Chris Ballantyne

A Rail Tale In 2005, Parliament passed new legislation to regulate railway organisations and staff to make best use of their new regulatory tools and skillset. safety in . Applying international best practice, As a result, the Transport Agency is changing the way it interacts with the the Railways Act took a goal-based approach that utilised organisations it regulates, and how it the Safety Case concept as the foundation for regulatory measures the success of regulatory interventions. Its experiences are not oversight. This article describes the Transport Agency’s unique among the regulatory community (New Zealand Productivity Commission, experience in implementing this regulatory approach, 2014). particularly the Safety Case concept. The change required the The Railway Story Transport Agency to first recognise that fully harnessing the Railways in New Zealand recently celebrated its 150th year – the first public legislation required a transformational response and then, railway joined Christchurch to Ferrymead along with the wider industry, address the challenges faced in 1863, just 23 years after the signing of the Treaty of Waitangi. The railway in developing and implementing an appropriate regulatory industry has been through peaks and troughs – both in its role as a driving force operating model behind the growth of our nation and in its success in keeping its workers and Railway safety is just one of many areas and continually growing instruction on passengers safe. in New Zealand where a goal-based safety requirements (Robens, 1972). approach has been adopted. Goal-based Regulators are fast building the 1863 – 1983: The emergence of a safety regulation offers the potential skillsets required in response to this nationalised rail network to provide organisations with more change in regulatory practice, supported 17 years after the Provincial Government flexibility in meeting their obligations. by cross-government capability building created the 7km Christchurch-Ferrymead It contrasts with prescriptive-based initiatives such as G-Reg. However, as the link, the network had grown to 1,900km regulation, where government seeks to Transport Agency has found, the change and New Zealand Railways, the national manage risks on industry’s behalf, not is not just about new skills. It is about rail provider, was created. By 1920 necessarily more reliably, by voluminous transformational change to enable railways ran the length of the country and carried 28 million passengers per year - in a country with a population of only a Chris Ballantyne is the Lead Advisor, Rail System Integrity, Transport Access Delivery at the New Zealand Transport Agency million.

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Table 1: Disasters in New Zealand’s early rail history This echoes the findings of a seminal Year Location Fatalities Event 1972 inquiry of worker health and safety 1923 Ongarue 17 to passenger service hit by Lord Robens in the United Kingdom. landslide and derailed Robens proposed focusing on the level of 1936 Ratana 7 Wellington to New Plymouth passenger service safety that must be achieved (the “goal”), overturned due to excessive speed on a corner rather than how it was achieved (Robens, 1943 Hyde 21 Cromwell to Dunedin passenger service 1972). He foresaw prescriptive regulation overturned due to excessive speed on a corner was fatally flawed in that, as complexities 1948 Seddon 6 Picton to Christchurch passenger service grew, it would unacceptably throttle safety overturned due to excessive speed on a corner improvements. Businesses wouldn’t be 1953 Tangiwai 151 Wellington to Auckland passenger service fell able to exploit safety advances or adopt into the Whangaehu River after a lahar sweeps customised approaches. away the bridge

Post 2005: The way forward? As the network continued to grow, the Former Treasury official John Wilson In 2005, Railways Act came into force, safety systems required to manage it grew (Wilson, 2010) wrote that, by 2001: regulating an industry that was far as well. Rail is an activity exposed to low different to that of the previous 140 frequency, high consequence accidents – ’s financial problems were years. Although the national rail provider movement of large objects at speed has now creating visible shortfalls in the returned to government ownership, always meant a complex system of capital asset replacement programme its staff numbers were down to 3,500 controls are required to prevent fatalities. and it operated a network of only 3,700 Vulnerabilities have been learnt the hard The prescriptive-based safety system km (from a peak, 50 years earlier, of way in some cases (see Table 1). strained with the pressures of 5,689km). However, the wider industry The national rail provider took a downsizing, asset deterioration and had proliferated - today there are about strong, but prescriptive approach to safety increased production. Prescriptive-based 100 licensed rail participants using a huge – as all industries of the