3319 Technical workshop proceedings: Process safety management framework

1. Background

1.1  Introduction

In 2010, the EI published the PSMF, which defines what PSM should involve. Divided into four focus areas (process safety leadership, risk identification and assessment, risk management, and review and improvement) and sub-divided into 20 'elements', it sets out a framework of activities major accident hazard organisations should undertake to ensure PSM. Each element lists a number of high level activities organisations should meet (expectations).

EI PSMG is a series of 20 publications ('guidelines') that build on the PSMF. Commissioned by the EI Process Safety Committee (PSC) each guideline captures and presents current industry good practices and guidance on how organisations can meet the expectations set out in each element of the PSMF.

The PSM workshop was convened to enable reflection on the PSMF and PSMG, with a view to optimising the resources going forward.

Key topics discussed during this workshop included the following:

• Tips for implementation in businesses (nature of the business: large vs. small, corporately vs. individual business units).
• International application (use of PSMF and PSMG by international companies, use where there is limited local legislation, viability of transposing the framework to an international standard).
• Using PSMG performance measures (PMs).
• Any omissions in the framework and what should be added if revised.
• Communicating the PSMF and PSMG to leaders through to workers.
• Conflicting systems (integrating systems that are essentially all the same).

1.2 Documentation

• High level framework for process safety management.
• Guidance on meeting expectations of EI process safety management framework:
  • Element 1: Leadership, commitment and responsibility
  • Element 2: Identification and compliance with legislation and industry standards
  • Element 3: Employee selection, placement and competency, and health assurance
  • Element 4: Workforce involvement
  • Element 5: Communication with stakeholders
  • Element 6: Hazard identification and risk assessment
  • Element 7: Documentation, records and knowledge management
  • Element 8: Operating manuals and procedures
  • Element 9: Process and operational status monitoring, and handover
  • Element 10: Management of operational interfaces
  • Element 11: Standards and practices
  • Element 12: Management of change and project management
  • Element 13: Operational readiness and process start-up
  • Element 14: Emergency preparedness
  • Element 15: Inspection and maintenance
  • Element 16: Management of safety critical devices
  • Element 17: Work control, permit to work and task risk management
  • Element 18: Contractor and supplier, selection and management
  • Element 19: Incident reporting and investigation
  • Element 20: Audit, assurance, management review and intervention

1.3 Workshop agenda

The following agenda was issued for the workshop:

3. Afternoon sessions

3.1 Session 1 – Continuous improvement of the framework and guidelines – What needs to be improved?

• Framework
  • What should be added?
    • Commercial management.
    • HSE requirements (ALARP).
    • COSHH/DSEAR requirements.
    • Operational excellence.
    • Visibility of leadership/culture.
    • Human factors.
    • Environmental.
    • How PSM is interpreted.
    • Consider elements added by other businesses.
    • Inherent safety needs to be visible in the framework.
  • What should be removed?
    • No parts were suggested to be removed.
  • What should be modified?
    • Duplication in Element 7 and 8, and Element 10 and 18. It was suggested to maybe combine these elements.
    • Re-align focus areas.
  • Have you found alignment or conflict with other systems?
    • Difference between asset integrity and process safety.
    • Consider terminology: e.g. 'expectation' vs. 'requirements'.

A discussion started on the following elements:

• Element specific discussions
• Element 14 Emergency preparedness – Capturing worse case

It would be beneficial to look at worst case/low probability incident. It was noted that emergency response should be defined by risk assessment, using a risk matrix.

• Element 15 Inspection and maintenance

It was noted that the title might be misleading. Consider integrity rather than inspection and maintenance.

• Element 16 Management of safety critical devices (SCDs)
  • Defining SCD criteria.
  • Safety critical function e.g. safety critical control functions.
  • Basis for defining criticality on a register of SCDs.
  • Is it a function of the system?
  • Degree of criticality.
  • If not on register it is considered not critical?
  • Giving wrong direction in some cases.
  • Explicit reference to environmental issues e.g. safety and environmentally critical elements (SECE).
• Guidelines

Despite the number of downloads, it was noted that there was a lack of awareness of the guidelines. Increased marketing would be beneficial to create awareness and clarify purpose. It was suggested that it would be beneficial to differentiate between minimum requirements and guidance.

It was noted that the guidelines could have different uses:

• as review tool;
• as audit too;
• as reference, or
• use in their entirety.

It was suggested to create a tool or guidance which would aid implementation of the guidelines.

• Suggested PMs

It was agreed that the PMs were useful to measure 'process steps'.

It was noted that some PMs were identical across elements. This is purposeful and enables their aggregation up to board level reporting (see Element 20). In-line controls are for reality checks on site.

3.2 Session 2 – Learnings from implementation

• What has gone well?
  • Integrated PSM into SSHE management system (not adding another system).
  • Customised EI PSMF into business management system (use of evidence statements).
  • Can be used to benchmark across businesses – share best practices.
  • Use of spider diagrams.
• What could have gone better?
  • More helpful guidance on SCDs.
  • Lack of senior management support/sponsorship.
  • How to implement PSM in diverse businesses.
  • Better marketing of PSMF and PSMG.
  • Acknowledging that implementation depends on size of the business and available resource.
  • Recognising the difference in need for smaller independent vs. major organisations and in upstream vs. downstream oil and gas sectors.
• What would you do differently to overcome these issues?
  • Drive from senior management/ sponsorship.
  • Start by getting support from CEO.
  • Detail the benefits for implementation.
  • Develop an awareness presentation which would promote the benefits of implementation.
  • Liaise with insurers.
  • Timeframes (resource, implementation).
  • Degree of bias.
  • Faster delivery of PSMG.
  • Promote where there is no local legislation.
  • Aim resources to regions with less mature legislation.
  • Develop a tool or guidance to aid implementation.

3.3 Summary of key workshop findings

Revision of PSMF and PSMG was proposed, and this could be covered by the following key issues:

• Rationalise principles, e.g. process safety vs. asset integrity vs. operational excellence.
• Combine some elements, e.g. inspection/maintenance and SCDs.
• Revise some elements, e.g. define criticality of SCDs, consider SCD scope (e.g. refer to SECE), review stakeholder engagement vs. American Chemistry Council 'responsible care'.
• Add some new elements, e.g. environmental management, having carefully defined its boundaries (from major accidents to the environment (MATTEs) through to operational environmental issues such as waste, energy and permits).
• Define key terms such as 'operations envelope', 'minimum requirements', 'expectation' vs. 'requirements' (to align with ISO management systems standards).
• Link 'evidence' to elements/expectations.

Participants also encouraged EI to develop tactics for successful implementation guidance.

The workshops findings, and the detail that builds on them, will be evaluated by PSC with a view to improve the PSM resources, e.g. by revising PSMF, and in due course, revising PSMG, and considering developing implementation guidance.

Annex B Presentations

B.1 Introduction on the history of EIPSM – John Pond

B.3 Application of high level PSMF to ageing assets – Mahmoud Gawish

B.3 Building Process Safety Management Capacity - Gavin Ramsden

B.4 Introduction to Operational Excellence - Graham Beale