accident or incompetence. Sitting on the outside looking in, I’m guessing that working out how to best identify incompetence might be one of the bigger challenges for the regulators.
In the discussion on a previous post there was concern about approval of departures from the Standard (as permitted by Clause 1.6.2 of AS 2885.0, subject to justification and approval). I think each jurisdiction needs to determine its own approach to this, and it may be a greater or lesser issue depending on the jurisdiction’s general philosophy of approval. For approval of departures from the Standard, being able to distinguish competent from half-baked justifications is probably going to be a large part of it.