day did. It created regulatory approaches give a sense of variety of rail vehicles for commuting, a quality management system based on an security because they are comparatively freight, servicing, tourist and heritage ever expanding mountain of rules, policies simple to confirm compliance. However, purposes. and schematics to dictate safety. whether this compliance achieves safety is The commentary for the Railways Act By the 1950s, rail was starting to more difficult to confirm – changing did not identify it as a goal-based decline in popularity as a series of shocks circumstances, such as railways saw over approach, but the principles were there. hit the industry. The widespread uptake those two decades, can easily destroy this The Select Committee sought to enable a of motor cars cut passenger numbers, and link. co-regulatory framework and flexibility in deregulation in the 1970s and 1980s saw a After five Tranz Rail workers died in a how safety requirements were met, and considerable move of freight tonnage to 7 month period (a fatality rate eight times the Act imposed an overarching duty of road. New Zealand Rail had been a higher than the national worker average) care for all rail activities, primarily that government department for most of its the Wilson Ministerial Inquiry was the operator: existence but, struggling to cope with initiated (, these shocks, was turned into a State 2000; Williams, 2000). The Wilson .. must ensure, so far as is reasonably Owned Enterprise in 1982 in an attempt Ministerial Inquiry identifiedpracticable, that none of the rail to turn the industry around. fundamental flaws in the railways activities for which it is responsible regulatory approach. causes, or is likely to cause, the death 1983 – 2005: A struggling system of, or serious injury to, individuals. Government efforts to cut costs and the number of [safety system] restructure to address rail’s profitability documents is in the range of 1,000 to The Act put in place a bespoke ultimately culminated in the sale of 2,000 and the number of drawings is regulator that oversees a licensing regime the national rail provider to a private in the region of 100,000. It would for those operating rail vehicles or consortium in 1993. Staff numbers, appear that the scale of controlling a network. To obtain a licence, peaking at 21,000 in 1982, had dropped to documentation is unmanageable operators must have a Safety Case below 5,000 by this stage. relative to the aim of securing a safe approved by the regulator. The regulator The following decade was one of the system … The sheer extent and has powers to conduct in-depth system hardest in New Zealand rail’s history as coverage of the [regulator] Approved assessments of the operator to verify ownership and investment drifted. The Safety System renders it unwieldly compliance with the Safety Case and other business was renamed Tranz Rail and and probably impenetrable to outside safety documentation. The Act allows the subject to aggressive profit strategies. observers. (New Zealand regulator to intervene more directly if Government, 2000, p.23)

Page 22 – Policy Quarterly – Volume 13, Issue 4 – November 2017 there are immediate safety risks or if non- compliances are detected. What is a Safety Case? However, the decade following the enactment of the Railways Act 2005 Safety Cases originated in the nuclear power industry in the late 1950s but their demonstrated the difficulty in applying a potential value for other high-risk, specialised industries was recognised after goal-based approach on a deeply accidents in the chemical industry (particularly Flixborough in 1974 and Seveso established industry without sufficient in 1976) and then more widely after the Cullen Inquiry into the 1988 Piper appreciation of the change it entailed. The Alpha explosion. potential of the approach was not fully recognised and the regulator was under- Principles of Safety Cases prepared to deliver the altered style and Safety Cases are based on three principles common to most goal-based ap- thinking required to fully exploit it. proaches (Leveson, 2011). Particularly, the oversight of Safety Cases, • Risks must be reduced below a specified threshold of acceptability a powerful tool for implementing a goal- • Those who create risks are responsible for controlling those risks based regime (see boxed text “What is a • Government set safety goals and operators decide the appropriate methods to Safety Case?”) was under-utilised. Instead, achieve those goals a process-based operating model was adopted that focused heavily on The Safety Case delivers on these principles in a way that allows the regulator mechanically auditing activities across all to focus on what is being achieved rather than how it is being achieved, while still operators. providing a degree of assurance as to the quality of the operator’s methods. A key element of a Safety Case is that it is an argument, not a summary. An Recognising the need for transformation argument convinces an audience of a premise – in this case, confidence that an Following the Wilson Inquiry and passing operator can achieve its safety commitments. As with an argument, the rationale in of the new Act, railway deaths and serious a Safety Case must be able to be tested. The United Kingdom’s Defence Standard injuries significantly reduced but, as 00-56 notes a Safety Case to be: has been found before, the absence of accidents is not proof of safety. There was a structured argument, supported by a body of evidence, that provides a uncertainty over the role of the regulator compelling, comprehensible and valid case that a system is safe for a given and the robustness of safety protections. application in a given environment. Change was needed, and the railway Because a Safety Case communicates this rationale for how the operator will industry was fortunate in that its impetus keep safe, it sits apart from the management systems to provide direction and for this change did not come from a integrate them. catastrophic accident, but as part of a When a regulator intervenes in a goal-based approach, it is on the basis general push towards improved regulatory that the operator has not demonstrated it has developed its approach in a robust services by the Transport Agency, the manner and so is unlikely to be able to meet its goals. The regulator is not critiquing industry and other government agencies, particularly in the wake of regulatory the safety approach taken but the method the operator used to determine it. failures such as the 2010 Pike River Mining Disaster. support arrangements within NZTA It was only once the Transport Agency, A number of internal and independent for such a safety critical independent while implementing these tactical reports helped the Transport Agency rail safety regulator function to be less changes, reflected more deeply on the core understand where the gaps lay and became than an acceptable standard. drivers for the problems these reviews the catalyst for a multi-year improvement (Australasian Transport Risk highlighted that it began to recognise that project that is still underway. In particular, Solutions, 2013, p.5) moving to a goal-based regime in rail a report by Australasian Transport Risk safety and delivering the required standard Solutions (2013) made 18 observations The various reviews recommended a of regulatory service was a more and commented: series of tactical changes, such as elevating fundamental shift. the regulator in the Transport Agency A dramatic shift in the regulatory ... there is considerable room for hierarchy, increasing regulatory staff framework, from a prescriptive to a goal improvement. This conclusion is numbers, broadening the skill-base and basis, can have a disorientating impact on based on the results of the performing greater analysis. However the regulators and the regulated if not international benchmarking analysis, none, including the Wilson Inquiry, recognised and can, ultimately, lead to feedback received from the explicitly highlighted the need to move to regulatory failure (Mumford, 2011; Black, stakeholders, and evidence found by a goal-based culture or the challenges this 2014). For instance, New Zealand’s leaky the review team which suggests that would entail. building crisis was partially attributed to the current administrative and such a change. Mumford (2011) noted that

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implementing a pre-planned strategy. This The New Zealand Rail Industry reflected that the transformational nature of the change was only gradually recognised in 2017 after the simpler, task-driven change programme had been begun. In addition, 6,200 workers are employed by, or volunteer for, licensed rail participants in New with the rail industry going through parallel Zealand. Many of these workers are proud to be from a long lineage of rail work- changes, the approach needed flexibility to ers, have known rail all their lives and have seen a number of structural models navigate a shifting environment. come and go. The industry carries 34 million passengers and 18 million tonnes In addition, the change was relatively of freight every year, across 4,260km of rail network, on everything from brand- compartmentalised within the wider new commuter fleets to hand-restored museum pieces. Those licensed to operate Transport Agency. It sought direction railways include: from the senior leadership and values of • KiwiRail, a State Owned Enterprise that employs 3,700 staff. As the national the organisation, but it only had a rail provider, it controls and maintains the 3,744km national rail network and transformational impact on a small operates all national freight and passenger services. number of teams who had direct roles in • Auckland and operate the two metropolitan enabling a goal-based approach to rail commuter services, carrying 32 million passengers every year. safety. Achieving the change did not • Industrial businesses utilising rail to load and move freight on their sites or to require a whole-of-organisation shift. As a service their infrastructure. result, although the changes were deep, • Tourist and Heritage services operating rail services to showcase rail his- they were narrow and more manageable. tory and/or provide tourist experiences. Running excursions on the national Successful change required two network or their own railways, they operate a huge range of vehicles including significant perceptual changes to be made. full-sized heritage locomotives, trams, cable-cars, custom-built rail cars and modified golf-carts. Roles in the regulatory framework To understand its role in the regulatory In addition to this, more than 200 organisations operate rail vehicles under framework, the Transport Agency had to others’ licences, to provide vehicle and infrastructure maintenance services. understand what it meant for the operator to own the risks of its activities – a the haste to move away from an expensive approaches, it was exploring its role as concept that felt contrary to the regulatory (if reliable) standards-based approach to a manager of the national rail system under role. Regulation is enacted to provide more flexible regime resulted in discarding such a regulatory framework. A particular assurance that the risks that society finds previous safeguards without adequate challenge for it was reconciling how its unacceptable are addressed (New Zealand consideration of what was replacing them. safety outcomes related to those of the Productivity Commission, 2014). It is the Mumford commented: operators under its supervision on the responsibility of the regulator to provide network. this assurance, and it is therefore natural for New Zealand moved into an Smaller operators, on the other hand, a regulator to feel most comfortable when unknown future while burning the experienced difficulties in maintaining meeting this duty directly by controlling bridges to its past. the competencies and documentation to the risk itself (for instance, by approving comply with a regulatory framework safety measures) rather than entrusting To be successful, the Transport Agency more often applied to multi-national, management of the risks to the operator. needed to redefine its rail safety role, how high-risk industries than small hobbyist. The challenge became for the Transport it engaged with the industry, and how it They were still looking for clear, Agency to let go of this role and meet its exerted its influence over the industry. prescriptive expectations from the duty through more indirect methods. A cultural change such as this is regulator as to how to be compliant with Some in the industry were coming to referred to as transformational change. It the safety requirements rather than the same conclusion. The rail industry had fundamentally alters the strategy by which moving into a goal-based mind-set. been challenging themselves and the an organisation achieves its objective. Regulator and regulated alike were Transport Agency as to where Existing skills, behaviours and approaches struggling to understand their respective responsibilities and accountabilities lay for are no longer suitable and have to be responsibilities and approaches to safety, and what tools could support clearer adapted, enhanced or replaced meeting those responsibilities in a goal- accountabilities and allow the regulator to (Cummings and Worley, 2009; New based regulatory framework. have confidence the industry would deliver Zealand Productivity Commission, 2014). on their safety commitments. The national rail provider was also Making the changes To enable such an approach, some going through its own transformational The Transport Agency took a learning, regulatory tools, such as the Safety Case, change. Along with a heavy period of asset highly adaptive approach to its rail safety needed to be recognised as being of equal, renewal and developing new safety transformational change, rather than or greater, value to the industry than the

Page 24 – Policy Quarterly – Volume 13, Issue 4 – November 2017 regulator – a fact commented on by Lord Cullen in the Piper Alpha Inquiry. The RAF Nimrod mid-air explosion Haddon-Cave (2009) paraphrased his observations, noting that the purpose of The Haddon-Cave inquiry (Haddon-Cave, 2009) into the loss 14 aircrew after Safety Cases was: British Royal Air Force (RAF) Nimrod XV230 exploded in mid-air serves as one of the most well examined and illustrative studies of the potential weaknesses of to assure [the company] that its Safety Cases. operations were safe ... Whilst the The report made 12 observations, which included the following failures of the Safety Case had a further role in Safety Case process at the RAF demonstrating this to the regulatory 1. Safety Cases had become too long, bureaucratic and contained impenetrable body, this latter function was a matter detail, often simply to give a “thud factor”. of only secondary importance. 2. Safety Cases gave equal attention to minor hazards as they did catastrophic (p.166) hazards.

Becoming a risk-based regulator 3. Safety Cases were routinely outsourced and reduced to mere back-office With the focus on high-level outcomes, paperwork with little appreciation or personal interest in the subject of the moving to a goal-based approach facilitates Safety Case. the Transport Agency in becoming a 4. Safety Cases were a compliance document that looked for evidence to justify a risk-based regulator, as expected of all predetermined answer that the system is safe, rather than look for evidence as agencies (New Zealand Government, to why it might not be. 2017). Previously the Transport Agency 5. Safety Cases were “shelfware”, rather than living documents to keep abreast had taken an across-the-board approach to oversight, working across all areas of of hazards and cultural changes. harm and pursuing serious issues as they Haddon-Cave commented: arose. This was an ineffective approach The Nimrod Safety Case was a lamentable job from start to finish. It was (Sparrow, 2008; Baldwin and Black, 2007) riddled with errors… Its production is a story of incompetence, complacency as it spread Transport Agency resources too thinly and intervention was too and cynicism… The best opportunity to prevent the accident to XV230 was, transient to have lasting effect. tragically, lost. Again, this challenge can generate uneasiness. Becoming a risk-based regulator means consciously de- the Transport Agency and the industry. Safety Cases, in particular, require prioritising other potential sources of The Transport Agency has gained several discipline by the Transport Agency to harm. These sources of harm may still be insights regarding its regulatory role and maintain its regulatory role by following important, but just not as important as being a risk-based regulator through goal-based principles and resist using its others. In addition, there is uncertainty in focusing on this tool. rail technical expertise to double-check decisions as to where the greatest risk is. These insights are similar to many the operator has chosen the appropriate The result is it places a great deal of other industries’ experiences with Safety safety approach. Instead, to ensure that an responsibility on the regulator - what if Cases, such as the Nimrod mid-air operator owns the risks of its activities, the Transport Agency makes the wrong explosion (see boxed text), the Gulf Oil approval needs to be based on the strength choice and it is a different risk that leads disaster (United States, 2011) and as of the operator’s argument. to the next catastrophic accident? Being surveyed by the United Kingdom Health A consequence of this is that the clear about the evidence base (and and Safety Executive (Vectra Group regulator requires broad, rather than limitations of it) and each party’s Limited, 2003). deep, expertise to assess a Safety Case. accountabilities in respect of the targeted Rather than relying solely on rail and risks and general risks helps move beyond safety expertise, to critique the argument the inertia this can cause. Avoid owning the risk the Transport Agency staff also have to A Safety Case doesn’t work well when have expertise in such aspects as change Reflecting these changes through Safety used in a prescriptive way. The natural management, assurance, safety systems Cases tendency is for an operator to describe and governance. The Transport Agency’s re-positioning how it is managing its safety. However, of the Safety Case’s role in the regulatory when a Safety Case descends into nothing Underpin trust with evidence framework has been a core outcome of more than a summary of how the safety In the traditional use of Safety Cases for the change process. Better utilisation of measures are being carried out, all it offers heavy equipment installations, the Safety this tool is both reflecting and driving is paper safety. Case provides confidence by providing many of the changed perspectives within direct evidence of safety. However, for an

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Figure 1: The Safety Case providing a trust framework face complex risks, the flexibility and safety-focus of a goal-based approach remains more effective. In essence, a good • Have they made measurable safety commitments? Commitment Safety Case is as simple as proving an • Have they set clear accountabilities for these commitments? organisation can make good decisions. Focusing its efforts according to risk, • Have they demonstrated that they understand the context they the Transport Agency is looking towards Context will operate in – particularly the risks and barriers to achieving pragmatic solutions that simplify their commitments? requirements without losing the core principles of Safety Cases. This is not • Do they make a robust argument that their management about turning the Safety Case back into a systems can achieve safety commitments? safety system summary or providing • Have they demonstrated that they have the determination, Confidence detailed templates that result in a paint- capability and capacity to carry out their safety activities? by-numbers exercise. The Safety Case still • Are there the hallmarks of a strong safety culture? has to demonstrate the operator’s own safety argument for it to have any value. • Can they justify their decisions? Conclusions Confirmation • Is safety awareness widely embedded? The move away from prescriptive • Are there any warning bells? regulation to the effective use of goal- based tools such as Safety Cases has both empowered and challenged the Transport organisational Safety Case like in railways, such as integration, communication and Agency to better carry out its role in such definitive evidence is not available - capability. achieving the Government’s objectives for particularly when first licensed. A framework-based approach also rail safety. To be successful it had to But rather than requiring blind trust, helps the industry understand they have recognise that the transition is not just a the Safety Case provides the Transport to earn that trust – it’s not just a case of matter of better regulatory practice, but Agency with a framework to structure its “hands-off regulation”. organisational transformation – for both confidence around – a robust and the regulator and the regulated. evidenced argument, embedded in the Simplify but don’t compromise safety cases The Transport Agency is still organisation, that the operator will The Railways Act has imposed a undergoing this journey, but is already achieve its safety commitments (see sophisticated regulatory approach over an recognising important lessons: Figure 1). industry that includes operators with only 1. The move to goal-based legislative This allows the Transport Agency to basic competencies and comparatively approaches is positive for safety, but better understand the value-add of its low risks. The original users of Safety the cultural shift required should not role. Its engagement with operators is Case approaches were high risk, heavily be underestimated – transformational about building confidence in the Safety resourced and complex operators – such change approaches should be adopted Case argument, rather than approving the as nuclear, chemical and extractives and a learning environment safety system approach. industry. Parts of the rail industry are, encouraged. As an example, approval of Safety in contrast, hobbyists. This challenge 2. The industry needs to be involved – it Cases involves site visits. Previously, the has been observed in other sectors where is not something the regulator does operator may have thought (rightly or Safety Cases or similar tools have been behind closed doors. wrongly) that the Transport Agency was applied homogeneously over a diverse 3. As a cultural shift, the change has to approving its specific safety activities. industry (Deighton-Smith, 2008). be deep but it can be achieved However, the Transport Agency visits not Some rail operators may have the right through a focus on the critical as auditors but to gain evidence for a approaches and culture in place, but regulatory staff, rather than more subjective judgement as to whether struggle to join them up as a system and organisation wide. the operator’s safety argument stands up demonstrate it on paper. An operator may 4. Being a goal-based regulator is an and it will achieve its safety commitments. simply not have the competency to uneasy experience – assurance of Regulatory staff may still observe the develop bespoke safety solutions and so safety is based on trust (underpinned adequacy of a rail vehicle or the network rely on standard industry practices. It can with evidence) in the capability and control approach, but as part of building be argued that a more prescriptive willingness of the regulated party, a picture of the organisational approach should be applied to such rather than having the ability to competence, along with their operators (Deighton-Smith, 2008). dictate the “right” solution. observations of more general aspects However, the Transport Agency is 5. Goal-based regulatory approaches confident that, given these operators still support the transition towards

Page 26 – Policy Quarterly – Volume 13, Issue 4 – November 2017 risk-based regulation by stressing the surveys and the Transport Agency’s own doesn’t create it. As Lord Cullen operator’s overall accountability for experiences have highlighted that a commented (Jeffrey 2013): their risks and allowing the regulator cultural transformation among the to focus on the high-level outcomes. regulator and the regulated community is A Safety Case should reflect the Safety Cases and goal-based legislation what enhances safety. A Safety Case helps organisation’s safety culture. If that are not an automatic panacea to demonstrate this has been achieved – it culture is sound and healthy – it organisational safety. Various inquiries, should show.

References Australasian Transport Risk Solutions Pty Ltd. (2013) Independent Review New Zealand Government (2000) Ministerial Inquiry into Tranz Rail Report into Rail Systems Team, downloaded from www.nzta.govt.nz/ Occupational Safety and Health, Wellington: New Zealand Government assets/site-resources/content/commercial/docs/atrs-rail-systems-team- New Zealand Government (2017) Government Expectations for Good review.pdf Regulatory Practice, downloaded from www.treasury.govt.nz/regulation/ Baldwin, R. & Black, J. (2008). Really Responsive Regulation, Modern expectations Law Review, 71, pp. 59 - 74 New Zealand Productivity Commission (2014) Regulatory Institutions and Black, J. (2014) Learning from Regulatory Disasters, Policy Quarterly, Practices, downloaded from www.productivity.govt.nz/sites/default/files/ 10(3), pp. 3 – 11 regulatory-institutions-and-practices-final-report.pdf Cummings, T. G., & Worley, C. G. (2009). Transformational Change, in Robens, A. (1972) Safety and Health at Work: Report of the Committee Organization development and change, pp 505 – 534, Mason, Ohio, 1970–72, London: Her Majesty’s Stationery Office Thomson/South-Western. Sparrow, M. (2008) The Character of Harms: Operational Challenges in Deighton-Smith, R. (2008) Process and Performance-Based Regulation: Control, Cambridge: Cambridge University Press Challenges for Regulatory Governance and Regulatory Reform, in United States. (2011) Deep Water: The Gulf Oil Disaster and the Future of Carroll, P. (Ed) Minding the Gap: Appraising the Promise and Offshore Drilling : Report to the President. Washington, D.C.: National Performance of Regulatory Reform in Australia, pp. 89 – 104, ANU Commission on the BP Deepwater Horizon Oil Spill and Offshore EPress: Canberra Drilling. Haddon-Cave, C. (2009) The Nimrod Review, London: The Stationery Vectra Group Limited. (2003) Literature Review on the Perceived Benefits Office and Disadvantages of UK Safety Case Regimes, downloaded from Jeffrey, K. (2013) Review: Lord Cullen - What Have we Learned from Piper www.hse.gov.uk/research/misc/sc402083.pdf Alpha?, downloaded from www.findingpetroleum.com/n/Review_Lord_ Williams, M. (2000) Industry of Myth and Might (Accidents, Ownership Cullen_what_have_we_learned_from_Piper_Alpha/044b5113.aspx and Change on the Railways), The Dominion, 12/05/2000 (2), pp. 13 Leveson, N. (2011) The Use of Safety Cases in Certification and Wilson, J. (2010) A Short History of Privatisation in New Zealand, Regulation, Journal of System Safety, 47 (6) pp. 1 - 5 downloaded from www.treasury.govt.nz/downloads/commercial/ Mumford, P. J. (2011) Enhancing Performance-Based Regulation: Lessons mixed-ownership-model/mom-shppnz-wilson-dec10.pdf from New Zealand’s Building Control System, Wellington: Institute of Policy Studies School of Government Brown Bag seminars – open to all Join lively, topical presentations and Zealand Primary Health Care Strategy discussions in an informal setting at the • Strategic public procurement: a School of Government. These Brown Bag research agenda sessions are held the first Monday of most • What role(s) for Local Government: months, over lunchtime. Past topics have ‘roads, rates and rubbish’ or ‘partner included: in governance’? • Intergenerational wellbeing and public • Human capital theory: the end of a policy research programme? • A visual exploration of video • How do we do things? surveillance camera policy We would welcome your attendance and practice and/or guest presentation, if you are • The role of financial risk in the New interested. Contact us to go on the mailing list for upcoming sessions at [email protected]

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